FCA consults on Financial Crime Guide overhaul: AI, crypto, sanctions and fraud all in scope

Action required for all firms supervised by the FCA for financial crime.

CP26/38, published on 23 October 2026, proposes substantive updates to the FCA's Financial Crime Guide across seven areas: fraud, cryptoassets, financial and trade sanctions, proliferation financing, data security, financial crime systems and controls, and money laundering and terrorist financing. If your firm sits within the FCA's financial crime supervisory perimeter, including under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, this applies to you. Annex 1 financial institutions and cryptoasset businesses are explicitly called out.

The FCA is candid about what has driven the review: since the Guide was last updated, the UK sanctions regime has evolved, cryptoasset regulation has developed, and firms have increasingly adopted AI and third-party tools for financial crime controls. The regulator wants the Guide to keep pace with those shifts rather than lag behind them.

The cryptoasset chapter is timed to align with the UK's incoming regulatory regime for cryptoassets, due to take effect on 25 October 2027. Firms seeking transitional protection under that regime must submit authorisation applications by 28 February 2027, so the updated guidance will matter well before the regime goes live.

The FCA has also signalled a change in how it will deliver financial crime guidance going forward. It is exploring Q&A sessions and the option to publish standalone guidance quickly, without prior consultation, consolidating it into the Guide later. Firms should expect more frequent, lighter-touch updates rather than periodic large rewrites.

Responses must be submitted by 24 December 2026, either via the online form on the FCA's website or by email to cp26-38@fca.org.uk. The FCA will then publish a Policy Statement containing its feedback and the final Guide text.

Sources

• Cp26 38 financial crime guide updatesfca.org.uk
• The uk s FCA has issued a guidance document onnews.futunn.com