Pseudonymising Firm-Wide Financial-Crime Risk Assessments – UK GDPR-compliant anonymisation per FCA SYSC 6
Firm-wide financial-crime risk assessments (FCRAs) document the firm's exposure to money laundering, fraud, and sanctions risks, and may reference named high-risk customer segments or named senior managers responsible for risk ownership. anonym.legal pseudonymises those personal references so the FCRA can be shared with external advisers or auditors assessing the adequacy of the firm's systems and controls under FCA SYSC 6 without disclosing individual identities.
When this applies
This task applies when an FCRA is shared with external assurance providers, skilled-person reviewers, or board advisers who require sight of the risk methodology, exposure ratings, and control gaps but do not need to know the identities of named individuals referenced in the assessment.
How anonym.legal handles it
- Upload the FCRA document (PDF or DOCX).
- The engine identifies named senior managers, named risk owners, and any named customer-segment examples referenced in the narrative.
- Each named individual is pseudonymised consistently; risk exposure ratings, control descriptions, gap analysis, and remediation timelines are preserved.
- Board-approval records and regulatory-submission history references remain in clear text.
- A reversible mapping table is produced with UK/EU data residency.
- Release the pseudonymised FCRA for external adviser or auditor review; restore originals before any regulatory submission.
What you provide
- Firm-wide financial-crime risk assessment document
- Risk-register appendix (if it names individuals as risk owners)
- Board-approval sign-off documentation
Limitations & cautions
- The tool pseudonymises personal references in the FCRA but does not assess whether the risk methodology or control framework is adequate under FCA SYSC 6.
- FCRAs that reference named customer segments or customer types (rather than named individuals) do not require pseudonymisation of those segment descriptions.
- The pseudonymised FCRA must not be submitted to the FCA or UKFIU in place of the original.
FAQ
Should I pseudonymise the names of senior managers listed as risk owners?
Yes. Senior manager names are personal data under UK GDPR and should be pseudonymised when the FCRA is shared outside the compliance team. Role titles and responsibility areas are preserved.
Does the tool handle FCRAs that reference third-party correspondent bank relationships?
Named natural persons at correspondent banks are pseudonymised. Correspondent bank institution names are preserved unless you flag them for pseudonymisation.
Can a pseudonymised FCRA be shared with an external skilled-person reviewer?
Yes, for preliminary review purposes. However, the skilled-person reviewer may ultimately require the re-identified version to fulfil their obligations under an FCA s.166 review — confirm this requirement before sharing the pseudonymised version.