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Registered, but not authorized: Why the FCA is focusing on on Annex 1 firms

A general view of 240 Blackfriars and 255 Blackfriars Arbor office buildings, Opus 50-story in the Bankside Yards, One Blackfriars, Southbank Tower, Thirty Casson Square at Southbank Place residential apartment skyscraper buildings, Sea Containers London, London Eye, Blackfriars Bridge across the River Thames and Unilever House (Unilever Global Headquarters) on June 29, 2026 in London, England.
Photo: John Keeble/Getty Images

Gary Watson, Clarionet Consulting

4 min read

The message is clear: an Annex 1 FCA registration is not a substitute for due diligence. Authorized firms still need to exercise robust AML controls.

In August 2026, the FCA sent an anti-money laundering (AML) questionnaire to approximately 900 Annex 1 firms. It marks a shift in how the regulator supervises this part of the market. Understanding the background is important for any Annex 1 firm trying to work out what comes next, but there are also

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