FCA Registration Support for Annex 1 Firms

At Fundsure, we specialise in helping firms navigate the FCA's registration process for Annex 1 financial institutions under the Money Laundering Regulations (MLRs). These firms - including certain lenders, money brokers, financial leasing companies, safe custody providers, and other specified entities - must register with the FCA for anti-money laundering (AML) supervision, even if they do not require full Part 4A authorisation for their core activities.

The threshold question is rarely as simple as it looks. Whether a firm captures an Annex 1 activity often turns on the precise mechanics of what it does: a lender that originates loans sits differently from a vehicle that acquires receivables by assignment, and a structure that looks like straightforward lending can edge towards the collective investment scheme perimeter. Getting this scoping right at the outset is what separates a clean registration from a rejected or mis-scoped one. We work through the detail with you before a single form is completed.

With over 35 years of regulatory expertise in financial services, we understand the unique challenges Annex 1 firms face. The FCA has increased scrutiny on these registrations, with a focus on robust financial crime controls, accurate activity descriptions, and ongoing compliance. We help you achieve a smooth, successful registration and maintain strong AML frameworks to meet regulatory expectations.

How We Can Help

Our team provides end-to-end support tailored to Annex 1 firms, including:

• Activity Scoping and Perimeter Analysis - A clear-eyed assessment of whether and how your activities fall within Annex 1, including the finer points that drive registration outcomes (such as loan origination versus acquisition by assignment, and any collective investment scheme perimeter considerations).

• Application Preparation and Submission - Full assistance with the FCA registration process, ensuring your application accurately reflects your business activities and meets all requirements.

• Business-Wide Risk Assessments (BWRA) - Development or review of comprehensive risk assessments to identify and mitigate money laundering and terrorist financing risks.

• Policies, Controls, and Procedures - Creation of a complete AML policy and procedures suite covering customer due diligence (CDD), ongoing monitoring, and suspicious activity reporting, tailored to your operations and designed to support a complete, credible application.

• Fit and Proper Checks - Support with background screening (if required), including Basic DBS checks, ID verification, KYC/AML checks, and adverse financial checks for Ultimate Beneficial Owners (UBOs) and controllers.

• Governance and Training - Advice on governance structures, audit trails for financial crime decisions, and bespoke staff training (including our online AML courses aligned with JMLSG and FCA guidelines).

• Ongoing Compliance Support - Post-registration healthchecks, monitoring, and updates to keep pace with evolving FCA expectations, such as those highlighted in recent Dear CEO letters.

We project manage the entire process, from initial scoping to submission via Connect, minimising delays and reducing rejection risks.