• FCA round up: The FCA has published a summary of its activity during July 2025, and notes in its opening paragraph that it has been accelerating its work on supporting growth and competitiveness over the past year. The FCA also reminds firms to check their information on FCA Connect and the Register, and flags its new website for the Office for Investment, an initiative to attract international firms to the UK.

Regulation round-up - July 2025

• POCA exemptions: On 31 July 2025, the Home Office published guidance on the exemptions from money laundering and money laundering reporting obligations as set out in the Proceeds of Crime Act 2002 (POCA). The Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025 raised the threshold amount for two of these exemptions from £1,000 to £3,000. The threshold amount is the value of criminal property below which a regulated business can carry out a transaction without submitting an authorised disclosure to the National Crime Agency. On 31 July 2025, the threshold amount specified in section 339A of POCA increased from £1,000 to £3,000 for acts by banks and payment institutions in operation of an account. The threshold amount also increased from £1,000 to £3,000 for acts carried out by all regulated businesses when they end a relationship with a customer and pay away property for this purpose below the threshold.

Guidance on the exemptions from the money laundering obligations and money laundering reporting obligations in the Proceeds of Crime Act 2002 - GOV.UK

• Digital design in customer journeys: On 31 July 2025, the FCA published a good and poor practice guide in relation to customers’ online journeys so they are in line with Consumer Duty expectations. This guide is for consumer credit providers only but may be relevant to any firm with digital presence.

Digital design in customers' online journeys: good practice and areas for improvement | FCA

• FCA fines SIgma Broking Limited: On 29 July 2025, the FCA fined Sigma Broking Limited £1,087,300 for failing to submit complete and accurate transaction reports for five years – approximately 984,000 incorrect reports had been submitted. In February 2025, Sigma confirmed that it submitted 924,584 incorrect reports, making up nearly 100% of transactions handled by the firm between 1 December 2018 and 1 December 2023. This is the second enforcement action the FCA has taken against Sigma for inadequate transaction reports.

FCA fines Sigma Broking Limited for transaction reporting failures | FCA

Final Notice 2025: Sigma Broking Limited

• Market watch: On 23 July 2025, the FCA published its newsletter on market conduct and transaction reporting issues. The FCA notes its observations from supervising the UK MiFID transaction reporting regime, covering remedial timelines, back reporting, transaction reporting errors and omissions notifications. The FCA recommends that firms integrate these measures into their processes for efficient reporting. The FCA does not expect this to create any additional burden.

Market Watch 82 | FCA

• Swiss UK BFSA: On 23 July 2025, the FCA invited UK and Swiss firms to submit their interest in providing cross-border services as part of the Berne Financial Services Agreement (BFSA). The aim of the BFSA is to reduce regulatory barriers and boost the UK’s financial international competitiveness by allowing UK firms to provide wholesale financial services into the Swiss domestic market and vice versa. Please see our article for more detail.

FCA helps unlock market access for UK and Swiss firms | FCA

The Berne Financial Services Agreement - GOV.UK

• FCA fines and bans former deputy CEO of H20 AM LLP: On 22 July 2025, the FCA fined Jean-Noel Yves Alba, the former deputy CEO of H20 £1,049,500 and banned him from working in the financial services industry. Mr Alba was the principal point of contact with the FCA during its investigation of H20. Mr Alba provided false records, minutes, and due diligence materials to the FCA who consider that Mr Alba acted either intentionally to mislead it, or recklessly.

Final Notice 2025: Jean-Noël Yves Alba

• MLR reform: On 17 July 2025, HM Treasury published its response to the consultation on improving the effectiveness of the Money Laundering Regulations. Changes to be made include:
  • enhanced due diligence on complex transactions and high-risk third countries;
  • due diligence on pooled client accounts and for certain non-financial firms;
  • information sharing with public bodies;
  • currency thresholds in euros;
  • regulation of ‘off-the-shelf’ companies;
  • registration and change in control requirements for cryptoasset service providers; and
  • registration requirements for the Trust Registration Service.

HM Treasury have concluded that some issues discussed in its initial consultation will be managed through non-legislative means such as through improved guidance. A draft statutory instrument is intended to be published in the coming months.

Improving the effectiveness of the Money Laundering Regulations - HM Treasury

• Financial Ombudsman Service: On 15 July 2025, the FCA announced that they are seeking to reform the Financial Ombudsman Service. HM Treasury have also issued a consultation on this. Changes proposed include:
  • adapting the ‘fair and reasonable test’;
  • giving the FCA more flexibility to manage mass redress events, including pausing complaints;
  • introducing a formal mechanism to refer issues to the FCA where there is ambiguity in how FCA rules apply;
  • allowing firms and complainants to refer issues to the FCA for clarity on rules before the FOS’ final decision; and 
  • introducing an absolute time limit of 10 years for bringing a complaint.

