Financial Crime Guide updates: FCA consults in CP26/38
The FCA proposes changes to its Financial Crime Guide on fraud, cryptoassets, sanctions, data security and AML controls. Comments close on 24 December 2026.
What changed
On 23 October 2026 the FCA published CP26/38, a consultation on changes to its Financial Crime Guide to help firms strengthen their systems and controls. The FCA says it wants the Guide to keep pace with emerging risks, such as those linked to AI, cryptoassets and evolving sanctions regimes.
The proposed changes cover fraud; cryptoassets, to reflect the new regime from October 2027; financial and trade sanctions; proliferation financing; data security; financial crime systems and controls; and money laundering and terrorist financing. The consultation is relevant to all firms the FCA supervises for financial crime, including under the Money Laundering Regulations 2017, such as Annex 1 financial institutions and cryptoasset businesses. The FCA notes that since the Guide was last updated, firms have increasingly adopted AI and third-party tools for financial crime controls. Responses are due by 24 December 2026, and the FCA will publish feedback and the final Guide text in a policy statement. It is also exploring publishing timely standalone guidance without prior consultation where consultation is not required, to be consolidated into the Guide later.
The rules it touches: FCG 1, SYSC 6.1.1R, SYSC 6.3.1R.
What to do
- Read CP26/38 and map each proposed change against your financial crime policies, procedures and risk assessment.
- If you use AI or third-party tools in financial crime controls, check how you oversee and test them against the updated guidance.
- Cryptoasset firms preparing for the regime from October 2027 should read the cryptoasset chapter changes alongside their authorisation plans.
- Send any comments through the FCA's online form by 24 December 2026.
Our view
In our view the useful part of this consultation is its attention to AI and third-party tools in financial crime controls. Many firms now rely on a supplier's screening or monitoring model, and the Guide is where the FCA sets out what it expects firms to be able to show about those controls. We think firms that already test and evidence their tools will find the updated Guide confirms practice rather than changes it.
How this was produced: drafted automatically from the source and our FCA Handbook mirror; every Handbook reference was checked against the provision text before publication.