Financial services growth and competitiveness strategy

On 29 April 2025, the Chancellor of the Exchequer, Rachel Reeves, announced that the government will publish its first ever financial services growth and competitiveness strategy on 15 July 2025, alongside her Mansion House address. FinTech has been identified as a priority growth opportunity within financial services.

FCA to simplify supervisory communications

On 24 April 2025, the FCA published a press release about simplifying supervisory letters.

The key points to note are:

• Portfolio letters discontinued. From 30 April 2025, the FCA will stop issuing and publishing portfolio letters. It will publish a small number of market reports instead. These include communications relevant to various types of firms and include insights from the FCA's supervisory work.

• Website clarity and accessibility. The FCA will make it easier for firms to find current supervisory communications by retiring outdated portfolio and Dear CEO letters, clearly marking these as 'historical' while keeping them publicly accessible via existing links.

• Continued use of Dear CEO letters. These will still be used to alert senior managers to significant issues that require action.

Firms should continue referring to existing portfolio and Dear CEO letters until the new market reports are published later in 2025. The FCA is reviewing its approach to other historical communications and will consider how it can routinely review outdated material.

FCA presence in the US and Asia-Pacific

On 15 April, the FCA published a press release announcing that it is establishing a permanent presence in the US and Asia-Pacific (APAC) for the first time, having set out its intention to do this in its 2025–2030 strategy. 

As part of the FCA’s US expansion, Tash Miah, who has worked in the international division of the FCA since 2022, began her role at the British Embassy in Washington, DC in April 2025. She will work alongside the Department for Business and Trade to strengthen UK-US financial services policy and regulatory co-operation and support US firms engaging with UK regulation. Meanwhile, Camille Blackburn, the FCA’s director of wholesale buyside since 2022, will open a regional APAC office in Australia from July 2025. In her new role as Director, Asia-Pacific, she will help firms to understand the regulatory regime thereby preparing them for entering the UK market or raising capital, while also supporting UK firms expand into the APAC region.

Financial Services Regulatory Forum publishes eighth regulatory initiatives grid

On 14 April 2025, the Financial Services Regulatory Initiatives Forum published its eighth regulatory initiatives grid. The members of the Forum are the Bank of England, the PRA, the FCA, the Payment Systems Regulator, the Competition and Markets Authority, The Pensions Regulator, and the FRC. HM Treasury is an observer member.

The grid provides details of regulatory initiatives that are relevant to the financial services sector, which are planned for the next 24 months.
This is the first comprehensive update to the grid since November 2023 and therefore reflects the significant reprioritisation that has taken place since the 2024 general election. 

Oversight of appointed representatives discussed in annual regulatory perimeter meeting

On 11 April 2025, HM Treasury published a policy paper containing a record of the regulatory perimeter meeting that took place on 24 March 2025 between Emma Reynolds, the Economic Secretary to the Treasury (EST), and Nikhil Rathi, the Chief Executive (CEO) of the FCA. 

The purpose of the meeting was to discuss the issues raised in the FCA's December 2024 update to its perimeter report (see our January 2025 update).
The CEO noted that the poor quality of oversight by some principal firms over their appointed representatives (ARs) can contribute to significant consumer harm and said that the FCA would appreciate an update on next steps on whether wider legislative changes are needed following the Treasury’s Call for Evidence in December 2021 (see our January 2022 update).

The EST acknowledged the need to address potential consumer harm, while also striking a balance with making sure burdens on firms are proportionate.  

Chief Executive reappointed for a further term of office

On 10 April 2025, HM Treasury published a press release confirming that Nikhil Rathi has been reappointed as Chief Executive of the FCA for a second five-year term until September 2030. The announcement explains that Mr Rathi's reappointment helps to ensure continuity of leadership and the delivery of key reforms to the regulatory environment to help boost growth and deliver the government's Plan for Change. HM Treasury also published a letter from Rachel Reeves, the Chancellor of the Exchequer, to Mr Rathi confirming his appointment and the government's expectations of the FCA, and Mr Rathi's response. The FCA also published a press release on the reappointment, which reflects on some of the FCA's initiatives, including the introduction of the Consumer Duty and improvements at the regulatory gateway and cutting investigation times.

