| Date Issued: | 23/10/2026 | Applicable to: | All firms | |
| Link(s): | CP26/38: Financial Crime Guide updates | FCA CP36/38: Financial Crime Guide updates | |||
Context
The FCA is consulting on proposed changes to its Financial Crime Guide. Fighting financial crime is a priority in the FCA’s 5-year strategy. The FCA wants the Guide to continue to help firms understand FCA expectations, and to assess and strengthen their financial crime systems and controls so they are effective and proportionate to their risks.
Key points to note and next actions
The FCA has proposed changes in the following areas:
- Fraud
- Cryptoassets
- Financial and trade sanctions
- Proliferation financing
- Data security
- Financial crime system and controls
- Money laundering and terrorist financing
- Consequential changes
The CP also looks at how the FCA could change the way it gets feedback on the Guide in the future. This could include holding a series of in-person or online Q&A sessions or publishing targeted, standalone guidance without prior consultation, where it is not required. This guidance would then be consolidated within the Financial Crime Guide at a future date.
Specific proposed changes are set out in Chapter 2 of the Consultation, and include updates to the Fraud Chapter (Chapter 4 of the Guide):
- Anti-fraud controls and complaint handing in firms (with a focus on APP fraud).
- Proceeds of fraud – detecting and preventing money mules.
- Firms’ use of the National Fraud Database (NFD) and money mule account detection tools.
- Combating romance fraud – prevention, detection and supporting victims.
The FCA also includes commentary on and plans to share examples of good and poor practice for, onboarding., monitoring, and reporting.
The FCA is proposing updates to Chapter 7 of the Guide to set out its expectations and examples of good and poor practice. In particular, the FCA proposes to cover trade alongside financial sanctions, reflecting developments in the UK’s sanctions framework including the establishment of OTSI. Paragraph 2.19 in the Consultation sets out the FCA’s specific proposed guidance in this regard.
The FCA is also proposing amends to the guidance in relation to proliferation financing, data security, financial crime systems and controls, money laundering and terrorist financing, and other consequential changes.
The FCA welcomes feedback all stakeholders on the proposed changes via the response form on its website, or by emailing: cp26-38@fca.org.uk. The deadline for responding is 24th December 2026. The FCA will consider all responses and publish feedback on this CP, along with the final amended text of the Guide, in a Policy Statement. Feedback will also inform future updates to the Guide.