CP26/38: Financial Crime Guide updates

Although this is a consultation rather than final rules, compliance teams should treat the direction of travel as a signal of where FCA supervision is heading. Firms should map existing financial crime systems and controls against each proposed area, assess exposure to AI and cryptoasset risks, validate sanctions and proliferation financing screening, and review data security and ML/TF controls. Cryptoasset firms should begin readiness planning for the proposed regime from October 2027.

A board-level gap assessment, owner allocation and remediation roadmap would be prudent, alongside a formal consultation response where relevant. Early action can reduce enforcement risk, strengthen customer trust and support safe innovation, while delayed preparation may create remediation pressure as expectations crystallise.