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ARTICLE · 17 DECEMBER 2025

Investment Management Update - December 2025

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Welcome to the latest edition of our investment management update. This publication has been tailored to highlight topical news, cases and changes in the law impacting the investment management sector.

United KingdomStrategy
Lora Froud
Lora Froud
Alex Green
Alex Green
Alexandra Green
Alexandra Green
Michael Sholem
Michael Sholem
Rachel Serene
Rachel Serene

Welcome to the latest edition of our investment management update. This publication has been tailored to highlight topical news, cases and changes in the law impacting the investment management sector.

UK

FCA review of firms AML risk assessments: On 11 November 2025, theFCA published its findings following a review of both business-wide risk assessments (BWRA) and customer risk assessments for a range of firms, including wealth management firms, platforms and custody and fund service providers. The poor practices identified included failing to tailor the BWRA to the specific business and inadequate evidence for concluding their business was low risk. The FCA was concerned that some firms could not explain sufficiently how they are managing and mitigating identified risks. Firms are encouraged to consider the FCA's findings and suggestions within the context of their firm and continue to review their risk-based approach to systems and controls.

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