PS 21/4 – Extension of Annual Financial Crime Reporting

The FCA has confirmed in PS21/4 that it is proceeding with its previously stated intention to extend the requirement to submit REP-CRIM, the annual financial crime report.  Firms conducting the following activities, regardless of turnover, will have to submit the report:

  • advising on investments, where the firm holds client money or assets
  • arranging (bringing about) deals in investments, where the firm holds client money or assets
  • dealing in investments as agent or as principal
  • assisting in the administration and performance of a contract of insurance in relation to non-investment insurance contracts
  • managing investments
  • establishing, operating or winding up a collective investment scheme
  • establishing, operating or winding up a personal pension scheme or stakeholder pension scheme
  • managing a UK UCITS, or an AIF
  • safeguarding and administering investments
  • acting as trustee or depositary of a UK UCITS or an AIF
  • operating a multilateral trading facility or an organised trading facility

Firms that conduct the following activities, will also have to submit the report if the firm has revenue of more than £5 million:

  • advising on investments
  • arranging (bringing about) deals in investments
  • advising on pension transfers and pension opt-outs
  • credit related activity

The following firms will not be required to submit the report:

  • firms that conduct home finance activity only
  • firms that only have permission for “making arrangements with a view to transactions in investments”
  • general insurance intermediaries
  • authorised professional firms


The new obligation to report takes effect from 30th March 2022 so firms with a year end of 31 March will be the first in the extended group to submit the report. The report should be submitted via RegData within 60 business days of the firm’s accounting reference date.

The report can be seen here.

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

ATEB Suitability provides report writing software for the financial services market.

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Action Required By You

Firms that will be affected by this extended reporting requirement should incorporate this within their compliance activities calendar.
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