The FCA has just published the outcomes of a survey of corporate finance firms (CFFs). The results send a clear message: many firms remain vulnerable to financial crime risks and regulatory censure because key controls are missing or underdeveloped. The review highlights persistent gaps and common weaknesses, offering valuable insights for firms seeking to strengthen their frameworks.
Key findings from the FCA review:
- Around two-thirds of responding firms may not be compliant with the Money Laundering Regulations in one or more parts of their anti-financial crime frameworks.
- 11% of firms reported they had no documented business-wide risk assessment. (And in our experience as auditors, many firms which do have one are ticking a box, not meeting the required standards.)
- 10% reported they did not retain documented evidence of customer due diligence.
- Among principal firms, 29% reported they do not assess the financial crime risks of their appointed representatives (ARs), and 19% do not assess the effectiveness of oversight over ARs.
On the positive side:
- Nearly all firms (97%) say they report financial crime matters regularly to senior management.
- 72% of firms use a customer risk assessment (CRA) form.
- Some firms have embedded live risk registers and tailored management information to strengthen their controls.
What this means for firms
If you operate in or with a corporate finance firm, the message is clear: having long-standing client relationships or relying on legacy advisers is no substitute for formal controls. Firms must document, assess, monitor, and govern their risks proactively. Many CFFs perceive their financial crime risk as low and may assume the FCA will be lenient if they fall short of the Money Laundering Regulations. This is not the case – this review signals that any gaps will be challenged, and firms will be expected to take remedial action.
How Cosegic can help your firm stay ahead
At Cosegic, we help firms bridge these gaps and embed resilient frameworks that meet regulatory expectations and support sustainable growth.
We provide:
- Business-wide risk assessments: identifying, assessing and documenting financial crime exposure across all business lines and third party relationships.
- Customer risk assessment and due diligence: designing and embedding CRA and CDD/EDD workflows so that client onboarding and monitoring are robust and defensible.
- Oversight of ARs and third parties: strengthening governance, monitoring, and control testing for ARs or outsourced functions.
- Remediation and gap closure programmes: prioritising and addressing weaknesses in line with the FCA’s findings to ensure lasting change.
Taking Control of Financial Crime Risks
The FCA’s review serves as a timely reminder: financial crime controls are not a box-ticking exercise. They’re a critical part of maintaining integrity, protecting clients, and building a sustainable business.
If your firm wants to move from regulatory risk to regulatory-ready, speak to our experts today to assess your current framework and strengthen your financial crime controls.
Get in touch with our team to start the conversation.
