The Wealth Management Financial Crime Compliance Learning Programme – Meeting FCA Expectations in 2025 and Beyond

The new “failure to prevent fraud” offence represents a step-change in corporate liability, with personal accountability likely to follow. This session equips your firm with the foundational knowledge and practical steps you need to protect your business and meet evolving legal expectations. 

By the end of this session you’ll: 

• Understand the scope and implications of the new corporate offence of “failure to prevent fraud” under the Economic Crime and Corporate Transparency Act. 
• Identify the types of fraud offences covered and when your firm could be held liable. 
•  Assess what constitutes “reasonable procedures” as a legal defence. 
•  Begin designing or enhancing internal systems to ensure compliance and mitigate legal and reputational risk. 

An FCA visit to scrutinise your approach to financial crime can happen with little notice – but how your firm prepares and responds can have long-lasting impacts. This session ensures you’re not only ready, but confident in your ability to demonstrate a strong culture of compliance and control. 

 By the end of this session, you’ll: 

• Understand the types, triggers, and structure of FCA financial crime regulatory visits and reviews. 
• Be able to prepare proactively for financial crime supervisory engagement, including document readiness and interview preparation.
•  Understand the difference between the different types of FCA interaction – walkthroughs, interviews and what is needed from file reviews. 
• Learn how to manage on-the-day dynamics and respond confidently to FCA questioning. Understand how to follow up effectively and mitigate regulatory risk post-visit. 

Your financial crime risk assessment is the cornerstone of your firm’s defence framework, so why do so many firms continue to get it wrong with dire consequences? This session helps you make it more than a compliance document – ensuring it drives real risk awareness, control design, and informed decision-making. 

By the end of this session, you’ll: 

• Understand the regulatory purpose, objectives and expectations around financial crime risk assessments. 
• Identify key risk events and corresponding risk factors across different financial crime typologies (e.g. AML, sanctions, fraud, bribery). 
• Build or refine a structured, evidence-based risk assessment process.
•  Use the risk assessment to isolate relevant controls, enhance oversight, and improve business decision-making. 

Financial crime risks are evolving—but many of the mistakes wealth management firms make are still surprisingly familiar. This practical, fast-paced session helps your firm avoid the hidden traps and build frameworks that stand up to regulatory scrutiny and real-world pressure. 

By the end of this session you’ll: 

• Identify the most frequent and high-risk weaknesses in financial crime frameworks flagged by the FCA. 
• Understand potential root causes of these mistakes and how they manifest in real-world operations.
• Learn practical steps to remediate or avoid these issues within your own firm’s framework.
• Be able to understand how exposed your firm is to these issues and measure yourself against good industry practice. 

Your policies and controls are only part of the story without a positive financial crime compliance culture a firms controls will struggle to be embedded. This session will draw on real-life examples to help financial crime leaders and control functions influence firm-wide behaviour and embed lasting cultural integrity. 

 By the end of this session, you’ll: 

•  Understand how your culture directly impacts financial crime risk and regulatory outcomes. 
• Know what the characteristics of a strong financial crime compliance culture. 
• Recognise the barriers that undermine effective cultural change. 
• Apply practical techniques to influence staff behaviour, leadership tone, and ownership of financial crime risks. 

With growing regulatory scrutiny and complex financial crime risks, your firm must be able to evidence not just first-line controls, but also the robustness of their oversight and internal and external audit layers. This session supports PIMFA member firms enhance their oversight and assurance capability and demonstrate proactive financial crime risk management. 

By the end of this session you’ll: 

• Grasp the core components of an effective financial crime assurance framework.
• Differentiate clearly between the roles and responsibilities of 1LoD, 2LoD, and 3LoD in financial crime risk management.
• Evaluate how to design, implement, and maintain an effective 2LoD and 3LoD oversight and when to seek independent assurance process.
• Identify indicators of an effective assurance framework and common gaps observed by the FCA. 

Skilled person reviews, or s166s, are a tool used by the FCA to assess specific areas of concern they have on your firm’s approach to financial crime. They are intrusive, expensive and time-consuming for firms under such investigation. This session provides practical, regulatory-aligned guidance to help your firm ideally avoid such action. However, if faced with such an investigation, learn how to manage the process smoothly, maintain credibility, and emerge stronger on the other side. 