FCA consults on regulatory fees and levies for 2025/26 

On 8 April 2025, the FCA published a consultation paper (CP25/7) setting out its proposals to increase fees and levies for 2025/26 to fund its operational costs and new regulatory projects. 

Key proposals:

• The FCA proposes an annual funding requirement for 2025/26 of £783.5 million. This is made up of two components: the baseline costs of operating the FCA (base ORA) and costs for exceptional projects, which relate to additional work it undertakes on government initiatives and legislation.

• While the base ORA budget has increased by 2.5% from £729.1 million to £746.4 million, this is a flat increase in real terms. 

• Application, transaction, and notification fees will increase in line with the 2.5% uplift to operating costs.

• The FCA has set out its cost recovery approach for motor finance commission complaints (see our Consumer Credit section below). 

• £9 million will be investing in continuing the Smarter Regulatory Framework, which relates to the repeal of assimilated EU law and its replacement, where appropriate, by FCA rules.

• £7.8 million will be invested in developing and implementing the cryptoassets stablecoins and wider regime.

• Open Banking/Open Finance has been identified as a strategic priority and investment has been increased from £1.2 million to £3.2 million.

• Amendments to the FCA's FEES Manual to allow it to cover costs for skilled person appointments made under the Money Laundering Regulations. The Financial Ombudsman general levy will remain at £70 million, with revised allocations across industry blocks based on forecast case volumes.

Responses to the consultation paper are required by 13 May 2025. The FCA plans to publish a policy statement in early July 2025.

FOS plans and budget for 2025/26

On 3 April 2025, the Financial Ombudsman Service (FOS) published its plans and budget for 2025/26. Key aspects include:

• The FOS expects to resolve 270,000 cases in 2025/26, which is a 20% increase from the previous financial year.

• To ensure fairness and value for money, the case fees for businesses remain frozen at £650 but a new fee charging model for professional representatives has been introduced.

• For complaints referred to the FOS from 1 April 2025, the award limit has increased to £445,000 for complaints about acts or omissions that occurred on or after 1 April 2019.

• The service standard targets to resolve cases received in the reporting period (excluding motor finance commission cases) are 60% of business-as-usual complaints within three months of receipt and 85% within six months.

• Investment will continue in digital transformation initiatives, including the rollout of the Business Connect portal and enhanced data insight sharing, with £9 million earmarked for transformation investment.

• In relation to motor finance commission complaints, see our Consumer Credit section below.

ICO reports on use of children's data by financial services sector

On 1 April 2025, the Information Commissioner’s Office (ICO) published a report following a review of how children’s data is handled by the financial services sector. The review, conducted between March and September 2024, assessed practices among providers of products such as children’s current accounts, savings accounts, trust accounts, ISAs and prepaid cards.

It identified both good practices and areas needing improvement across six key areas: governance, transparency, use of information, consent, data subject rights, age verification, contact (including marketing).

Key findings include:

• Most organisations have children's data policies but there is little monitoring of compliance and little specific training provided in relation to use of children's data.

• Half of the respondents said they had age-appropriate privacy information but the ICO considers the true number to be lower. The ICO is concerned that some organisations have passed transparency responsibilities on to parents, raising the risk of children agreeing to terms and conditions they don't really understand.

• Most organisations regularly review the categories of children's data to ensure it is limited to what is necessary and to prevent purpose creep. However, some ask parents to provide consent on behalf of their child but fail to review the consent, risking it becoming invalid until it is refreshed and obtained directly from the child as it grows older.

• Respondents said that children rarely request exercise of their data protection rights but that parent's views often supersede those of the children due to the difficulty in explaining privacy information and rights to children. In several cases, the decision about whether to accept a request from a child or from parents, was based on a pre-determined age, rather than an assessment of the child's competence.

