FCA AML Supervision of Annex 1 Firms

Introduction

Annex 1 firms occupy an unusual position in the UK regulatory landscape. They are registered with the FCA for anti-money laundering supervision, but are not necessarily authorised under FSMA or subject to the FCA’s wider conduct rulebook. That distinction is often misunderstood by firms, counterparties and customers.

Following the FCA’s Dear CEO letter to Annex 1 firms, and its continued focus on financial crime controls, firms need to be able to evidence that their AML framework is tailored to their actual business model, customer base, products, services, jurisdictions and delivery channels. This webinar will take a practical look at the FCA’s key concerns, and the steps firms should be considering in response.

What You Will Learn

This webinar will cover the following:

• What an Annex 1 firm is, and the important distinction between FCA AML registration and FSMA authorization
• When a firm may need to register with the FCA for AML supervision
• The key weaknesses identified by the FCA in its Dear CEO letter to Annex 1 firms
• How to check whether a firm’s actual business model still matches its FCA registration and financial crime controls
• Practical steps for reviewing business-wide risk assessments and customer risk assessments
• Common weaknesses in CDD, EDD, ongoing monitoring and suspicious activity reporting procedures
• How senior management should evidence ownership, oversight and challenge of financial crime risks
• What firms should be able to produce if the FCA asks for evidence of gap analysis, remediation and testing
• Practical 30-day and 90-day action points for firms reviewing their AML framework

This pre-recorded webinar will be available to view from Friday 4th December 2026

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