FCA Compliance, End to End
Built for firms regulated by the Financial Conduct Authority — covering the Money Laundering Regulations 2017, FCA Handbook SYSC 6.3, the Proceeds of Crime Act 2002, and SAR filing to the National Crime Agency through its SAR Portal.
The UK's Conduct & Financial Crime Supervisor
The Financial Conduct Authority (FCA) regulates the conduct of around 35,500 firms in the United Kingdom — banks, payment institutions, electronic money institutions, investment firms, consumer credit lenders, and crypto-asset businesses. It supervises conduct of business and firms’ financial crime systems and controls. HM Treasury sets the policy framework — it owns the Money Laundering Regulations and houses the Office of Financial Sanctions Implementation (OFSI) — but the FCA supervises independently.
The UK's anti-money-laundering framework is built on three statutes: the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — usually called the MLRs — the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000. The FCA Handbook adds supervisory expectations on top, primarily in the Senior Management Arrangements, Systems and Controls sourcebook (SYSC), and in the Financial Crime Guide.
The FCA enforces actively. Recent years have seen multi-million-pound fines for inadequate transaction monitoring, weak CDD, and slow SAR filing — including individual sanctions against MLROs and senior managers under the Senior Managers & Certification Regime.
A Layered Framework — Statutes, Regulations, Handbook
UK AML obligations are set across primary legislation, statutory regulations, and FCA Handbook chapters. One Constellation maps to all of them.
Money Laundering Regulations 2017
The core statutory framework — risk assessment, CDD, EDD, ongoing monitoring, record keeping, and the appointment of an MLRO. Amended substantially in 2019, 2022, 2023 and 2026.
Proceeds of Crime Act 2002
Defines the predicate money-laundering offences, the SAR filing duty under sections 330–332, and the consent / Defence Against Money Laundering (DAML) regime for proceeding with reportable activity.
FCA Handbook — SYSC 6.3
Senior management responsibilities for financial crime, requirements for systems and controls proportionate to risk, and the standing requirement for an effective AML control framework.
Financial Crime Guide & Thematic Reviews
The FCA's published examples of good and poor practice — non-binding but treated as the de facto benchmark by supervisors during firm visits and skilled-person reviews.
Crypto-Asset Registration
Crypto-asset exchange providers and custodian wallet providers must be registered with the FCA under the MLRs — with the same CDD, monitoring, and Travel Rule obligations as regulated financial firms.
Senior Managers & Certification Regime
Personal accountability for the MLRO and senior managers responsible for financial crime — including direct enforcement risk for the named SMF17 holder.
What the FCA Requires — and How We Address It
Across the MLRs, POCA, and SYSC the same operating obligations recur. Here are the seven the FCA examines most closely.
Firm-Wide Risk Assessment (Reg. 18)
Every regulated firm must conduct and maintain a documented business-wide risk assessment covering customer, geography, product, transaction, and delivery-channel risk.
Customer Due Diligence (Reg. 27–28)
Identify and verify every customer using independent sources. For corporates, identify beneficial owners holding more than 25% and the persons exercising control.
Enhanced Due Diligence (Reg. 33)
EDD is mandatory for PEPs, business involving a country on the FATF call-for-action list, transactions that are unusually complex or unusually large for their type, and any other situation presenting higher risk.
Ongoing Monitoring (Reg. 28(11))
Scrutinise transactions throughout the relationship to ensure they are consistent with the firm's knowledge of the customer, the customer's business, and the source of funds.
Sanctions Screening (UK Sanctions List)
Screen every customer and counterparty against the UK Sanctions List — since 28 January 2026 the single source of UK designations, replacing OFSI’s Consolidated List — plus UN, EU, OFAC and other relevant regimes.
SAR Filing to the NCA via the SAR Portal
File a Suspicious Activity Report under POCA s.330 to the National Crime Agency through the NCA SAR Portal — the route that replaced SAR Online — as soon as suspicion arises.
MLRO & SMF17 Accountability
Appoint an MLRO. Under SM&CR, the SMF17 holder is personally accountable for the firm's financial-crime systems and controls, with the FCA empowered to enforce against them individually.
FCA Enforcement Has Real Teeth
FCA financial-crime enforcement has grown sharper year on year. Penalties combine financial fines, public censure, and individual accountability under SM&CR.
What FCA-Aligned Compliance Looks Like
Common Questions
The UK Framework in Detail
The FCA supervises against a framework assembled from several instruments rather than one. This guide works through how they fit together in practice.
UK MLR 2017 and What the FCA Expects — the Money Laundering Regulations 2017 read alongside SYSC 6.3 and POCA — risk assessment, CDD, the MLRO function and SAR filing to the NCA.
PEP Categories and RCAs — the three PEP categories, what RCA covers, and how the FATF risk-sensitive approach to domestic PEPs differs from regimes that mandate enhanced measures for all.
Suspicious Activity Reporting — the internal path from alert to filing, the tipping-off prohibition, and what makes a report useful to the FIU.
The controls these require are identity verification, transaction monitoring, enhanced due diligence and SAR workflow.
FCA Compliance, Done Properly
See the MLR workflows, OFSI screening, and NCA SAR export live — with the actual templates and evidence trail your FCA supervisor will ask for.