• Robust age verification processes are in use.

• Almost all respondents have policies in place which prevent marketing to children, however, there is a risk of non-compliance with marketing requirements where a parent's contact information is used for a child's account or service.

UK crypto regulatory framework

On 29 April 2025, HM Treasury published draft legislation establishing the framework for the UK's new cryptoassets regulatory regime. Please see our article for further details.

Speaking at the Innovate Finance Global Summit on the same day, the Chancellor of the Exchequer, Rachel Reeves, expressed her determination for a regulatory framework that supports economic growth and her ambition for the UK to be a global leader in digital assets. To support this objective, Reeves emphasised the importance of international co-operation, noting that the next UK-US Financial Regulatory Working Group meeting in June 2025 will include a discussion relating to the use and responsible growth of digital assets.

On 2 May 2025, the FCA published a discussion paper (DP25/1), to inform its approach to regulating cryptoasset trading platforms, intermediaries, cryptoasset lending and borrowing, staking and decentralised finance, and the use of credit to purchase cryptoassets. Feedback is required by 13 June 2025.

MiCA update

European Commission adopts MiCA delegated regulation regarding market abuse

On 29 April 2025, the European Commission adopted a delegated regulation that supplements the EU Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) (MiCA). This delegated act sets out regulatory technical standards detailing the arrangements, systems, and procedures that must be in place to prevent, detect, and report market abuse. It also establishes standardised templates for reporting suspected market abuse and outlines co-ordination procedures for competent authorities to manage and sanction cross-border cases effectively.

The regulation will enter into force on the 20th day following its publication in the Official Journal of the European Union.

ESMA issues supervisory guidelines to prevent market abuse under MiCA

On 29 April 2025, the European Securities and Markets Authority (ESMA) published guidelines on supervisory practices to prevent and detect market abuse under MiCA.

Drawing from supervisory practices developed under the Market Abuse Regulation, the guidelines promote the integration of existing tools while adapting to the specific characteristics of the crypto environment, such as the greater prominence of social media use, the specific technologies used and the cross-border nature of crypto-trading. ESMA emphasises the need for a data-driven, risk-based approach and encourages national competent authorities (NCAs) to remain vigilant to possible new forms of market abuse behaviours.

The guidelines will be translated into all EU languages. Although they will only start to apply three months after the translations are published on ESMA's website, ESMA recommends that NCAs start implementing the principles in the guidelines now.

PSR annual plan and budget for 2025/26

On 1 May 2025, the Payment Systems Regulator (PSR) published its annual plan and budget for 2025/26.

In March 2025, the government announced that the regulatory responsibilities for payment systems will be mainly transferred to the FCA. The PSR will work with the FCA, the government and the Bank of England to ensure a smooth transition and that payment systems remain competitive, innovative and safe.

Key commitments for its 2025/26 work programme include:

• working with the FCA and Bank of England to deliver the National Payments Vision, revise its Memorandum of Understanding with other regulatory bodies, and develop the Payments Forward Plan

• working with the Bank of England and the Payments Vision Delivery Committee to clarify the short-term upgrades required to Faster Payments

• working with the Bank of England to assess the governance and funding arrangements for the UK's retail payments infrastructure

• working with the FCA and industry to complete phase one of the roll-out of non-sweeping variable recurring payments for lower-risk use cases such as local government, utilities and financial services

• continuing to embed its APP reimbursement requirements

• enhancing its focus on competition and innovation in payment systems.

The PSR's budget for 2025/26 is £28 million, a real terms reduction on its 2024/25 budget. 

Government strengthens protection against debanking 

On 28 April 2025, the government confirmed that it will be introducing new rules to protect customers against debanking. Please see our article for further details. 

