On 7 August 2026, the Financial Conduct Authority (FCA) issued a Statement setting out that it is concerned about a number of risks among unregulated lenders, safe custody providers, money brokers and financial leasing companies (Annex 1 firms). Firms including unregulated lenders, safe custody providers, money brokers and financial leasing companies, need to be registered with the FCA for anti-money laundering purposes.

Concerns

In particular, the FCA is concerned that such firms are relying too heavily on the financial crime controls of their parent company. It reminds such firms they must assess whether the financial crime controls of the parent company are appropriate for their financial crime risks, governance and operations and that they also cannot rely on off-the-shelf procedures designed for a different company. Each firm must have controls tailored to the way they operate and the risks they need to manage.

The FCA is also concerned about the risks to consumers and markets from unregulated lending often conducted through complex structures, including special purpose vehicles. 

Closer scrutiny

To address these risks, the FCA states that it is closely scrutinising applications to register as an Annex 1 firm and as such firms should expect registration applications to take longer.

Information request

The FCA has also sent an information request to around 900 Annex 1 firms to improve its understanding of their activities, business models and risks. This follows on from the work the FCA did with 300 Annex 1 firms in late 2025 and means the FCA will have contacted all registered Annex 1 firms.