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FCA Reviews Financial Crime Controls in Corporate Finance

07 November 2025

FCA Reviews Financial Crime Controls in Corporate Finance

The FCA published review of financial crime controls in corporate finance firms. 

 

The report includes a review of financial crime controls across a sample of corporate finance firms, identifying both good and poor practices in how firms manage money laundering (ML), bribery and corruption risks.  

Key findings include: 

➡️ Some firms lacked a clear financial crime risk assessment tailored to their business model, with inadequate consideration of bribery and corruption risks; 

➡️ Customer Due Diligence (CDD) was often inconsistent, with some firms failing to verify source of wealth or funds, especially for high-risk clients; 

➡️ Enhanced Due Diligence (EDD) procedures were not always applied appropriately, particularly for Politically Exposed Persons (PEPs) and complex transactions; 

➡️ Suspicious Activity Reporting (SAR) procedures were not well understood by staff in some firms, and training was often generic or infrequent; and 

➡️ Governance and oversight varied, with some firms lacking clear accountability for financial crime compliance or failing to escalate risks appropriately.  

✅ Firms should strengthen their financial crime frameworks by conducting robust risk assessments, applying proportionate CDD and EDD, and ensuring staff are adequately trained and supported to identify and escalate concerns. 

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