EPC launches consultation on SEPA instant credit transfer scheme

On 25 April 2025, the European Payments Council (EPC) announced that it has opened a public consultation to gather input on how it can best support and promote the use of the Single Euro Payments Area (SEPA) instant credit transfer (SCT Inst) scheme at the point of interaction (POI). The consultation invites feedback from stakeholders involved in using, providing, developing, or operating SCT Inst-based payment solutions at the POI. This initiative follows changes to the SEPA Regulation introduced by the Instant Payments Regulation, which will require most payment service providers in the EEA to implement SCT Inst by July 2027. Stakeholders are asked to respond by 30 May 2025, with individual feedback required by October 2025.

PSR thought piece on the payments landscape

On 17 April 2025, the PSR published a thought piece entitled 'What's changed in the payments landscape?' 

Key points include:

• The payments landscape in the UK is evolving rapidly due to technological advancements, shifting consumer behaviour, and increasing market complexity. 

• Digital wallet usage has significantly increased, with over half of UK adults now using them. The proportion of card transactions using a digital wallet increased from 8% in 2019 to 29% in 2023. 

• Cards remain the most used retail payment method. In September 2024, there were 2.2 billion debit and credit card transactions, with contactless accounting for 65% of credit card and 77% of debit card payments.

• Faster Payments volumes rose by 14% to 4.9 billion in the 12 months to September 2024. Over the same period, 6.8 billion Bacs payments were made. 

• Open banking also continues to grow. There are over 11.7 million active users of open-banking enabled products in the UK and more than 22.1 million open banking payments are made each month. 

• Cash usage has declined but remains the second most popular retail payment method after cards, with recent data showing signs of stabilisation. Data from UK Finance indicates a slight increase in cash usage. This may be because some consumers feel it gives them more control over their spending.

• Fraud prevention efforts are improving, with £710 million in unauthorised fraud prevented in the first half of 2024 compared to £650 million in H1 2023. However, over £570 million was still stolen through fraud during that period, as fraudsters take advantage of new technology to develop more sophisticated methods. 

• The PSR’s new APP fraud reimbursement rules have been implemented effectively. It will continue to collaborate with the FCA, which is becoming the lead regulator for fraud. As part of its ongoing work, the PSR supports a 'whole-system' approach, with a particular focus on the role that social media and telecommunications play in removing vulnerabilities that fraudsters take advantage of.

• Merchants have expressed concerns about the cost of accepting card payments, which the PSR is looking into as part of its market review into cards. Nonetheless, card acceptance has increased among smaller merchants and has become standard for microbusinesses.

• Industry developments include new account-to-account payment services, biometric authentication, and the adoption of AI in payments beyond fraud detection. In addition, new digital assets and new payment systems are emerging such as the Regulated Liabilities Network and a potential digital pound.

The PSR notes that a number of workstreams looking at the issues raised in its thought piece (including its work with the FCA on digital wallets and on open banking, its continued focus on APP fraud and its market review on card fees) and the importance horizon-scanning plays in its overall work. It is particularly keen to get stakeholders' views on key changes and developments in the landscape and how they are impacting their businesses.

PSR updates timings for APP scams claims management consultation

On 10 April 2025, the PSR published an update on the timing of its consultation on an authorised push payment (APP) scams reimbursement claims management system (RCMS).

The PSR had planned to consult on regulatory requirements in April 2025. In view of stakeholder feedback on system development and delivery, and the government's National Payments Vision (NPV), which includes a review of Pay.UK, it has decided to delay the consultation. Subject to the NPV, it expects to consult within three to six months.

The PSR intends to adopt Reporting Standard B by December 2026. This requires payment service providers (PSPs) to use systems that can process comprehensive compliance data. Pay.UK's RCMS has been designed to managing APP scams claims and data reporting. While the PSR recognises the value in all PSPs using the same system, it does not consider that it has the power to mandate that PSPs use the RCMS or any other particular system.

In its update, the PSR notes that its consultation will seek stakeholder feedback on:

• a deadline for adopting Regulatory Standard B that is no later than December 2026

• additional regulatory obligations that may be placed on Pay.UK to enable it to meet its compliance monitoring obligations in Specific Direction 19. 

