The FCA in the UK has published this thematic review which highlighted a number of significant weaknesses in AML controls applied across the industry. A review of 19 firms was involved, and the FCA concluded that there is a general lack of deep understanding of money laundering risk to the capital markets. Complex cross border deals made up of multiple parties to a transaction provide numerous loopholes and weaknesses for money launderers to exploit. The FCA recommends that all market players start taking a full risk-based approach to money laundering in the context of the wider exposure they are liable to. It appears that the FCA is considering a supervisory response. The Annex to the review contains examples of typologies based on risks found in the sector, and which include helpful and simplified diagrams. The Annex also identifies a number of features that could serve as red flags, or at least prompt further questions – remote booking of trades between group entities; pre-arranged trading; instructions or involvement from third parties; ‘free of payment’ asset transfers; non-standard settlement arrangements uneconomic or irrational trading strategies of a customer; unusual trading patterns, such as: counterparty concentration, unusual win/loss rates or flat/neutralising activity, and no trading on an account.