FCA seeks comment on proposal to expand scope of financial crime reporting obligations

The FCA first issued its financial crime reporting obligations for certain firms in July 2016. In a consultation paper published last month, the agency explained it currently assesses whether the financial crime reporting obligations apply by looking at firm type, “irrespective of revenue threshold (e.g. banks, building societies, and mortgage lenders); and “activity type and total revenue of £5 million (U.S. $6.7 million) or more—for example, intermediaries, e-money institutions, and consumer credit firms.”

Approximately 2,500 of the 23,000 firms the FCA supervises under 2017 money laundering regulations submit these annual reports, according to the agency.

“We propose extending our requirements to include firms that carry on regulated activities that we consider potentially pose a higher money laundering risk,” the FCA said. “This extension will be irrespective of a firm’s revenue threshold.” Specific examples mentioned by the FCA include crypto-asset exchange providers and custodian wallet providers.

The FCA said, at the moment, it doesn’t intend to extend the financial crime reporting requirements to firms “that carry on activities we consider have a lower money laundering risk,” but that it “may consider doing so in the future and would consult on any changes.”

All firms, irrespective of whether they are required to provide such information, “should continue to assess their systems and controls, including through assessments against relevant financial crime publications, to identify and manage money laundering risks,” the FCA said. “They should also be able to evidence the steps they have taken to manage that risk.”

The consultation period closes Nov. 23.