Source of funds vs source of wealth: getting the distinction right
Source of funds vs source of wealth: getting the distinction right Source of funds and source of wealth are two distinct customer due diligence concepts that are regularly conflated in practice. The confusion is understandable — both concern the origins of a customer’s money, and …
PEP screening in practice: dealing with false positives at scale
PEP screening in practice: dealing with false positives at scale PEP screening generates more false positives than almost any other component of a regulated firm’s customer due diligence process. A common name, a partial name match, an incorrectly configured screening threshold — each of these …
UK MLRO salary 2026: what an MLRO earns by firm type and size
UK MLRO salary 2026: what an MLRO earns by firm type and size The Money Laundering Reporting Officer role has changed significantly over the past five years. Increased FCA enforcement activity, the expansion of the sanctions compliance function into most MLRO remits, the growing sophistication …
Outsourcing the MLRO function: when it works and when it doesn’t
Outsourcing the MLRO function: when it works and when it doesn’t The question of whether an FCA-regulated firm can outsource its MLRO function — and if so, how — is one that generates significant confusion. The answer depends on the firm’s regulatory category, its size, …
Hiring an MLRO in 2026: a recruitment guide for FCA-regulated firms
Hiring an MLRO in 2026: a recruitment guide for FCA-regulated firms The Money Laundering Reporting Officer is one of the most consequential senior hires an FCA-regulated firm makes. It is a personal accountability role — the individual who holds SMF17 under SMCR is personally responsible …
Building a whistleblowing culture: lessons from FCA enforcement cases
The FCA’s interest in whistleblowing culture extends well beyond the formal requirements of SYSC 18. Enforcement cases, thematic reviews, and the FCA’s continuing focus on non-financial misconduct have repeatedly revealed that the quality of an organisation’s whistleblowing culture is one of the most reliable early …
The Whistleblowing Champion (NED): who should fill the role and what they actually do
The Whistleblowing Champion is one of the most misunderstood appointments in the SMCR framework. Firms that are required to have one frequently confuse it with the executive whistleblowing function, underestimate what the role demands of the individual who holds it, and make appointments based on …
Best execution under COBS: what RTS 28 disclosures still require
Best execution has been a regulatory priority since MiFID II came into force in January 2018. The UK’s onshored version of RTS 28 — the Regulatory Technical Standard requiring investment firms to publish annual best execution reports — has created a disclosure obligation that many …
COBS suitability assessments: where firms most often fail FCA scrutiny
Suitability remains one of the FCA’s most consistent enforcement and supervisory priorities for investment firms. COBS 9 and 9A set out the requirements for personal recommendations and discretionary management, but the gap between what the rules require and what firms actually deliver in practice is …
Conduct rules breach reporting: what the FCA expects from your firm
The Notification Obligation in Plain Terms Under the Senior Managers and Certification Regime, firms that have taken disciplinary action against an employee for a breach of the Conduct Rules must notify the FCA. This notification obligation sits within the FCA’s Supervision manual (SUP 15) and …
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