Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the “MLRs”), businesses that carry on certain financial activities, but which are not authorised under the Financial Services and Markets Act 2000, must register with the Financial Conduct Authority (“FCA”) for anti-money laundering (“AML”) supervision. These businesses are commonly referred to as Annex I financial institutions.
Lending is the most common Annex I activity. It covers a broad range of credit, including commercial lending, credit agreements relating to immoveable property, factoring and the financing of commercial transactions. Other Annex I activities include financial leasing, offering guarantees and commitments, safe custody services and money broking.
Registration is not authorisation. Annex I firms are supervised by the FCA for AML purposes only. They are not subject to the wider FCA Handbook, but they must be able to show that they comply with the MLRs in full.
A significant proportion of Annex I firms are real estate lenders. This includes bridging lenders, development finance providers and commercial property lenders, where the lending falls outside the scope of regulated mortgage activity. These businesses are often established through dedicated lending vehicles or special purpose vehicles (“SPVs”), funded by private capital, family offices or investor loan notes.
Property has long been recognised as a sector exposed to money laundering risk. High-value assets, complex ownership structures, offshore borrowers and third-party funding all increase the importance of knowing who a lender is dealing with, where the money comes from and where it is going. A real estate lender sits at the centre of these flows and is expected to manage those risks accordingly.
The FCA has made clear that Annex I firms, and unregulated lenders in particular, are a supervisory priority. In August 2026 it published a statement confirming that it is applying increased scrutiny to the sector. The key messages are:
This is not a theoretical concern. In October 2026 the FCA announced that restrictions had been placed on six unregulated lenders following concerns about their AML policies, controls and procedures identified during the assessment of their applications. The restrictions limit their ability to take on new customers or to do new business with existing customers, including extending existing credit. In one case, the firm is required to run down its existing loan book in an orderly way.
The FCA has also reminded regulated firms that deal with Annex I firms, such as banks, brokers and funders, that they must carry out their own due diligence, including seeking direct confirmation of registration status. Registration alone is not a substitute for that due diligence. In practice, this means that weak AML arrangements at an Annex I lender can also affect its access to banking, funding and distribution.
Taking into account the nature, scale and complexity of its business, an Annex I lender should be able to evidence:
Suntera UK is a regulatory solutions provider with deep experience in AML and financial crime compliance, supporting a wide range of regulated and Annex I firms. We help real estate lenders meet FCA expectations in a way that is proportionate to their business and works in practice. Our support includes:
Our support can be provided on a project basis or as an ongoing arrangement, and can be tailored to the size and risk profile of your business, whether you are a new lender preparing for registration or an established lender responding to an FCA information request.
If your firm carries on Annex I lending activity, is preparing to register with the FCA, or is unsure whether its current arrangements would withstand FCA scrutiny, please contact Max Cunningham or Mike Booth to discuss how we can help.
The information in this publication is intended for general guidance only and should not be applied to individual circumstances without professional advice.
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Managing Partner
mike.booth@suntera.com
Senior Associate
max.cunningham@suntera.com
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