This month's updates span asset management authorisations, financial crime controls, crypto asset regulation, appointed representative, SMCR reforms and Consumer Duty developments, alongside important insights from the Financial Ombudsman Service and wider policy initiatives.
We have provided a comprehensive overview of all the notable regulatory developments this month in our full report, which you can download via the link below.
The FCA's review of asset management authorisations highlights a clear message, which is that firms must present well-structured, complete and tailored applications. Weak or generic submissions remain a key driver of delays and refusals, with 1 in 7 applications withdrawn or rejected due to poor quality.
The FCA's multi-firm review of customer due diligence (CDD) processes reinforces the importance of risk-based, well-documented and consistently applied frameworks.
Firms are expected to move beyond a tick-box approach, with particular focus on:
Failure to evidence robust financial crime controls may lead to increased supervisory attention, even where minimum requirements appear to be met.
Regulation of cryptoassets remains a key area of focus. The FCA's latest consultation on perimeter guidance aims to clarify when firms will require authorisation under the UK's future crypto regime.
Firms will need to undertake detailed, early analysis of their activities, particularly where they operate across borders or serve UK clients, and align business models with the FCA's "substance over labels" approach.
Alongside this, HM Treasury proposals seek to refine the regulatory framework, including clarifications for stablecoin-related activities and efforts to balance innovation and appropriate safeguards.
The regulatory spotlight remains firmly on the Appointed Representative (AR) regime. Both consultation responses and FCA reviews emphasise that principals retain full responsibility for oversight, even when ARs are inactive.
Firms are expected to:
A lack of effective oversight may be interpreted as a broader governance weakness, increasing the likelihood of supervisory intervention.
Reforms to the Senior Managers and Certification Regime (SMCR) aim to reduce administrative burden while maintaining accountability.
Key changes include:
The FCA continues to emphasise that Consumer Duty is no longer about implementation, but about evidencing outcomes.
Firms are expected to demonstrate:
OFSI’s new strategy and FCA enforcement activity highlight increased regulatory focus on sanctions compliance, client money protections, and illegal financial promotions and crypto activity.
For a full coverage of this month's regulatory developments, download the complete report via the form below.