FCA Section 55 Cancellation: Triggers and How to Respond
A Section 55 cancellation is one of the most serious regulatory actions the FCA can take — it removes the firm’s permission to carry on regulated activities. Understanding what triggers it, how the process unfolds, and what options are available is essential for any regulated …
FCA Application Timelines: Realistic Expectations for 2026
The FCA’s statutory six-month deadline is the ceiling, not the expectation. In 2026, most well-prepared applications from straightforward firm types are determined in three to four months. Applications with gaps, novel business models, or incomplete SMF submissions routinely run to five or six months — …
From TCF to Consumer Duty: What Changed in the Obligation
Treating Customers Fairly and Consumer Duty cover much of the same ground. But the differences in how each obligation operates — in governance, evidencing, enforcement and the standard of outcome expected — are material. Firms that treat Consumer Duty as TCF with a new name …
Vulnerable Customers in Wealth Management: A Practical Guide
Identifying vulnerable clients is one of the most technically and ethically demanding obligations the Consumer Duty places on wealth managers. Done well, it protects clients at the moments they most need it. Done as a compliance exercise, it generates documentation that satisfies no one. The …
EDD Triggers: High-Risk Countries, Sectors and Products
Enhanced due diligence is not a catch-all for any customer the firm is uncertain about — it is a defined set of measures triggered by specific risk factors. Knowing precisely when EDD is required, and what it must involve, is fundamental to a compliant and …
Transaction Monitoring Tuning: Balancing Detection and Noise
Transaction monitoring is only as good as its calibration. A system generating hundreds of unactionable alerts daily is not more effective than one generating ten meaningful ones — it may be less effective, because alert fatigue erodes the quality of the human review that makes …
MLR 2017 Firm-Wide Risk Assessment: Structure and Content
The firm-wide risk assessment is the foundation of every AML compliance programme. Without a well-structured, specific and regularly updated risk assessment, a firm’s AML controls — however individually sound — are built on uncertain ground that will not withstand FCA scrutiny. Regulation 18 of the …
Sanctions Screening for Payment Firms: Speed vs Accuracy
For payment firms processing thousands of transactions per day, sanctions screening creates a direct tension between two non-negotiable requirements: screening must be comprehensive enough to catch genuine matches, and it must be fast enough not to disrupt the payment processing that customers depend on. Sanctions …
Tier 1 and Tier 2 Conduct Rules: Who They Apply To
The SMCR Conduct Rules apply to virtually everyone working at an FCA-regulated firm — but they do not apply equally. The distinction between Tier 1 (Individual Conduct Rules) and Tier 2 (Senior Manager Conduct Rules) determines what each person is required to do and, critically, …
Reasonable Steps Under SMCR: What the FCA Looks For
“Reasonable steps” is the central concept of SMCR personal accountability — and the FCA’s track record in enforcement shows exactly what it means in practice. This is not an abstract standard. The FCA assesses it against concrete questions about what the SMF holder knew, what …
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