CDD under the microscope: Unpacking the FCA's latest multi-firm review

The situation

In April 2026, the FCA published its multi-firm review of Customer Due Diligence, Enhanced Due Diligence, and ongoing monitoring controls. Whilst the review covered Asset Management, Crowdfunding, Wholesale Banking, Contracts for Difference, and Non-bank Lenders, its findings apply to every firm undertaking CDD.

Whilst quite high-level, the picture it paints is clear: too many firms have policies that don't translate into practice, EDD processes that go undocumented, and compliance monitoring arrangements that lack genuine independence. The FCA has been explicit that it will continue to monitor firms on these points.

The discussion

Join James Nurse, UK AML/FinCrime thought leader and Strategic Advisor to Alloy, and Rebecca Marriott, Chief Risk Officer at Tide, as they break down what the FCA found, what it means for your firm, and the concrete steps you should be taking right now.

In this 45-minute session, you'll learn:

• What the FCA's review methodology looked like and the standards firms were measured against
• The most common CDD and EDD failures, from undefined review cycles to missing senior management sign-off
• What genuine good practice looks like across policies, processes, and compliance monitoring
• Immediate and medium-term actions to benchmark and strengthen your own programme

The session will close with a live Q&A, giving you the opportunity to put your questions directly to James and Rebecca.

This session is designed for compliance officers, MLROs, senior managers, and financial crime practitioners at UK financial institutions and fintechs who want a clear, practical read on where the regulatory bar now sits.
 

Additional resources