We are reminding regulated firms they need to undertake proper checks when dealing with unregulated lenders, safe custody providers, money brokers and financial leasing companies – also known as 'Annex 1' firms. There are around 1,200 of these firms registered with us for solely anti-money laundering purposes. Our powers are currently limited to looking at how these firms are meeting their anti-money laundering obligations and they are not subject to our wider rulebook. This regime is based o...
AI Analysis
The FCA statement reminds regulated firms to perform robust due diligence on 'Annex 1' firms—unregulated lenders, safe custody providers, money brokers, and financial leasing companies registered solely for AML purposes—due to their limited oversight and heightened financial crime risks. This matters because Annex 1 firms (approx. 1,200) are not subject to FCA's full rulebook, conduct rules, or protections like the Financial Ombudsman Service, exposing regulated firms to contagion risks if they fail to manage interactions properly. Non-compliance could lead to regulatory scrutiny, enforcement, or reputational damage amid FCA's ongoing AML focus.
What Changed
No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.
What You Need To Do
Verify Annex 1 registration status directly from the firm and via independent checks (e
Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA
Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending
Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e
Key Dates
2024 - FCA letter to CEOs of Annex 1 firms raising AML concerns.- **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**
Compliance Impact
Urgency: High – This amplifies existing AML due diligence requirements amid FCA's 2025-30 financial crime strategy, with evidence of supervisory action (2024 letter, 2025 follow-ups). Failure risks enforcement, as Annex 1 interactions could facilitate financial crime or consumer harm without FOS protections; firms should audit exposures immediately to align with BWRA/CRA expectations and avoid findings like those in FCA's risk assessment review.
We have opened an enforcement investigation into Market Financial Solutions Limited (MFS). MFS is an Annex 1 business, which is solely registered with and supervised by us for its compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.Annex 1 registered firms are not authorised or subject to wider FCA regulation.MFS entered administration on 25 February 2026.
AI Analysis
The FCA has opened an enforcement investigation into Market Financial Solutions Limited (MFS) following the firm's entry into administration on 25 February 2026, amid allegations of serious financial irregularities, fraud, and double-pledging of collateral. This investigation is significant because it represents regulatory scrutiny of an Annex 1 business—a firm with limited FCA oversight—whose collapse exposed structural weaknesses in private credit markets and raised questions about due diligence practices across the financial sector.
What Changed
The FCA's enforcement investigation does not introduce new regulatory requirements but rather represents the regulator's response to alleged breaches of existing obligations. The key regulatory framework under which MFS is being investigated is:
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017: MFS's primary regulatory obligation as an Annex 1 registered firm.
What You Need To Do
*For MFS and its Administrators
Cooperate fully with the FCA enforcement investigation
Preserve all documentation related to AML/CTF compliance, customer due diligence, and transaction monitoring
Provide access to bank accounts, transaction records, and compliance files to investigators
Respond to FCA information requests within specified timeframes
Key Dates
25 February 2026- MFS entered administration
20 March 2026- FCA enforcement investigation opened (current date context)
No specific deadline providedfor investigation completion or enforcement action
KasimGaripoglu has been banned from working in UK financial services. The FCA found he is not fit and proper because of his lack of honesty and integrity. Mr Garipoglu is the owner of a firm that provided online trading of foreign exchange and contracts.Between April 2012 and December 2022, including when Mr Garipoglu was the chief executive and director at the firm and an approved person, he repeatedly demonstrated a disregard for regulatory requirements, undermined compliance and anti‑money...
The latest report from the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) finds there is still room for improvement. The anti-money laundering supervisors of professional services firms are more effective than at any time since 2018. However, OPBAS remains concerned that their enforcement lacks the teeth to deter firms from falling short of minimum standards.OPBAS’s latest report found Professional Body Supervisors (PBSs) generally continue to demonstrate good levels o...
The Upper Tribunal has upheld the FCA’s decision that Rangecourt SA (formerly Banque Havilland), Edmund Rowland, the former London CEO and Vladimir Bolelyy, a former Bank employee, acted without integrity. The Tribunal agreed with the FCA that significant fines should be imposed, deciding that fines of £4m, £352,000 and £14,200 were appropriate for Rangecourt SA, Mr Rowland and Mr Bolelyy respectively. The Tribunal also upheld the FCA’s decision to ban Mr Rowland and Mr Bolelyy from working i...
We’re working closely with the Office of Financial Sanctions Implementation (OFSI), UK law enforcement, and our regulatory partners to tackle the abuse of cryptoassets and associated money‑laundering activities. Read the full blog on the OFSI’s website.
The FCA has secured a confiscation order of £265,523.96 against Andrew Currie. Mr Currie was convicted in 2023 and sentenced to 2 years 6 months imprisonment for defrauding investors through the collapsed peer-to-peer lending platform Collateral (UK) Ltd.He diverted funds from Collateral investors and used them for personal gain, including the purchase of a property in Spain.At a hearing at Southwark Crown Court on 9 January 2026, Mr Currie was ordered to pay £265,523.96. This amount represen...
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.