Daily Compliance Brief — FCA Restricts Six Lenders Over Anti-Money Laundering Control Concerns

October 23, 2026

Signal

On October 23, 2026, the UK Financial Conduct Authority (FCA) announced restrictions on six unregulated lenders, known as Annex 1 firms, after raising concerns about their anti-money laundering policies, controls and procedures during application assessments. According to the FCA's press release, the restrictions were imposed at the firms' own request and limit their ability to take on new customers or conduct new business with existing customers, including extending credit.

The affected firms fall within the FCA's AML supervisory remit under the UK Money Laundering Regulations, despite not being authorised or subject to the FCA's wider regulatory framework. The action demonstrates that registration-based AML supervision can have direct operational consequences when firms cannot adequately demonstrate the effectiveness of their controls.

The FCA linked the restrictions to its enhanced oversight of Annex 1 firms, which operate in sectors that may present heightened money laundering and financial crime risks.

Why it matters

Lenders subject to AML registration requirements should verify that their risk assessments, customer due diligence, transaction monitoring and escalation procedures are proportionate to their business models and customer profiles. Control documentation should demonstrate not only that policies exist, but that they are implemented and operating effectively.

Senior management and compliance owners should also ensure that weaknesses identified during regulatory assessments trigger documented remediation, clear accountability and appropriate restrictions on higher-risk activity where necessary. Firms outside the FCA's broader authorisation regime should not interpret that status as reducing their obligations under the Money Laundering Regulations.