United Kingdom Financial Sector Assessment Program Some Forward Looking Cross Sectoral Issues

The United Kingdom faces significant money laundering threats from foreign criminal proceeds, owing to its status as a global financial center, but the authorities have a strong understanding of these risks. The authorities estimated the realistic possibility of hundreds of billions of pounds of illicit proceeds being laundered in their jurisdiction. The money laundering risks facing the United Kingdom include illicit proceeds from foreign crimes such as transnational organized crime, overseas corruption, and tax crimes. Financial services, trust, and company service providers (TCSPs), accountancy and legal sectors are high-risk for money laundering, with also significant emerging risks coming from cryptoassets. Some Crown Dependencies (CDs) and British Overseas Territories (BOTs) have featured in U.K. money laundering investigations. Brexit and COVID pandemic have an impact upon the money laundering risks in the United Kingdom. The authorities nevertheless have demonstrated a deep and robust experience in assessing and understanding their ML/TF risks. Leveraging technology tools such as big data and machine learning to analyze cross-border payments may add further dimension to their risk assessments. This technical note (TN) will focus on key aspects of the United Kingdom’s anti-money laundering and countering the financing of terrorism (AML/CFT) regime: risk-based AML/CFT supervision, entity transparency and international cooperation.

This paper assesses the stability of the financial system of the United Kingdom as a whole, not that of individual institutions. Since the last Financial Sector Assessment Program (FSAP), the U.K. financial system has put the legacy of the crisis behind it and has become stronger and more resilient. This FSAP found the system to be much stronger and thus better able to serve the real economy. Like all systems, the U.K. financial system is exposed to risks. Its position as a global hub exposes the U.K. financial system to global risks. In addition, the uncertainties associated with the possibility of British exit from the EU weigh heavily on the outlook.

The United Kingdom’s macroprudential policy framework has proven its effectiveness. After the Global Financial Crisis (GFC) of 2007–09, the United Kingdom assigned the Bank of England (BOE) a clear financial stability mandate, created a new Financial Policy Committee (FPC) to set macroprudential policy, and shifted to a “twin peaks” model of financial oversight. The 2016 Financial Sector Assessment Program (FSAP) concluded that the new framework appeared appropriate for effectively conducting macroprudential policy. However, the framework was then relatively new. The 2021 FSAP represents an opportunity to review its performance in building systemic resilience through the financial cycle, including the market volatility resulting from the Brexit vote and the COVID-19 pandemic.

There has been a very smooth post-Brexit transition, with no material disruption nor any crystalized financial stability risks. This was the result of the U.K. authorities’ (and in some cases the EU authorities) and firms’ extensive preparations. The U.K. authorities have been proactively engaging with the industry, monitored risks, and consistently provided necessary legal certainty in a timely manner. This approach should continue, to the extent that any risks and uncertainties from Brexit remain.

This Financial System Stability Assessment paper discusses that Canada has enjoyed favorable macroeconomic outcomes over the past decades, and its vibrant financial system continues to grow robustly. However, macrofinancial vulnerabilities—notably, elevated household debt and housing market imbalances—remain substantial, posing financial stability concerns. Various parts of the financial system are directly exposed to the housing market and/or linked through housing finance. The financial system would be able to manage severe macrofinancial shocks. Major deposit-taking institutions would remain resilient, but mortgage insurers would need additional capital in a severe adverse scenario. Housing finance is broadly resilient, notwithstanding some weaknesses in the small non-prime mortgage lending segment. Although banks’ overall capital buffers are adequate, additional required capital for mortgage exposures, along with measures to increase risk-based differentiation in mortgage pricing, would be desirable. This would help ensure adequate through-the cycle buffers, improve mortgage risk-pricing, and limit procyclical effects induced by housing market corrections.

Ireland has considerably strengthened financial sector regulation and supervision since the 2016 FSAP, aided by the ECB/SSM, and is working with European and international regulators to strengthen oversight of the large market-based finance (MBF) sector. This strengthening is evidenced by a successful navigation through the challenges of Brexit and the pandemic. Despite global headwinds, Ireland is exiting the pandemic with strong economic growth and a highly capitalized and liquid banking system. The financial system has grown rapidly and in complexity, especially after Brexit, and Ireland has become a European base for large financial groups. The MBF sector has grown to the second largest in Europe, with global interlinkages.

The Financial Sector Assessment Program (FSAP) carried out a targeted evaluation of issues relating to the effectiveness of banking regulation and supervision in the United Kingdom. It leverages on the 2016 FSAP which concluded that the United Kingdom (U.K.) had a high degree of compliance with the 2012 Basel Core Principles (BCPs) with some shortcomings. The 2021 FSAP reviewed the progress in addressing them and examined the main supervisory and regulatory developments since the last FSAP. The FSAP evaluation also focuses on steps taken to minimize disruptions in the U.K. banking system at the end of the Brexit transition period, and on the regulatory and supervisory measures introduced to contain spillovers from the ongoing COVID-19 pandemic on the U.K. banking system.