
MLRO Resourcing: Balancing In-house Expertise with External Support
A decision guide to employed, external-support and co-sourced MLRO models, focused on SMF17 capacity, authority and retained senior-management accountability.
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A decision guide to employed, external-support and co-sourced MLRO models, focused on SMF17 capacity, authority and retained senior-management accountability.

The Mills Review is not a new AI rulebook. It gives retail-finance boards a practical prompt to define delegated authority, human intervention and outcome testing.

A practical guide to FCA Section 166 skilled-person reviews, covering appointment routes, scope control, evidence quality and remediation governance.

Principal firms must maintain documented oversight of inactive appointed representatives, with clear REP025 explanations and timely relationship decisions.

CP26/19 proposes targeted changes to FCA penalty and decision-making policy. We separate the live DEPP position from the thresholds and processes under consultation.

CP26/20 proposes explicit SIPP due-diligence rules and a Pension Scheme Money and Assets regime. We examine the evidence and operating-model decisions.

How boards can transform Consumer Duty monitoring data into clear evidence of customer outcomes, meaningful challenge and accountable actions.

Practical guidance for authorised firms on substantiating claims, audience controls, and maintaining defensible approval records for financial promotions.

CP26/28 proposes three AIFM size tiers, a new ALTS sourcebook and revised transition rules. Classification decisions will depend on reliable operating-model evidence.

CP26/26 proposes consolidated fund returns, essential and enhanced reporting tiers, and different reporting lags. This analysis maps the proposal to fund-level data controls.

The FCA has issued a decision notice proposing a £99,600 penalty on Carlos Fuenmayor over alleged disclosure failures. The decision notice is before the Upper Tribunal, so the findings are not final.

The FCA has fined Dinosaur Merchant Bank Limited £338,000 for failing to implement effective systems to detect and report suspicious trading in its CFD business, highlighting critical gaps in market abuse surveillance.

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