FCA Resources
FCA AML obligations for payment firms
MLR 2017, PSRs 2017, and JMLSG guidance — the three-layer UK regulatory framework that governs AML compliance for FCA-supervised payment processors and challenger banks.
MLR 2017
Money Laundering Regulations 2017 — the primary framework
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) set the primary UK legal framework for anti-money laundering and counter-terrorist financing. FCA-supervised firms — including payment processors, e-money institutions, and challenger banks — must comply with MLR 2017's requirements.
Key obligations under MLR 2017 include: customer due diligence (CDD) and enhanced due diligence (EDD) for high-risk customers; transaction monitoring for unusual patterns; suspicious activity reporting (SAR) to the UK National Crime Agency (NCA); and record-keeping for a minimum of five years.
| Obligation | Regulation | RegSynq Mapping |
|---|---|---|
| Customer Due Diligence | Reg. 27–38 | Customer Risk Scoring — CDD/EDD triggers |
| Enhanced Due Diligence | Reg. 33 | EDD auto-trigger at configurable threshold |
| Transaction Monitoring | Reg. 28 | Real-time monitoring against FCA typologies |
| Suspicious Activity Reporting | POCA 2002 + MLR Reg. 40 | SAR Auto-Filing — NCA submission within 2 hours |
| Record-Keeping (5 years) | Reg. 40 | Immutable audit log with export |
PSRs 2017
Payment Services Regulations 2017 — payment-specific AML
The Payment Services Regulations 2017 (PSRs 2017) implement PSD2 in the UK and set additional obligations for payment service providers. For AML compliance purposes, the key provisions relate to information accompanying fund transfers, fraud monitoring, and the information-sharing obligations that overlap with MLR 2017 SAR requirements.
| PSRs 2017 Provision | AML Relevance |
|---|---|
| Reg. 88 — Transfer of funds information | Payer/payee data requirements for wire transfers — input to transaction monitoring |
| Reg. 93 — Information on the payer | Incomplete payer data triggers monitoring escalation |
| FCA Principle 11 — Cooperation with regulator | SAR filing and evidence pack obligations for FCA information notices |
JMLSG Guidance
JMLSG guidance — the sector-specific interpretation the FCA expects
The Joint Money Laundering Steering Group (JMLSG) publishes sector guidance that provides the FCA's expected interpretation of MLR 2017 obligations for specific sectors. For payment service providers, Part II of the JMLSG guidance sets out the risk-based approach, typologies, and monitoring approaches the FCA will assess during supervisory visits.
RegSynq's transaction monitoring typologies are aligned to JMLSG Part II guidance for payment institutions — including Section 6.4 structuring typologies, cross-border wire patterns, and the domestic payment fraud indicators the JMLSG identifies for card-processing entities.
See how RegSynq maps to your FCA obligations
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