Dear Deputy CEO

Hi ,

Sarah Pritchard (previously FCA Exec Director for Supervision, Policy & Competition and International) was promoted to the new role of Deputy CEO of the FCA yesterday. She will now manage a wider perimeter (PSR integration, crypto, BNPL) and its expanding international agenda.

Below I provide three highlights from her career history which could inform her role as Deputy CEO of FCA and why you should care as an AML Leader.

1. Expect collaboration 

2. Expect change 

3. Expect detailed engagement 

I finish with one point from her most recent speech which may help predict her stance on risk-based approaches.

1. Expect further collaboration within the FCA and potentially beyond

There is more cross-government collaboration than ever on the subject of financial crime.

Expect that to continue.

Pritchard not only has a track record of doing this in the FCA - it was the first point she mentioned in her LinkedIn post announcing the change (see below).

As she says - “#breakingdownsilos”

2. Expect change - she has a track record of introducing new programmes/approaches

Data point 1: Pritchard was the first director of the National Economic Crime Centre and established it as a function.

Data point 2: She also established and led the FCA’s Supervision, Policy and Competition division (re: collaboration - she integrated supervision & policy).

3. Expect detailed engagement - she understands FinCrime operations from industry perspective

Not only does Pritchard have a background in industry with HSBC…

…she also has a track record of caring about detailed metrics.

Here’s what she called out in her most recent speech (last week) around how she has helped make the FCA a smarter regulator:

1. Processing times are no longer the bottleneck they were

   • 99.9% of SMCR approvals landed inside three months in Q4 2024

   • 100% of change-in-control cases were decided within 60 days

2. Meaningful cut to “dead-weight” rules

   • Capital-rules consolidation for investment firms expected to remove 70% of the current text

   • Archives of out-of-date Dear CEO letters underway.
     These changes should shrink the volume of duplicate MI requests we field

FinCrime hints

Finally, in last week’s speech she didn’t explicitly refer to anything from a financial crime perspective - only saying that the FCA wanted to be a smarter regulator.

That’s not too surprising. That speech was about UK competitiveness in public markets (and probably not the time to announce a new FinCrime approach).

But she did give some hints around risk appetite.

Pritchard wants investors “to take some risk” where appropriate, arguing that zero-risk cultures erode long-term returns.

Supervision visits are likely to probe how boards balance consumer protection against growth rather than insisting on absolute risk elimination.

Immediate actions to consider

• Refresh risk assessments for crypto-asset, BNPL and stable-coin flows ahead of perimeter expansion

• Review board MI packs to ensure they evidence a calibrated, not zero-tolerance, approach to risk

Closing thought

Pritchard’s LinkedIn post above (remember #breakingdownsilos) is bullish, but the hard numbers in her speech back up the rhetoric. Faster authorisations, less red tape, and a sandbox culture signal an FCA that wants to regulate by outcome rather than volume of guidance.

As AML Leaders, that means more room to build intelligence-led controls - provided we’re ready to demonstrate how they balance risk with growth.

Let me know anything else you’ve noted.

Cheers,

Paul