Redress system reforms to prevent compensation delays and provide predictability needed for innovation | FCA

FS Sector Strategy: Review of the Financial Ombudsman Service - GOV.UK

• SMCR reform: On 15 July 2025, the FCA, PRA, and HM Treasury each issued consultations on the potential reform of the Senior Managers and Certification Regime. The Treasury consultation proposes to:
  • replace the certification regime with a rule based, proportionate regime;
  • reduce the number of senior manager roles;
  • remove the requirement for pre-approval by the FCA/PRA for some Senior Manager Functions (SMF) roles; and
  • provide more flexibility for firms when notifying the FCA of updates to Statements of Responsibilities for Senior Managers.

The FCA consultation proposes implementing the reform in two phases. Key proposals for Phase 1 include:

• amending the 12-week rule such that for temporary Senior Manager cover, firms have 12 weeks to submit an SMF approval application rather than 12 weeks to obtain a decision on such application;
• simplifying the SMF approval process, including reducing the information required;
• extending the validity of criminal record checks for SMF applications from three to six months;
• removing overlapping certification requirements, especially where individuals hold multiple roles; and 
• firms having up to 20 business days to update most information on the FCA Directory, apart from staff departures.

Key proposals for the FCA's Phase 2 include:

• simplifying the certification process to reduce complexity and administrative burden;
• reducing the number of SME roles requiring pre-approval; and
• increasing firm flexibility in appointing interim Senior Managers by expanding the use of the 12-week rule.

Please see our article for more detail.

Reforming the Senior Managers & Certification Regime - HM Treasury

CP25/21: Senior Managers & Certification Regime review

CP18/25 – Review of the Senior Managers and Certification Regime (SM&CR) | Bank of England

• FCA statement on market reforms: On 15 July 2025, the FCA published a statement on upcoming reforms to UK capital markets where it emphasised its focus on seeking to ensure a balance between consumer protection and unlocking growth and opportunities. The FCA will provide an update on next steps in Q4 2025. 

FCA statement on market reforms and what's to come | FCA

• No UK Green Taxonomy: On 15 July 2025, HM Treasury announced, in response to a consultation which ran from November 2024 to February 2025, that the UK Government will not proceed with the development of a UK Green Taxonomy because it found no compelling evidence that a UK Green Taxonomy would proportionately or effectively deliver its intended objectives. Instead, the Government intends to “work with regulators through the Transition Finance Council to capitalise on the £200 billion opportunity of the global transition to net zero”.

Please see our article for more detail.

Rachel Reeves Mansion House 2025 speech - GOV.UK 

UK Green Taxonomy Consultation Response - HM Treasury

• Leeds Reforms: On 15 July 2025, the Chancellor, Rachel Reeves, announced the “Leeds Reforms” and delivered her Mansion House speech. These set out the Government’s new Financial Services Growth and Competitiveness Strategy. The Chancellor outlined the Government’s aim for the UK to be the global location of choice for financial services investment and innovation by 2035. Key initiatives include, amongst others:
  • addressing risk aversion to retail investment by rolling out targeted support;
  • addressing concerns about the application of Consumer Duty for firms engaged in wholesale activity; 
  • reform of the Financial Ombudsman Service (see item below);
  • shortened deadlines for regulatory applications, for example, Senior Manager applications to be completed within two months;
  • streamlining the Senior Managers and Certification Regime, including the removal of the Certification Regime (see item below);
  • plans to review the appropriateness of remuneration rules for asset managers and investment firms;
  • committing to publish an engagement paper on potential reforms to the market risk framework for the Investment Firms’ Prudential Regime by the end of the year and to launch a consultation in 2026; and
  • reforming the bank capital framework.

Please listen to our podcast that discusses these reforms.

Financial Services - Growth and Competitiveness Strategy - GOV.UK

Rachel Reeves Mansion House 2025 speech - GOV.UK

• Updated PEP guidance: On 15 July 2025, the FCA published its finalised guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes. Key changes include:
  • clarifying that non-executive directors should not be treated as PEPs;
  • providing firms with more flexibility on implementing senior manager sign-off for PEP relationships; and
  • clarifying how money laundering reporting officers are expected to oversee how PEP controls are operated.