Ahead of the PSR's consultation, Pay.UK will monitor compliance with the Faster Payments Scheme reimbursement rules and the PSR will use Reporting Standard A data to monitor compliance with its legal directions. The PSR is considering how this delay affects the timing and collection of sending and receiving firm data for its APP fraud performance data work beyond 2025 The industry is encouraged to engage with the PSR, which will be running joint engagement sessions with Pay.UK.

Reform of the Consumer Credit Act 1974

The annual perimeter meeting of 27 March 2025 (a record of which was published on 11 April 2025), between the Chief Executive of the FCA, Nikhil Rathi, and the Economic Secretary to the Treasury (EST) (see General section above), touched on the reform of the Consumer Credit Act 1974 (CCA).

Rathi observed that some stakeholders would like amendments to be made to how loans to small businesses are regulated. Currently under the CCA lending under £25,000 to sole traders, partnerships with no more than three partners, and unincorporated associations, is in scope of the perimeter. However, lending to limited companies, LLPs and partnerships of more than three persons is outside of the scope of perimeter, irrespective of the amount borrowed.

The EST noted that the Treasury would be "shortly" consulting on reforms to the CCA.

Motor finance complaints: FCA cost recovery approach and FOS resolution

The FCA's consultation on fees and regulatory levies for 2025/26 (see above) distinguishes between:

• its review of historical motor finance DCAs

• its wider review following the Court of Appeal judgment in Johnson v FirstRand Bank in October 2024 (which includes all future costs relating to this wider review).

The FCA proposes to introduce a new fee-block (CC4) to recover £6.9 million from fee-paying lenders involved in motor finance discretionary commission arrangements between 2007 and 2021.

In relation to its wider review and future costs, it will provide an update in April 2026.

In the 2025/26 plans and budget of Financial Ombudsman Service (FOS) (published on 3 April 2025) (see above), FOS notes that:

• It expects to end 2024/5 with 189,700 cases awaiting a resolution, of which 96,000 relate to motor finance commission (MFC).

• Overall at the end of 2025/6, it anticipates having 128,700 cases awaiting a resolution, of which 101,500 will be MFC cases.

• It does not expect to begin to progress MFC cases until late in 2025/26. This is because of the impact of the FCA's review of the historic use of motor finance discretionary commission arrangements (DCA) and ongoing legal action. It therefore expects to resolve only 5,000 MFC DCA and only 5,000 MFC non-DCA cases. 

Next steps on Buy Now Pay Later regulation

The latest regulatory initiatives grid (published on 14 April 2025) includes information on the next steps for the regulation of interest-free Buy Now Pay Later (BNPL) products.

The government is reviewing stakeholder feedback on its October 2024 consultation on a proposed regulatory regime for BNPL products in preparation for publishing a consultation response in the spring. The government is also planning to lay the necessary secondary legislation in the spring. As BNPL products will come under FCA regulation 12 months after the legislation is made, the new regime is expected to go live around mid-2026.

FCA publishes examples of good and poor practice when communicating the cost of international payments

On 1 May 2025, the FCA published a webpage setting out examples of good and poor practices in relation to how firms communicate the cost of international payments. This follows a review of websites of a sample of firms offering UK customers international money remittance and cross border payments through the lens of the requirements of the Consumer Duty.

Under the Duty a firm must regularly monitor the effectiveness of its communications in ensuring good outcomes for retail consumers.

Key concerns that the FCA identified in its review include:

• transactions fees were not always displayed clearly

• additional fees (such as third party intermediary fees) were often not displayed up front

• consumers were not always given clear information that fees could vary

• that it was not always easy for consumers to find relevant information.

The FCA says that these issues make it challenging for consumers to compare prices and make informed decisions.

The examples of good and poor practice, which cover fixed fees, variable fees and third-party fees, are designed to assist firms in delivering better outcomes for retail customers and will be particularly relevant to firms offering payment services to retail customers where those services involve a currency conversation.