By the end of this session, you’ll: 

• Understand what a Skilled Person Review (s166) is and why it is commissioned by the FCA. 
• Prepare for the different stages of a s166 review – from initial notification to final reporting. 
• Manage internal coordination, communication, and governance during the review process.
• Minimise operational disruption and regulatory risk while demonstrating transparency and control. 

When concerns around money laundering, fraud, bribery, or corruption arise, the ability to carry out a well-structured and defensible internal investigation becomes critical. Firms must ensure they have both the expertise and confidence to act swiftly and effectively that are aligned to FCA expectations.  

This session is designed to build the practical skills and strategic thinking required to lead or contribute to internal investigations guiding you through the investigation lifecycle, helping you manage legal, regulatory, and reputational risks while increasing the likelihood of achieving fair and effective outcomes.  

By the end of this session, you’ll: 

• Understand the regulatory and legal requirements underpinning investigations under the FCA regime.
•  Recognise the skills and strategies required to set up, run and report on a workplace investigation.
•  Apply best practices for gathering, analysing and preserving digital and physical evidence. 
• Maintain documentation that meets FCA and potential court expectations. 

Screening failures are among the most common causes of regulatory action – but they’re also preventable. This session empowers firms of all sizes, to choose the right provider, test tools effectively, and maintain confidence in their screening controls. 

By the end of this session, you’ll: 

• Understand the regulatory expectations for sanctions, PEP, and adverse media screening. 
• Appreciate the key elements of customer screening and payment screening, including utilising third party watch list providers. 
• Evaluate what makes a screening tool “fit for purpose” in the context of your firm’s risk profile. 
• Identify key considerations when selecting or reviewing a screening provider. 
• Assess ongoing effectiveness and governance of screening solutions in practice. 

A robust transaction monitoring (TM) system is essential to detect and prevent financial crime effectively—and to meet regulatory expectations. Yet many firms struggle with outdated rules, inflexible platforms, and a disconnect between their risk assessments and actual monitoring activity. 

This session will guide firms through the key components of designing, implementing, and maintaining a fit-for-purpose TM system. You’ll learn how to build a framework that is proportionate, data-driven, and capable of evolving with your firm’s business model and risk landscape. 

By the end of this session, you’ll: 

• Understand the core building blocks of a compliant and effective TM system. Explore the FCA’s expectations on transaction monitoring as set out in the Financial Crime Guide and recent supervisory activity.
•  Learn how to align your TM rules and scenarios to your firm’s risk assessment, products, and client base. Identify the data, governance, and oversight structures required to support robust monitoring. 
• Discover how to enhance detection capabilities through typology mapping, threshold testing, and scenario tuning.
•  Consider the role of AI, and advanced monitoring tools in future-proofing your approach. 

Enhanced Due Diligence (EDD) is not just a tick-box exercise—it’s your firm’s front line of defence for high-risk relationships. This session equips compliance and onboarding teams with the tools and confidence to apply EDD that is risk-based, defensible, and audit-ready. 

 By the end of this session, you’ll: 

• Understand what does effective EDD look Like?
•  Identify which clients, transactions, or geographies trigger EDD requirements. 
• Apply a proportionate, risk-based approach to gathering and evaluating EDD information. 
• Strengthen documentation, escalation, and oversight of higher-risk relationships. 

Politically Exposed Persons (PEPs) relationships carry heightened regulatory, legal, and reputational risk. This session gives firms the confidence and capability to identify, assess, and manage these clients with a proportionate, compliant, and commercial approach. 

By the end of this session, you’ll: 

• Understand the legal and regulatory requirements for identifying and managing Politically Exposed Persons (PEPs). 
• Apply a proportionate, risk-based approach to onboarding and ongoing monitoring of PEPs and their associates.
•  Distinguish between foreign and domestic PEPs and apply appropriate levels of Enhanced Due Diligence (EDD).
• Strengthen governance, escalation, and documentation processes to manage regulatory risk and reputational exposure.