FG25/3: The treatment of politically exposed persons for anti-money laundering purposes

• FCA annual report: On 10 July 2025, the FCA published its annual report and accounts which covers its 3-year strategy and progress so far on strategic commitments.

Our Annual Report and Accounts 2024/25 | FCA

• FCA enforcement data: On 10 July 2025, the FCA published its enforcement data for 2024/2025. One key statistic to take away is that the number of voluntary outcomes supported by enforcement increased by 18% compared with the previous year. Please see our article for more detail.

FCA Enforcement data 2024/25 | FCA

• FCA response to Government remit letter: On 10 July 2025, the FCA responded to the Government’s remit later dated 14 November 2024, setting out how it is supporting the Government’s growth mission and economic policy. The letter summarises the FCA’s progress in respect of the following six aspects of economic policy: 
  • Supporting the growth mission and embedding the secondary objective. The FCA has reviewed its existing rules in light of the secondary objective and the effect of Consumer Duty.
  • Enabling informed and responsible risk-taking (such as the proposal for targeted support to bridge the advice gap). This includes introducing ‘targeted support’ to bridge the advice gap (see item above) and prompting public discussion on the future of the mortgage market.
  • Supporting the real economy through sustainable lending, including through the CCI regime and exploring changes to the pensions regulatory framework.
  • Supporting innovation and competition, including through the AI lab and review of AIFMD regime.
  • Competitive capital markets that support UK growth. The FCA’s work here includes the new PISCES and prospectus regimes.
  • Reinforcing financial inclusion and supporting home ownership through the FCA’s Mortgage Rule Review.

FCA’s response to Treasury remit letter 2025

• SICGO report: On 10 July 2025, the FCA published its second progress report on its secondary objective of international competitiveness and growth. The report details the FCA’s key initiatives since July 2024 to support growth. The report reiterates the FCA’s calls for an open debate with Government about rebalancing risk in order to allow for more growth in the UK’s financial industry. The FCA’s initiatives are split into four themes: authorisations and operational efficiency; policy and regulatory impact; data collection; and digital and innovation. Annex 1 of the report sets out timings of progress and next steps on various FCA initiatives since the FCA’s response to the Prime Minister’s letter dated 24 December 2024. Annex 2 sets out how FCA rules and guidance have advanced the secondary objective.

Secondary International Competitiveness and Growth Objective report 2024/25

Secondary International Competitiveness and Growth Objective report 2024/25: Annex 1

• Professional opt-up changes: On 10 July 2025, the FCA announced that it is reviewing its client categorisation rules in order to support capital markets and unlock opportunities for wealthy investors. This announcement was made at the same time as the FCA published its Secondary International Competitiveness and Growth Objective (‘SICGO’) report setting out its progress on supporting growth (discussed below). 

The FCA’s statement also listed some of the FCA’s completed growth initiatives as well as the work it is doing to deliver other initiatives including, for example, the new private stock market PISCES, the new Digital Securities Sandbox to allow for the exploration of new technology, and the FCA’s pre-application support service to assist firms in seeking authorisation.

FCA to modernise rules to unlock investment | FCA

• Deputy chief executive's speech at the IA: On 2 July 2025, Sarah Pritchard, deputy chief executive of the FCA, gave a speech at the Investment Association’s Private Market Summit. Ms Pritchard noted that the FCA is seeing increasing numbers of asset managers investing in private markets to meet demand in raising capital. She emphasised that the FCA has been providing greater transparency in private markets by “bringing the risks out from the shadows”. In particular she noted the FCA’s review of valuation practices across firms, the Call for Input on AIFMD, and the FCA’s focus on data. 

A key focus of the speech was investment risk and retail access to private markets. She commented that “Now is the time to have this debate – particularly as we consider how retail investors might access private markets… We are confident that more people could benefit from access to private markets, in time. And we’re open-minded about how retail access could be expanded.”

Shining a light on private markets | FCA

• FCA proposals for ‘targeted support’: On 30 June 2025, the FCA published its long-awaited proposals to help bridge the “advice gap”. The FCA proposes a new form of support: ‘targeted support’. Targeted support is a new advice service, which would allow firms to provide suggestions tailored to support groups of consumers sharing common characteristics. The FCA also confirmed that it will update its guidance on the advice boundary and plans to launch a separate consultation in early 2026. Please see our article for more detail.

CP25/17: Supporting consumers' pensions and investment decisions: proposals for targeted support

Once-in-a-generation advice changes to help millions navigate their financial lives | FCA