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Welcome to our weekly round-up for UK financial services regulation. Paul Staples summarises the key announcements and developments. Be sure to subscribe to receive our updates in your inbox every week.
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This week’s regulatory developments have moved away from the recent flurry of activity from the Financial Conduct Authority (FCA) and reflect a sharpened focus on financial crime and international competitiveness. The National Crime Agency’s (NCA) 2025 priorities, developed with the FCA and HM Treasury, signal a coordinated push against fraud, sanctions evasion, and professional enablers, especially in light of geopolitical tensions, indicating that financial crime frameworks of firms will be under scrutiny.
Meanwhile, the Office of Financial Sanctions Implementation’s (OFSI) proposed enforcement reforms aim to streamline investigations and incentivise cooperation, while HM Treasury’s confirmed MLR changes will clarify customer due diligence expectations and close regulatory gaps, without overhauling legislation.
Elsewhere, the Prudential Regulation Authority’s (PRA) low-impact Rulebook updates and the FCA’s rollout of the UK–Swiss market access agreement show how regulators are balancing clarity, proportionality, and global reach.
NCA sets 2025 crime priorities
The NCA in collaboration with the FCA, Home Office, and HM Treasury, has published its 2025 system priorities to guide the regulated sector’s response to economic crime. These priorities aim to help firms allocate resources effectively while maintaining regulatory obligations.
Key takeaways:
The priorities focus on threats such as fraud, terrorist financing, sanctions evasion, and money laundering typologies linked to serious organised crime
Professional enablers—those who facilitate criminality through negligent or dishonest conduct—are a central concern, especially in relation to sanctions evasion tied to the Russian invasion of Ukraine
A new System Prioritisation Governance Group (SPGG) will oversee implementation and coordination
Firms should review the priorities and align their financial crime controls accordingly. Guidance will continue to be issued via UKFIU, the FCA, and relevant regulators.
The OFSI has launched a consultation proposing significant changes to its civil enforcement processes. The aim is to improve transparency, efficiency, and proportionality in handling breaches of financial sanctions.
Key proposals include:
Penalty discounts for voluntary disclosure and cooperation
A new Settlement Scheme for monetary penalty cases
An Early Account Scheme (EAS), allowing subjects to provide a full factual account early in investigations
A streamlined process with indicative penalties for reporting and licensing offences
Revised statutory penalty maximums, including for Russia-related asset reporting and the UK Maritime Services Ban
These reforms are designed to reduce burdens on both OFSI and regulated firms, while enhancing public enforcement delivery.
Firms should review the proposals and consider responding to the consultation to help shape future enforcement practice.
HM Treasury has published its response to the 2024 consultation on the Money Laundering Regulations (MLRs), confirming targeted reforms to improve effectiveness while reducing unnecessary burdens.
The response outlines changes to:
Clarify customer due diligence (CDD) triggers and expectations, especially for non-financial firms
Strengthen system coordination between supervisors and law enforcement
Close regulatory loopholes and improve proportionality in risk-based approaches
Notably, the government will address several issues through updated guidance rather than legislative change—highlighting the importance of supervisory consistency and industry engagement.
Firms should review their CDD frameworks and prepare for updated guidance, particularly around digital identity and beneficial ownership.
The PRA has published a suite of low-impact amendments to its Rulebook and policy materials, aimed at improving clarity and alignment with international standards.
Key proposals include:
Solvency II Firms: Removal of subjective language and outdated references in the definition of ‘parent undertaking’
Interest Rate Risk (IRRBB): Updated shock scenarios in Rule 9.11 to reflect Basel Committee revisions, effective from 1 July 2026
Benchmarking: Deletion of the Benchmarking of Internal Approaches section, aligning with the UK’s post-EU regulatory stance
Solvency II Corrections: Minor fixes to formatting and links following the 2024 reforms
MREL Statement: Updates to SS16/16 to remove outdated links and clarify current PRA practices
Comments on the consultation are invited by 2 September 2025. Responses should be sent to LIAP@bankofengland.co.uk.
The FCA has launched a new initiative under the Berne Financial Services Agreement (BFSA), inviting UK and Swiss firms to express interest in cross-border wholesale financial services. This move aims to reduce regulatory friction and enhance the UK’s global competitiveness.
Under the BFSA, UK firms can provide wholesale services in Switzerland without needing Swiss authorisation, relying instead on UK rules. Similarly, Swiss firms can serve UK high net worth and professional clients without UK authorisation. The FCA is also working with Swiss regulators to establish mutual supervisory arrangements and a streamlined registration process.
With UK-Swiss financial services trade nearing £5 billion in 2024, this agreement marks a significant step in strengthening international ties and supporting growth in wholesale markets.
Firms interested in participating can register via the FCA’s new BFSA page.
Explore key insights from the latest Financial Ombudsman Service complaints data and how they can guide better practices and outcomes in financial services.
In a recent review of risk management in payments firms, the FCA identified continuing shortcomings in wind-down plans. We look at the FCA’s findings and how firms can enhance their approach.
