Money Laundering Through the Markets - Navigating FCA’s Review and Compliance Standards

Introduction

This session focuses on the FCA’s January 2025 multi-firm review into Money Laundering Through the Markets (MLTM) — a detailed follow-up to the regulator’s 2019 Thematic Review TR19/4. The January 2025 report provides an up-to-date risk assessment of how capital markets are exploited for the purpose of laundering criminal funds and outlines the FCA’s evolving expectations for systems and controls.

Delegates will explore the FCA’s latest insights into money laundering typologies, including circular trading, pre-arranged trading, mirror and wash trades, and third-party payments, supported by real-life case studies.

Drawing from both the review and recent enforcement cases, this virtual classroom session will explain how weaknesses in governance, onboarding, customer risk assessments, and transaction monitoring have led to regulatory failings — and what good looks like in response.

Whether your firm operates a venue, acts as a wholesale intermediary, or facilitates client trading through prime brokerage, this session will help you navigate the complex intersection of market abuse, money laundering, and compliance risk.

What You Will Learn

This live and interactive course will cover the following:

• Understand key findings from the FCA’s January 2025 MLTM review and how these build on TR19/4
• Recognise money laundering vulnerabilities in capital markets, particularly for wholesale brokers and firms offering agency execution services
• Examine recent FCA and international enforcement cases to identify practical lessons
• Evaluate common red flags and ML typologies like circular trading, mirror trades, pre-arranged options, free of payment transfers, and third-party payments
• Identify weaknesses in business-wide and customer risk assessments that may result in poor outcomes
• Assess the effectiveness of transaction monitoring and trade surveillance controls in detecting MLTM
• Use SARs guidance to avoid reporting pitfalls
• Understand FCA expectations on role-specific training, governance, and cross-functional collaboration
• Benchmark your firm’s approach against examples of good and poor practice
• Take practical steps to align systems and controls with current FCA expectations and prepare for regulatory scrutiny

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.