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Financial Crime Committee – 01 April 2025

The committee discussed the UK government’s ransomware consultation. Members raised concerns around unclear authorisation processes and obligations under reimbursement-based cyber insurance. The draft response is being revised. The subgroup working on coverholder guidance opted for a flexible webpage format. Updates were given on evolving sanctions regimes, including the impact of US extraterritoriality and the implications of a potential Trump presidency. A scenario-planning tool was introduced. Russian credit defaults were also discussed, with a request for clearer licensing guidance. The committee agreed to align its terms of reference more formally and explore compliance resources under ECCTA