Reference Case Number: FOI2025/00326
Freedom of Information: Right to know request:
1. Has the FCA conducted any impact assessments on the effectiveness of The Money Laundering, Terrorist Financing and Transfer of Funds Regulations (MLRs) since 2017?
i. If so, what conclusions have these impact assessments revealed?
2. May you provide a record of the fines imposed by the FCA for breach of The Money Laundering, Terrorist Financing and Transfer of Funds Regulations (MLRs) since 2017, including the quantities fined?
FCA response:
Regarding question 1, we would like to clarify that the Money Laundering, Terrorist Financing and Transfer of Fund Regulations (MLRs) fall under the responsibility of the HM Treasury, who is leading on the review of their effectiveness and their continuous improvement.
The FCA has not conducted any impact assessments on the effectiveness of the MLRs. However, we do deliver a range of work that provides insight into how well firms are applying these regulations. Information on this supervisory activity is reported through our annual reports and, when relevant specific reports are published, for example: Money laundering through the markets | FCA. Furthermore, publications on our enforcement activity can also provide insights into aspects of how well firms are complying with the MLRs: FCA fines Barclays £42 million for poor handling of financial crime risks | FCA
Whilst we do not conduct formal impact assessments on the MLRs, we do engage with HMT on potential amendments to the MLRs and their impact on the effectiveness in stopping money laundering and terrorist financing. We also work with stakeholders to develop the UK response to the Financial Action Task Force mutual evaluation, which considers whether the UK is effective in tackling money laundering, terrorist financing and proliferation financing. The last Mutual Evaluation Report was published in 2018 and can be found here: MUTUAL EVALUATION OF THE UNITED KINGDOM. The UK is currently preparing for the 2027/8 FATF Mutual Evaluation.
We also contribute to the UK’s National Risk Assessment, which partially addresses how well the UK mitigates ML/TF risk. The most recent report of July 2025 can be found here: National risk assessment of money laundering and terrorist financing 2025 - GOV.UK
More broadly, we work with stakeholders, for example, through Economic Crime Plan 2, to continue to improve the effectiveness of the UK’s response to financial crime. More information on the Economic Crime Plan can be found here: Economic Crime Plan 2 2023-26.
Regarding question 2, we can confirm that we hold the requested information, which can be found in Annex A below. Please note that in the case of Stephen Sahota, a fine was not imposed in lieu of a payment made to the Financial Services Compensation Scheme. More information can be found in the linked press release within the Annex.
Further to the cases cited in the below annex, we have also issued a fine to Starling Bank Ltd for failings related to financial sanctions screening. Further information can be found here: FCA fines Starling Bank £29m for failings in their financial crime systems and controls | FCA