How this came about
The FCA is already collecting the evidence.
The 5 March 2024 letter went only to Annex 1 firms registered at the time. If yours was one, the gap analysis it asked for is what the FCA said it is likely to ask you to produce. If your firm registered since, no lapsed deadline applies to you, and the same four weaknesses are still the yardstick.
4
Common weaknesses named in the FCA’s Dear CEO letter of 5 March 2024, which asked firms to “complete a gap analysis against each of the common weaknesses we have outlined within six months of receipt of this letter”.
300
Annex 1 firms the FCA worked with in late 2025. The 7 August 2026 statement says the newer request “follows on from” that work.
900
Firms the FCA said it had sent an information request to, in a statement published on 7 August 2026. That request “means we will have contacted all registered Annex 1 firms”, and the FCA will use what it collects “to identify and disrupt financial crime risks in this sector”.
Sources: FCA, Dear CEO letter · 5 March 2024, and FCA applying increased scrutiny to Annex 1 firms · 7 August 2026