The Financial Conduct Authority (FCA) and National Crime Agency (NCA) have jointly published a set of “System Priorities” for the UK’s response to economic crime in 2025. 

The System Priorities, created in partnership with the Home Office, Treasury, and UK Finance, set out a comprehensive approach to address the most pressing threats facing the UK’s financial system.

The System Priorities are aligned with both: 

• the National Risk Assessment of Money Laundering and Terrorist Financing 2025, which sets out what HM Treasury and the Home Office consider to be the key money laundering and terrorist financing risks facing the UK; and
• the NCA’s National Strategic Assessment of Serious and Organised Crime which they published in 2025. 

The governance of the priorities will be overseen by a newly established public-private System Prioritisation Governance Group. The publication makes clear the need for strong collaboration between the public and private sectors to prevent, identify, and disrupt the financing of organised crime.

The nine System Priorities are listed below.

1. Economic Crime and Sanctions Evasion facilitated by UK-based or UK-registered Professional Enablers, especially in relation to the Russian invasion of Ukraine.
2. Transaction flows and corporate structures associated with the abuse of power by overseas Politically Exposed Persons.
3. Protecting the public by creating a cryptoasset ecosystem that is increasingly resilient to criminal abuse.
4. Addressing criminal cash consolidation, cross-border movement, and deposits into the UK banking system (including via the Post Office). 
5. Money laundering through UK corporate structures on behalf of organised criminal groups, particularly those with links to priority Jurisdictions such as Albania, China, Russia, and the UAE.
6. Fraud perpetrated by international offenders against victims in the UK, including organised criminal groups with links to criminality in priority Jurisdictions such as Ghana, Nigeria, India, and Southeast Asia (with a focus on Cambodia, Laos and Myanmar). 
7. Exploitation of money mules by criminal networks to obscure the origins and movement of illicit funds.
8. Tackling the significant percentage of the value of frauds in the UK originating from a telecommunications service or online platforms.
9. The financing of terrorist attacks or plots in the UK, or individuals or groups engaged in attack planning or propagating terrorist ideology.

The priorities are all equally weighted, but in their announcement the NCA has highlighted the examples of combating cash-based money laundering, the use of money mules, and fraud associated with overseas jurisdictions. This follows the FCA’s findings earlier in the year that firms are underestimating the threat of money laundering and are routinely failing to report money mules to the National Fraud Database. We have written about this in further detail in an earlier article. 

The FCA and NCA have emphasised that tackling economic crime requires a co-ordinated effort, with public-private partnerships playing a central role. The new priorities are designed to help regulated firms allocate resources more effectively on a cost-neutral basis, focusing on areas where they can have the greatest impact while maintaining their regulatory responsibilities. This emphasis on efficient and cost-neutral allocation of resources is in line with the Government’s recent increased emphasis on reducing the regulatory burden on firms. The NCA has stressed in its announcement that there are areas where firms will be able to “dial-down” regulatory activity to reallocate resources for maximum impact, citing examples of the increase to the threshold for reporting Defence Against Money Laundering reports (due to take place on 31 July 2025) and proposed changes to increase the effectiveness of the money laundering regulations.

Further guidance will be published in due course to help firms interpret and navigate the priorities. For now, the NCA has provided examples of actions it expects the public private partnerships to take, some of which include: 

• enhanced information sharing and intelligence flows, both within the private sector and with UK law enforcement;
• proactively reporting suspicious activity to relevant authorities and databases; and
• developing frameworks and agreed industry methodology to identify trends and key risk areas.