FCA expectations on due diligence when dealing with unregulated lenders

What the FCA said

In March 2026 the FCA highlighted the risks for regulated firms, such as brokers, when they work with lenders that are not FCA-authorised, including firms registered with the FCA only for anti-money-laundering purposes under Annex 1. The message was that firms should carry out robust due diligence and make independent checks rather than relying on what the counterparty tells them.

Read the FCA's statement itself and your compliance adviser's view before changing your procedures; this summary is simplified.

Why it matters to lenders

Brokers and funders are likely to ask more questions of the lenders they introduce business to. Lenders that can show a clear, consistent record of their own checks on brokers, solicitors and borrowers are easier to work with.

Independent checks you can record

• The firm's status on the FCA Register, including whether it is authorised or only registered, and the FCA Warning List.
• The company on Companies House: status, officers, people with significant control, filing history and charges.
• Directors against the disqualified directors register.
• The ICO data protection register.
• Trade body memberships, confirmed with the body itself.

Example

A broker asks an unregulated bridging lender for evidence of its checks before placing a case. The lender sends a dated report showing register results and screenshots for the solicitor and borrower company, and the case proceeds without a delay.

What Vettsafe records

Vettsafe runs the register checks above in one place, captures a screenshot from each source at the time of the check and exports a timestamped PDF for the credit file.