Clifford Chance

"Enforcement needs to be loud and in your face", according to Therese Chambers, joint executive director of enforcement and market oversight at the FCA. On 11 April 2025, Ms Chambers delivered a speech at the Spring Conference of NYU's Program on Corporate Compliance and Enforcement where she highlighted the FCA's enforcement priority on tackling financial crime.

The FCA has highlighted that one of its key enforcement priorities over the next five years will be in relation to money laundering and fraud.

While the FCA has an "open mind" to the use of new technology to support use of risk-based controls, there will be a focus on policing AML systems and controls issues and other failings.

Likewise on fraud, a "major priority" where fraud by regulated firms will simply "not be tolerated," the FCA has "record levels of prosecutions underway." There was also a warning shot: "I hope your firms and clients have robust anti-fraud controls in place. If you provide banking for fraudsters, we will scrutinise those controls with care." This is an indication that as well as going after fraudsters, which can take time, banks providing support to them can expect to find themselves within the FCA's sights and potentially facing regulatory action far quicker. Set against the new corporate criminal offence of failing to prevent fraud, there is a real emphasis on the fact that banks' controls in this area need to be up to standard: "Firms need to have the right systems and controls in place to catch those transactions that raise suspicions or warrant further analysis."

Firms will need to ensure that their systems and controls are up to date and effective. The FCA will be looking closely at any allegations of money laundering or fraud which were facilitated (knowingly or unknowingly) through firms. Firms must also ensure that they have effective training on these issues so that employees are alive to and report suspicious conduct.

The speech also referenced crypto, and the fact that the FCA has excluded from the UK, many firms which it says have controls that are not adequate: only 50 out of 351 firms that applied for registration were approved.

Finally, the speech emphasised individual accountability and responsibility: "Enforcement action isn't just about firms, it's also about individual accountability and responsibility."

With reportedly fewer new investigations being opened than in recent years, the FCA's approach will inevitably include more early interventions and supervisory actions. However, the risks remain as ever before, and the speech goes some way to potentially debunk the theory that the UK government's priority of economic growth will mean less enforcement in these areas.