FCA Financial Crime Controls Checklist: Could You Prove Your Framework Works?

Pressure-test your financial crime framework against six areas of FCA scrutiny and identify gaps before the regulator does.

The FCA's latest financial crime review made one thing clear: having a policy isn't the same as having a control. Firms are increasingly being tested not on whether a framework exists, but on whether it's tailored to the actual business, evidenced with real data, and actively overseen by people who understand how it works. That's a higher bar, and it's catching firms out in ways we've explored in Where Your Financial Crime Controls Will Fail Next, and unpacked further in our on-demand financial crime webinar.

This self-assessment checklist walks through the six areas the FCA is scrutinising most closely, from risk assessments and customer due diligence to AI oversight and evidencing effectiveness. Use it to pressure-test your own framework before a regulator does it for you.

Who Is This Financial Crime Controls Checklist For?

This checklist is for compliance, risk, financial crime and governance leaders at banks, insurers, pensions, hedge funds, asset and wealth management firms, e-money and payment firms, and other FCA-regulated businesses who need to know whether their financial crime framework would hold up under real scrutiny, not just on paper.

Six Areas to Assess in Your Financial Crime Framework:

Business-wide risk assessment: whether your risk assessment reflects your actual business model rather than a generic template, and whether the rest of your controls are visibly built around it.

Customer due diligence: whether beneficial ownership, source of wealth and enhanced due diligence are genuinely evidenced, not just documented, and whether higher-risk relationships get real ongoing monitoring.

Governance and accountability: whether senior management and the board are getting meaningful reporting and demonstrating real challenge, not just signing off on paperwork.

Sanctions controls: whether you understand how your screening system actually works, test it regularly, and consider sanctions risk beyond your direct customers.

AI and technology oversight: whether AI used in screening, monitoring or due diligence has documented human oversight and can be explained, not just evidenced, when challenged.

Evidencing effectiveness: whether your management information shows outcomes rather than activity, and whether you could stand behind your framework in an unannounced FCA visit.

Identify the Gaps Before the FCA Does

Download the checklist to assess your controls, strengthen your evidence and prepare your framework for regulatory scrutiny.

Already Know Where Your Financial Crime Gaps Are?

Skip ahead and book a discovery call with our team directly today.

Talk to Ruleguard