FCA opens new criminal money laundering investigation

The FCA has announced a criminal investigation into Euro Exchange Securities UK Ltd (EES) in relation to potential offences under the Money Laundering Regulations 2017 (the MLRs). This is understood to be the FCA’s first major criminal investigation into money laundering offences since 2021.

The announcement follows regulatory action by the FCA in June 2026 whereby it required EES to cease carrying on regulated electronic money or payment services and applied to the High Court for the appointment of special administrators.

The FCA can take civil or criminal action where a firm has breached a “relevant requirement” under the MLRs and, typically, the FCA conducts its investigations on a “dual-track” basis, leaving its options open as to whether matters should be resolved on a civil or criminal basis.  Where a person is found to have committed a criminal offence, possible sanctions include two years’ imprisonment and/or an unlimited fine. In this investigation, the FCA has said that its main concerns are that, between 2020 and 2026, EES may have failed to:

• take appropriate steps to identify and assess the risks of money laundering; and
• establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering identified in the risk assessment, including:
  • customer due diligence,
  • ongoing monitoring controls,
  • internal governance and oversight,
  • resourcing and allocation of responsibilities, and
  • record-keeping and escalation/reporting mechanisms.

The FCA more commonly relies on its supervisory and civil enforcement powers under the MLRs (and the Financial Services and Markets Act 2000) in relation to anti-money laundering failures. Should this investigation result in criminal charges, it would be the FCA’s first major money laundering prosecution since 2021 which resulted in a £264 million fine for the bank in question.

The FCA has not reached any conclusions as to whether EES has breached any relevant requirements or not, but the investigation is a useful reminder to those in the regulated sector that failure to manage AML risks in accordance with the MLRs can result in more than civil penalties.  

Please do contact Burges Salmon’s Corporate Crime & Investigations team if you would like to discuss any of the issues raised in this article.