Nested Financial Crime Risks in Correspondent Banking
VideoNested relationships in correspondent banking can expose firms to hidden financial crime risks. Learn how to improve oversight, transparency and monitoring.
This week, the Financial Conduct Authority (FCA) sends a clear message of its expectations of firms in supporting customers who face higher costs, including mortgage rate changes, and warns that weak outcomes may lead to supervisory and enforcement action.
More widely, the 10th Regulatory Initiatives Grid helpfully lays out the next wave of coordinated work across UK bodies.
Elsewhere, the FCA’s multi-firm review of credit rating agencies underlines how governance, controls and consistent methods can build trust in wholesale markets. And the FCA calls for a system-wide response to financial crime, with more data sharing, joint working and risk-based focus.
We conclude this week with a Call for Input on tokenisation in wholesale markets (open until 3 July 2026) with the potential to transform markets and support UK competitiveness.
The FCA has reminded firms to strengthen support for customers facing cost pressures, stressing that the Consumer Duty requires firms to put customer needs first and avoid foreseeable harm.
Firms should actively monitor outcomes and adapt as circumstances change. Key expectations include:
The FCA highlighted practical steps such as flexible payment arrangements, early engagement ahead of mortgage rate changes, and clearer signposting to debt advice.
Firms are expected to now prioritise:
The FCA concludes by reminding firms that supervisory and enforcement action will follow poor outcomes or weak responses.
Read more on supporting customers through challenging times
Regulators have published the tenth edition of the Regulatory Initiatives Grid, giving firms a forward view of upcoming activity across UK authorities. The Grid, released on 19 May 2026, sets out the pipeline of initiatives to help firms plan for operational impact and prioritise resources.
The Forum behind the Grid brings together key regulators including the Bank of England, PRA, FCA and others to improve coordination and reduce duplication for firms.
Key takeaways for firms:
The Grid reflects ongoing collaboration across regulators, including joint work on payments and pension reform, and supports the Government’s wider financial services agenda.
Read more on Tenth edition of the Regulatory Initiatives Grid
The FCA has set out findings from its multi‑firm review of UK credit rating agencies (CRA), focusing on surveillance, methodologies and internal controls. This builds on the review from November 2025.
The regulator reinforces that ongoing surveillance is a core requirement, not a periodic exercise, with annual reviews only the minimum standard. Weak governance, inconsistent methodologies or poor controls risk undermining rating integrity and market confidence.
Key takeaways for firms include:
The FCA also highlights that use of AI and models can enhance surveillance, but only with effective governance and challenge.
Firms should now review their frameworks, conduct gap analysis and implement remediation where needed, as the FCA will continue supervisory engagement and may undertake targeted reviews.
Read more on credit rating agencies multi-firm review
The FCA has warned that financial crime is becoming more organised, technologically advanced and interconnected, posing risks to both economic stability and national security. Victims lose an average of £25,000 with proceeds flowing back into criminal enterprises funding serious crime.
Nikhil Rathi set out a clear direction of travel for firms, regulators and law enforcement: a fragmented approach is no longer sufficient.
Speaking at the FCA’s financial crime conference, key points to note include:
The FCA also highlighted practical shifts: greater information sharing, investment in analytics and detection tools, and deeper joint working across sectors and jurisdictions.
Firms should act now to review their financial crime frameworks, focusing on collaboration and information sharing. They should also consider how they prioritise risks and deploy technology to improve detection and response.
Read more on the financial crime speech
The FCA and Bank of England have issued a joint Call for Input setting out a shared vision for tokenisation in wholesale markets. Authorities position tokenisation as a potentially transformative shift, with benefits including improved efficiency, liquidity, transparency and reduced risk.
Key points for firms:
Authorities also highlight priority initiatives, including the Digital Securities Sandbox and the DIGIT pilot, to test issuance, trading and settlement in practice.
Firms can respond to the Call for Input until 3 July 2026.
Read more on the call for input, the future of tokenisation
UK Regulatory Handbook 2026
An essential guide to the regulatory landscape for financial services
Nested relationships in correspondent banking can expose firms to hidden financial crime risks. Learn how to improve oversight, transparency and monitoring.
A practical overview of the FCA’s 2026 wholesale markets priorities, highlighting key risks in financial crime, market abuse and conflicts of interest, and what firms should do to strengthen controls and governance.
Practical guidance on preparing for an FCA sanctions compliance review, covering regulatory expectations, programme readiness and how to respond effectively.