FCA review of firms AML risk assessments: On 11 November 2025, the FCA published its findings following a review of both business-wide risk assessments (BWRA) and customer risk assessments for a range of firms, including wealth management firms, platforms and custody and fund service providers. The poor practices identified included failing to tailor the BWRA to the specific business and inadequate evidence for concluding their business was low risk. The FCA was concerned that some firms could not explain sufficiently how they are managing and mitigating identified risks. Firms are encouraged to consider the FCA’s findings and suggestions within the context of their firm and continue to review their risk-based approach to systems and controls.

Risk assessment processes and controls in firms: our findings | FCA

FCA review of contracts for difference (CFD) providers Consumer Duty compliance: On 13 November 2025, the FCA published its findings on how CFD providers deliver fair value and use their Consumer Duty fair value assessments to deliver the price and value outcome. Good practices identified included simplifying fee structures and preventing investors who may be unable to bear potential losses from buying CFDs. Identified areas for improvement included where firms were:

a) not adequately considering consumer complaints or customer satisfaction as part of their fair value assessments;

b) making little or no changes to their products or services in response to the Consumer Duty; and

c) applying varying levels of overnight funding charges without providing clear justification.

Multi-firm review of contracts for difference providers’ provision of price and value | FCA

Transaction reporting: On 21 November 2025, the FCA issued its consultation paper on streamlining the UK transaction reporting regime following its discussion paper (DP24/2**) issued last November. The Treasury will repeal the MiFIR firm facing transaction reporting requirements and these will be replaced with new FCA rules in the MAR sourcebook of the FCA Handbook. The FCA streamlining proposals include: 

• removing foreign exchange derivatives from reporting requirements;

• removing reporting requirements for 6 million financial instruments including equities, bonds and certain derivatives that are only traded on EU trading venues; and 

• reducing the period for correcting historic reporting errors from 5 to 3 years.

The consultation also confirms the FCA’s intention for CPMI firms to remain out of scope of the regime. The FCA intends to publish a policy statement with final rules in the second half of 2026 with an implementation period of 18 months after publication. 

FCA transaction reporting proposals to save firms £100m a year | FCA 

SAR guidance: On 24 November 2025, the National Crime Agency published updated best practice guidance for submitting Suspicious Activity Reports (SARs). The guidance covers: 

• using the SAR Portal;

• submitting a Good Quality SAR; and 

• understanding Defence Against Money Laundering and Defence against Terrorist Financing.

Suspicious Activity Reports - National Crime Agency

FSCS deposit protection increase: On 18 November 2025, the PRA issued policy statement 24/25 which will increase the deposit protection limit from £85,000 to £120,000 (rather than the £110,000 consulted on) with effect from 1 December 2025. The deposit protection limit represents the maximum amount of money the FSCS typically protects should a depositor’s bank, building society or credit union become insolvent.

PS24/25 – Depositor protection | Bank of England

FCA review of prudential reporting: On 26 November 2025, the FCA published its findings following a data quality review of prudential reporting by MIFIDPRU investment firms. The review assessed how firms compile, validate and submit MIFIDPRU regulatory returns. Good practices included consistent reporting across time periods and cross-validation cross returns. Areas for improvement included inconsistent reporting across multiple data sources, inaccurate implementation of guidance and incorrect reporting of K-factors.

Prudential regulatory reporting by MIFIDPRU investment firms – data quality review | FCA

UK EMIR Intragroup Regime: On 5 November 2025, the FCA published a consultation paper on simplifying the UK EMIR Intragroup Regime for counterparties seeking intragroup exemptions from clearing and margin requirements. The consultation closes on 16 January 2026. 

CP25/30: Streamlining the UK EMIR Intragroup Regime

Rebalancing risk: On 25 November 2025, Ashley Alder, FCA Chair, gave a speech at the Investment Association Annual Conference 2025. The speech highlighted that ‘rebalancing risk’ is a key part of the FCA’s strategy and is essential to encouraging investment and increasing participation in private markets.

Chair reflections: rebalancing risk | FCA

The role of the Chief Risk Officer (CRO): On 4 November 2025, Sarah Pritchard, FCA deputy chief executive, gave a speech at the launch of the Chief Risk Officer Network. The speech discussed the FCA’s approach to rebalancing risk and called on CROs to communicate where they believe there are unnecessary regulatory barriers. 

Rebalancing risk for growth, the role of the Chief Risk Officer | FCA

UCITS and AIFMD liquidity management tools (LMTs): On 17 November 2025, the European Commission adopted two Regulatory Technical Standards (RTS) supplementing the AFIMD and UCITS Directive specifying the characteristics of LMTs. UCITS managers and AIFMs of open-ended funds are required to select at least two appropriate LMTs from a list of nine annexed to each of AIFMD and UCITS directive. The RTS are due to apply from 16 April 2026.

AIFMD Delegated Regulation

UCITSD Delegated Regulation

SFDR 2.0: On 20 November 2025, the European Commission published a legislative proposal to update the EU Sustainable Finance Disclosure Regulation (SFDR), dubbed “SFDR 2.0”. The most notable changes proposed by the official draft are the introduction of a product categorisation regime and the following new product categories: 

i. Transition - Article 7;

ii. ESG basics - Article 8; and

iii. Sustainable - Article 9.

The official draft does not contain an expected carve-out for AIFs marketed to professional investors. Please read our article for further information. 

Commission simplifies transparency rules for sustainable financial products - Finance

SFDR 2.0 - Text Proposal