CP26/38: Financial Crime Guide updates

Key dates

2026-10-23

FCA consultation CP26/38 opened and published.

2026-12-24 Deadline

Deadline for submitting responses to the FCA consultation.

2027-10-01

The FCA describes the new cryptoasset regime as applying from October 2027; the precise commencement date should be confirmed against the final legislation and FCA rules.

Suggested considerations

• Compliance teams may wish to review the proposed changes and submit consultation responses through the FCA online form by 24 December 2026, particularly where the proposals would create material implementation costs or operational challenges.
• Firms should consider mapping current fraud, AML/CTF, sanctions, proliferation-financing, data-security and financial-crime systems-and-controls frameworks against the consultation themes, while recognising that the proposals are not yet final guidance.
• Cryptoasset businesses and firms intending to provide regulated cryptoasset services may wish to assess readiness for the new regime expected in October 2027, including AML/KYC controls, blockchain analytics, Travel Rule processes, sanctions screening, transaction monitoring and governance.
• Firms using AI or external technology providers for transaction monitoring, customer screening or other financial-crime controls should consider documenting model governance, validation, parameter testing, explainability, human oversight, data security, third-party oversight and retention of decision records.
• Senior management and boards may wish to review whether financial-crime management information, risk assessments and escalation arrangements adequately cover proliferation financing, sanctions evasion, cryptoasset risks and reliance on outsourced or AI-enabled controls.
• Firms may wish to monitor the FCA's final Policy Statement and consolidated Financial Crime Guide, since the final text may differ from the consultation proposals and is likely to inform future supervisory assessments.

What changed

No new binding rules have been made by this consultation. The FCA proposes to revise non-Handbook guidance and practical examples in the Financial Crime Guide to reflect emerging risks and regulatory developments, including AI and third-party tools used in financial-crime controls, cryptoasset-specific risks, evolving financial and trade sanctions, proliferation financing, data security, fraud, and AML/CTF systems and controls. Independent commentary on the FCA's wider financial-crime and cryptoasset work indicates that firms should expect increased focus on enterprise-wide risk assessments, sanctions and AML governance, management information, onboarding and beneficial-ownership controls, outsourced-control oversight, transaction monitoring, blockchain analytics, Travel Rule compliance, a

Who is affected

• FCA-supervised banks and building societies subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• Annex 1 financial institutions supervised by the FCA for financial crime
• FCA-registered cryptoasset businesses and firms preparing for authorisation under the UK cryptoasset regime
• FCA-supervised investment, payments, e-money, lending, wealth-management and other firms with financial-crime obligations

Related regulations

• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• Regulation 18 of the Money Laundering Regulations 2017
• Regulation 18A of the Money Laundering Regulations 2017
• UK financial sanctions legislation
• UK trade sanctions legislation
• Senior Management Arrangements, Systems and Controls sourcebook (SYSC)
• UK cryptoasset regime expected to apply from October 2027