On 7 October 2021, the FCA published an analysis of the annual financial crime data returns (REP-CRIM) for the 3 reporting periods between 2017 – 2020. For these periods the FCA received a total of 5,685 REP-CRIM submissions from over 2,300 different firms.

The key observations of the analysis include:

  • Firms reported approximately 89,000 Politically Exposed Persons (PEP) as customers in 2019/20 and 2018/2019, a substantial decrease from approximately 111,000 PEP customers in 2017/18, in part attributed to the amendment of the FCA guidance in 2017 to exclude the reporting of certain domestic customers as PEPs.
  • Wholesale financial markets firms account for 67% on average of the 180 submissions received reporting non-EEA correspondent banking relationships. This is indicative of the complexity of services this sector provides which spans multiple jurisdictions.
  • Retail banking firms have reported approximately 390,000 high risk customers in 2019/2020 which is almost half the high-risk customers reported by all firms (far exceeding firms from other sectors). This is reflective of the sector’s business models which increase their exposure and vulnerability to being used for the purposes of money laundering, as reflected in the National Risk Assessment 2020.
  • The number of suspicious activity reports (SARs) reported to the National Crime Agency has increased, from 394,048 in 2017/2018 to 480,202 in 2019/2020 (c.22% increase).
  • The number of firms reporting automated sanctions screening is increasing year on year, with a 16.5% increase over the 3 reporting periods. However, the investment management sector has the highest number of firms that do not use automatic screening.
  • For the year 2019/20, firms which submitted the REP-CRIM collectively employed approximately 17,000 full-time equivalent staff in financial crime roles, this compares to approximately 15,700 in 2017/2018.
  • A total of 761,437 customers were exited during the 2019/20 reporting period, which has more than doubled in the last 3 years. This was about 0.16% of total customers across all submissions that year. Retail lending and retail banking sectors have exited the most customers for each of those years.