Partner Chris Roberts has provided comment in Law360 on the examination of financial crime systems and controls across a range of retail, wholesale and life insurers.

Commenting on the FCA’s findings, Chris said: “The good news is that the FCA found most firms’ controls to be mostly effective. The review and the lessons identified by the FCA give firms a clear opportunity to learn from best practice and strengthen their financial crime systems, controls and resources.”

Highlighting the implications of insufficient guidance for specific business areas, he commented: “One of the FCA’s findings was that, while firms generally had comprehensive policies and procedures in place, these were not always supported by sufficiently detailed guidance for specific business areas. In practice, that can create gaps where a broad, firm-wide framework does not adequately reflect the particular risks and operational realities of different parts of the business.”

Chris added: “So overall, a positive bill of health from the FCA with areas of improvement highlighted. Fighting financial crime is an ongoing battle, and there will always be areas of improvement.”

Chris’ comments were published in Law360, 24 June 2026.