Financial crime and SMCR proposals
The Financial Conduct Authority has published consultation paper CP26/38 proposing updates to its Financial Crime Guide, which covers sanctions, fraud, data security, artificial intelligence and external provider oversight. The consultation closes on 24 December 2026. The guidance highlights screening only at the claims stage as poor practice and questions reliance on third-party screening without adequate checks. Meanwhile, the FCA and PRA have published Phase 2 consultations on proposed reforms to the Senior Managers and Certification Regime, including the removal of the Certification Regime, a reduction in roles requiring regulatory approval, and the retirement of the Directory of certified and assessed persons. Both consultations close on 22 January 2027. The MGAA noted these changes are currently proposals rather than final rules.
Artificial intelligence governance
An October publication from the FCA outlines good practice and areas for improvement regarding artificial intelligence, focusing on governance, customer outcomes, human oversight and supplier management under existing regulatory requirements. Additionally, the Information Commissioner's Office is seeking evidence on data security, transparency, accountability and automated decision-making regarding agentic artificial intelligence, with responses closing on 20 November 2026. The MGAA advised members to maintain existing accountability arrangements and assess how controls operate in practice despite potential administrative reductions.