FCA consults on Financial Crime Guide updates covering fraud, sanctions and cryptoassets
The UK Financial Conduct Authority has published consultation paper CP26/38 proposing changes to its Financial Crime Guide. Responses are due by 24 December 2026.
On 23 October 2026 the UK Financial Conduct Authority (FCA) published consultation paper CP26/38, which proposes changes to its Financial Crime Guide. The FCA says the changes are meant to help firms strengthen their systems and controls against financial crime.
The FCA lists the areas it proposes to change: fraud; cryptoassets, to reflect a new regime from October 2027; financial and trade sanctions; proliferation financing; data security; financial crime systems and controls; and money laundering and terrorist financing. The FCA explains that since the guide was last updated, the UK sanctions regime has changed, cryptoasset regulation has developed, and firms have increasingly adopted AI and third-party tools for their financial crime controls.
According to the FCA, the consultation is relevant to firms it supervises for financial crime, including those supervised under the Money Laundering Regulations 2017 such as Annex 1 financial institutions and cryptoasset businesses. It may also interest trade and professional bodies.
The consultation closes on 24 December 2026. The FCA says it will consider all responses and then publish feedback and the final text of the Financial Crime Guide in a Policy Statement. It is also exploring Q&A sessions and standalone guidance on timely issues, which would later be brought into the guide.
Why it matters to AML professionals
Regulators use their own published guidance as a benchmark when they review a firm's financial crime controls. A change to that guidance can shift what a supervisor expects to see in a firm's risk assessment, monitoring and screening. AML professionals at UK-supervised firms can use the consultation period to check where their own controls may fall short of the proposed text.
Red flags in this case
- Customer funds moved through mixing services or privacy-focused crypto tools with no clear business reason
- Trade payments routed through intermediaries in third countries for goods that could have military uses
- A customer's stated business does not match the size, speed or counterparties of its payments
- Repeated small inbound payments from many unrelated people followed by fast outbound transfers
If this landed in your queue
- Read the consultation paper and list each proposed change that touches your firm's products and customers
- Compare the proposed text against your current risk assessment, procedures and monitoring rules, and note any gaps
- Check that you can explain how any third-party screening or AI tool reaches its results before relying on it to close alerts
- Share the gaps with compliance leadership and decide whether to respond to the FCA before 24 December 2026
Key terms
- Financial Crime Guide
- FCA guidance describing the systems and controls it expects firms to use against financial crime.
- Annex 1 financial institution
- A firm carrying out certain financial activities, such as some types of lending, that is registered with the FCA only for anti-money laundering supervision.
- Policy Statement
- An FCA document that responds to consultation feedback and sets out the final rules or guidance.
Interview angle
A regulator has proposed updates to its financial crime guidance. How would you assess the impact on your team?
Explain that you would map each proposed change to your firm's products, compare it with current procedures and controls, record the gaps with owners and deadlines, and consider responding to the consultation.
Sources
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