FCA applying increased scrutiny to Annex 1 firms

We are 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 us for anti-money laundering purposes.If you’re carrying out these activities without being registered, you should submit an application for registration.We are concerned about a number of risks we’ve identified among Annex 1 firms, in particular the potential for them to facilitate financial crime.We have seen firms rely too heavily on the financial crime controls of their parent company. Each individual firm within a group must assess whether these controls are appropriate for their financial crime risks, governance and operations. They also can’t rely on off-the-shelf procedures designed for a different company. Each must have controls tailored to the way they operate and the risks they need to manage.We are also concerned about the risks to consumers and markets from unregulated lending often conducted through complex structures, including special purpose vehicles. We recently highlighted the