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

Timings

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.