The FCA will use its regular engagement with firms to reinforce its expectations, identify gaps in compliance and make sure appropriate action is taken. It is likely to undertake further work in this area to understand what improvements have been made.

FCA review of banks' bereavement and power of attorney policies

On 12 April 2025, the FCA published its findings of its multi-firm review into the bereavement and power of attorney (PoA) policies of building societies and retail banks. 

The findings are categorised into four areas: policies and procedures, identifying and responding to customer needs, outcomes testing and monitoring, and customer journeys.

Key points include:

• Policies and procedures: there was evidence that staff did not know how to respond to urgent or complex situations, such as sudden changes in customer capacity or when funds are needed quickly. Policies need to be clear that staff should adapt their approach to the customer's needs and escalate when it is appropriate to do so. 

• Identifying and responding to customer needs: firms should actively identify information that may indicate vulnerability and, where applicable, request information from customers that will allow staff to respond to their needs.

• Outcomes testing and monitoring: among most of the firms reviewed, there was scope for improvement in outcomes testing and monitoring. 

Management information (MI) was found not to give a clear picture of customer outcomes. Firms relied on data that was lacking in both breadth and detail, and there were instances of MI reports being insufficiently detailed or unclear.

Customer journeys: when designing their customer journeys, firms should do so with vulnerable customers in mind, particularly in relation to critical services such as bereavement and PoA.

FPC report on financial stability risks of AI 

On 9 April 2025, the Financial Policy Committee (FPC) published a Financial Stability in Focus report on AI in the financial system. The Financial Stability in Focus publications set out the FPC's views on specific topics related to financial stability.

This particular report considers the potential benefits of AI and its growing role in the financial system and what this means from a macroprudential perspective.

The report explains that the FPC is focused on four areas:

• Greater use of AI in banks' and insurers' core financial decision-making. The FPC draws attention to the risks associated with the use of advanced AI models (including agentic AI) that have been deployed without appropriate testing, governance and risk controls.

• Greater use of AI in financial markets. The FPC warns that the increasing use of AI to guide trading and investment decisions could lead to unintended collective behaviour from market participants which reduces financial stability.

• Operational risks in relation to AI service providers. Reliance on a limited number of AI providers for a particular service may lead to systemic risks if the provider experiences a failure or outage, particularly if a rapid migration to alternatives is not possible.

• The changing external cyber threat environment. The FPC also notes that the use of AI by malicious actors could increase their ability to undertake successful cyberattacks against the financial system. Financial institutions' own use of AI could inadvertently create new vulnerabilities that threat actors may exploit, for example through third-party software or hardware vulnerabilities. 

The FPC plans to expand its monitoring approach to enable it to follow the development of AI-related risks relevant to financial stability. With the support of the regulators, the FPC intends to to make use of a range of sources, including the Bank of England and FCA's survey on AI in UK financial services, the AI Consortium and targeted intelligence gathering. The FPC highlights the the role regulators have in ensuring existing guidance and regulation evolves as needed to support the safe adoption of AI across the industry.

FCA summary and insights from AI Sprint

On 23 April 2025, the FCA published a summary of its AI Sprint, which took place in January 2025. This event discussed the opportunities and challenges of AI in financial services, considering the current financial services regulatory regime, and the next five years of AI in financial services.

Four common themes emerged:

• Regulatory clarity. Participants stressed the importance for firms to clearly understand how current regulatory frameworks apply to AI. They suggested areas where the FCA could provide more clarity or build on existing requirements to help firms understand regulatory expectations and to support innovation.

• Trust and risk awareness. Building trust in AI was viewed as essential for successful adoption and for the full benefits of AI in financial services to be realised. 

• Collaboration and co-ordination. There was strong emphasis on the need for collaboration among all stakeholders involved in AI, including domestic and international regulators, government, the industry, academic, model developers and end users.

