The National Crime Agency (NCA) and the Financial Conduct Authority (FCA) have published a joint list of nine priority areas in the fight against economic crime. These priorities guide the regulated sector to focus on the highest-impact threats, with a ninth area added to the expected eight to reflect the evolving risk landscape.
In this article, we explain the context to these priorities, outline each in turn with practical insights, and set out what firms should do now to respond effectively.
Context to the Priorities
The regulators have made it clear that economic crime is one of the UK’s most serious and costly threats, announcing that £100 billion is laundered through or within the UK each year. The proceeds of financial crime fuel organised crime, erode public trust in the financial system, and cause real harm to individuals, communities, and the economy.
The NCA and FCA’s list is intended to sharpen the sector’s focus, aligning firms’ activities with national law enforcement efforts and other strategic initiatives such as the Economic Crime Plan 2 and the Fraud Strategy.
For regulated firms, these priorities should feed directly into financial crime risk assessments, due diligence approaches, transaction monitoring rules, and staff training. The FCA will expect to see evidence that firms have considered these priorities when designing and maintaining their financial crime controls.
The Nine Priorities
Below, each of the nine priorities is listed. The priorities have no order of ranking.
1. Professional Enablers
Individuals such as lawyers, accountants, and trust or company service providers can be exploited to help move or conceal illicit funds. The NCA and FCA are focused on identifying and disrupting those who knowingly or unwittingly facilitate financial crime.
2. Politically Exposed Persons (PEPs)
PEPs hold prominent public positions and may be more susceptible to corruption. Following recent amendments to the guidance on the treatment of PEPs, this priority reflects the heightened risk associated with these individuals and the need for ongoing scrutiny of their financial activity.
3. Cryptoassets
Digital currencies and blockchain-based assets are increasingly being misused for money laundering, fraud, and sanctions evasion. The agencies are seeking to strengthen the ability of firms to detect and deter illicit use of cryptoassets.
4. High-End Money Laundering
Large-scale laundering schemes often involve complex financial structures and multiple jurisdictions. This priority focuses on dismantling the sophisticated networks and financial channels that enable these high-value crimes.
5. Cash-Based Money Laundering
Despite the growth of digital payments, physical cash remains a favoured tool for criminals, particularly in connection with drug trafficking and organised crime. The emphasis here is on disrupting the collection, movement, and conversion of illicit cash.
6. Money Mules
Criminal groups often use individuals (knowingly or unknowingly) as money mules to transfer criminal proceeds through their accounts. The focus is on identifying mule networks and preventing the recruitment and exploitation of vulnerable individuals.
7. Fraud Linked to Overseas Jurisdictions
Scams and fraud originating abroad can be harder to investigate and disrupt. This priority seeks to address cross-border challenges and the exploitation of weaker anti-fraud controls in other jurisdictions.
8. Sanctions Evasion
The UK’s financial sanctions are undermined when individuals or entities find ways to bypass them. This priority targets attempts to disguise ownership, use intermediaries, or route transactions through unsanctioned jurisdictions to evade restrictions.
9. Terrorist Financing
Funding streams that support terrorism can be complex, small in scale, and hidden within legitimate activity. The focus is on identifying suspicious patterns and disrupting the channels used to finance terrorist operations.
Next Steps for Firms
These priorities are a clear statement of where law enforcement and the regulator believe firms can make the most impact.
Although there is no explicit action required from regulators, firms should be working to align their frameworks with the nine priorities.
If you would like to discuss how to incorporate these priorities into your financial crime framework, contact us using the form below.
