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ESG Risk Becomes Core AML Exposure for MLROs as FCA Consultation Deadline Falls in March 2026

ESGESG Risk Becomes Core AML Exposure for MLROs as FCA Consultation Deadline Falls in March 2026

The UK’s Financial Conduct Authority published Consultation Paper CP26/5 in January 2026, with a March 20, 2026 feedback deadline, proposing alignment of listed issuers’ sustainability disclosures with international standards.

For Money Laundering Reporting Officers, the convergence of ESG and AML obligations is no longer theoretical — regulators across the UK, EU, Netherlands, and Australia are treating inaccurate ESG disclosures as potential financial crime predicate conduct, capable of triggering fraud, misrepresentation, and AML investigations.

In the EU, Germany’s financial regulator BaFin has imposed a significant penalty on an asset manager for alleged greenwashing, while France’s financial markets regulator has repeatedly identified misleading sustainability communications as an enforcement priority, having completed over 25 environmental deferred prosecution agreements since 2020.

For compliance teams, this means ESG risk must be incorporated into client onboarding, ongoing monitoring, and product governance frameworks — not managed separately by sustainability functions. Adverse media screening should now include environmental and governance misconduct signals. Meanwhile, the EU Omnibus simplification has reduced the formal CSRD reporting scope for many mid-sized firms, but ESG litigation and enforcement risks remain elevated across jurisdictions, particularly around greenwashing claims and supply chain due diligence failures.

By FCCT Editorial Team

Disclaimer: The views expressed in this article are independent views solely of the author(s) expressed in their private capacity.

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