The practical guidance highlights the importance of improving customer outcomes, accountability and governance, and operational resilience. Launching the best practice examples this week, Jessica Rusu, the FCA’s chief data, information and intelligence officer, said the FCA is using AI to gather evidence and flag early warning signs and is ‘building AI tools for the oversight of 60,000 anti-money laundering (AML) firms coming into the FCA’s remit in 2028.
‘We are deploying automation and building AI agentic tools—like our market first responder agent—which will supervise about 9,000 small wholesale markets transaction reporting firms.’ Rusu said regulators would increasingly need to make judgements without precedent because of the speed of AI development.
Priya Dave, of counsel at Corker Binning and a former contentious regulation lawyer at the FCA, said law firms should read the announcement as a preview of how they will be supervised when the FCA takes over AML supervision of the legal sector from 2028.
‘Law firms used to a more guidance-led approach by the SRA should expect sharper scrutiny of their data, controls and decision-making, and would be wise to ready themselves for this now by revisiting and refreshing their firm-wide risk assessments and AML frameworks.’
Imogen Makin, counsel at WilmerHale, said: ‘The FCA’s plans to use agentic AI across its divisions are to be commended.’ She noted the FCA has used a lack of detailed rules as a means of achieving enforcement outcomes based on high-level principles breaches in the past. Makin said: ‘Firms could use further clarity on their obligations in circumstances where it’s clear a customer has relied on AI to make financial decisions. That is currently a significant area of risk for regulated firms.’