• Safe AI innovation through sandboxing. Participants supported the use of controlled environments to test AI applications safely such as the FCA’s sandboxes and innovation services, along with access to datasets to develop and improve AI solutions.

On the same day, the FCA also published a blog by Colin Payne, Head of Innovation Services, on what the FCA is doing to enhance trust and clarify its rules. The blog refers to the expansion of the FCA's AI Lab and Supercharged Sandbox, the FCA's work with the synthetic data expert group and its collaboration with the Information Commissioner's Office on AI adoption issues.

FCA seeking views on new live AI testing service

On 29 April 2025, the FCA published a press release announcing plans to launch a live AI testing service.

This testing service is part of the FCA's AI Lab, aimed at supporting the safe and responsible deployment of AI in UK financial markets. Designed to fill a key testing gap that is currently slowing adoption, the service will offer regulatory support to firms ready to deploy AI models that interact with consumers or markets.

The FCA’s regulatory and technical teams will work with firms to provide bespoke support to help them develop, assess and deploy live AI models in UK financial markets.

The live testing initiative will also provide the FCA with valuable insights into AI’s potential impacts and risks, helping it explore effective mitigation strategies. 

Firms in earlier stages of AI exploration can obtain support from the FCA’s Supercharged Sandbox and Digital Sandbox programmes.

An engagement paper outlining the proposed approach has been published, with feedback open until 10 June 2025. The service is expected to launch in summer 2025, with applications opening in early summer and testing to run for approximately 12 months. If successful, the FCA may integrate live AI testing into its established services.

FCA speech on enforcement priorities

On 16 April 2025, the FCA published a speech given by Therese Chambers, FCA Joint Executive Director of Enforcement and Market Oversight, on the FCA's enforcement priorities.

Key points include:

• Fighting financial crime. The FCA is committed to keeping dirty money out of the financial ecosystem, acting promptly when it sees that regulated firms are being used for fraudulent activities, keeping the markets clean, and developing a safe crypto regime that protects consumers. Actions against NatWest, Santander, and Coinbase illustrate the FCA’s readiness to hold firms to account.

• Strong UK-US regulatory partnership. The FCA has a long-standing, productive relationship with US agencies, exemplified in their collaboration on major global scandals like LIBOR and FX manipulation. This co-operation remains critical today, as financial misconduct is often cross-border in nature as highlighted in the 'tuna bonds' scandal.

• Enforcement as a tool for deterrence. Increased pace, focus and transparency are key to the FCA's approach to enforcement. By resolving investigations more quickly (eg five recent investigations achieved an outcome within 16 months or less, compared with a 42-month average previously), the FCA is 'better placed to tell the story of what we are doing than ever before.' 

• Use of Technology. The FCA recognises the potential that technology has to support its detection efforts. It is committed to supporting FinTech solutions through its Innovation Hub and it is following with interest the role that Digital ID may have in improving verification methods.

• Individual accountability and responsibility. Beyond firms, the FCA prioritises and places a premium on the integrity of senior individuals, highlighting its decision to prohibit Jes Staley (while noting that it is awaiting the Tribunal's decision following Staley's challenge of the decision).

FCA updates webpage on cash-based money laundering and announces multi-firm review

On 2 April 2025, the FCA published an updated version of its webpage on cash-based money laundering.

The webpage refers to:

• The work it undertook with the National Economic Crime Command, industry, banks and the Post Office to remedy vulnerability in anti-money controls relating to cash deposits.

• Its new regime to protect access to cash, which was introduced in September 2024.

• The key importance attached to reducing and preventing financial crime within its five-year strategy, launched in March.

• Its expectations of banks in relation to a series of measures it has introduced to reduce the risk of money laundering via the Post Office. These apply to all firms within the Banking Framework Agreement.

The answer to last month's question: Article 11 of the FCA's Strong Customer Authentication Regulatory Technical Standards sets out the current limits on contactless payments.

This month's question: how many members does the Financial Services Regulatory Initiatives Forum have?

• 4

• 8

• 9

• 5.