The FCA publishes its updated Financial Crime Guide (FCG) in the April 2025 edition.

The FCA's updated Financial Crime Guide (FCG) for April 2025 is a comprehensive resource designed to help regulated firms counter financial crime risks across various business lines.

Here are some key aspects:

1. Detailed Guidance: The guide offers in-depth advice on Anti-Money Laundering (AML), sanctions compliance, fraud prevention, and anti-bribery measures.
2. Self-Assessment Questions: Firms can use these questions to evaluate their financial crime controls and identify areas for improvement.
3. Enhanced Focus Areas: The guide emphasises the importance of robust customer due diligence, ongoing monitoring, and navigating complex international sanctions regimes.
4. Practical Tools: It provides practical tools and scenarios to help firms implement best practices and comply with legal requirements.
5. Enhanced AML Frameworks: The guide provides more detailed guidance on Anti-Money Laundering (AML) practices, emphasising the importance of robust customer due diligence and ongoing monitoring.
6. Sanctions Compliance: There is a stronger focus on sanctions compliance, with practical examples and scenarios to help firms navigate complex international sanctions regimes.
7. Fraud Prevention: The guide includes new case studies and self-assessment questions to help firms more effectively identify and mitigate fraud risks.
8. Anti-Bribery Measures: Enhanced guidance on anti-bribery frameworks, including best practices for preventing, detecting, and responding to bribery and corruption.
9. Case Examples: Real-world examples illustrate common pitfalls and effective strategies in financial crime prevention.

This updated guide aims to raise the bar for effective financial crime prevention, helping firms protect themselves and their clients more effectively.

References

• Financial Crime Guide: A firm's guide to countering financial crime ... https://www.handbook.fca.org.uk/handbook/FCG.pdf
•  PS24/17: Financial Crime Guide updates | FCA - Financial Conduct Authority https://www.fca.org.uk/publications/policy-statements/ps24-17-financial-crime-guide-updates

OTHER STANDOUTS ARE SHOWN BELOW:

🔍 Risk-Based Systems and Controls - The FCG emphasises a risk-based approach, requiring firms to tailor financial crime systems proportionally to their size, structure, and exposure. This includes:
• Senior management accountability under SM&CR.
• MI that captures risk exposure, emerging threats, and control effectiveness.
• Internal audit and oversight that’s genuinely independent, well-resourced, and risk-driven.

🧠 Governance and Tone from the Top - Leadership is critical. The FCA expects boards and senior managers to demonstrate:
• Proactive ownership of AML/CTF controls.
• Regular review of risk assessments and policies.
• Clear escalation routes for high-risk relationships and red flags.

🛡️ Customer Due Diligence: No Shortcuts - Enhanced scrutiny is expected for:
• Complex or opaque corporate structures.
• High-risk countries or sectors.
• PEPs and correspondent banking relationships.
• Electronic ID tools are welcomed—but must be understood, tested, and used cautiously.

📊 Transaction Monitoring and the Role of AI - The FCG highlights automated and AI-driven monitoring but warns that:
• Systems must be tuned to fundamental typologies.
• Human challenge remains essential.
• New tools like machine learning should be documented and explainable, mainly when used to triage alerts.

🔐 Ongoing Monitoring and Source of Funds - Firms are expected to:
• Update CDD dynamically based on customer behaviour.
• Scrutinize sources of funds and wealth—not only for PEPs but also across high-risk profiles.
• Consider blockchain and off-chain analysis where cryptoassets are involved.

🌍 Regulatory Integration - The FCG reinforces alignment with the following:
• SYSC requirements, Consumer Duty, and COCON principles.
• Money Laundering Regulations, EU Funds Transfer Regulation, and JMLSG guidance.
• Public-private partnerships and intelligence sharing under the Economic Crime and Corporate Transparency Act 2023.

References

• Financial Crime Guide: A firm's guide to countering financial crime ... https://www.handbook.fca.org.uk/handbook/FCG.pdf
• PS24/17: Financial Crime Guide updates | FCA - Financial Conduct Authority https://www.fca.org.uk/publications/policy-statements/ps24-17-financial-crime-guide-updates