The FCA has published a ‘Dear CEO’ letter regarding the procedures for taking on new clients for firms that offer contract for difference (CFD) products. The FCA has reviewed the procedures of ten firms that offer CFD products on a non-advised basis, assessing the client take-on procedures against the requirements in COBS and SYSC. Areas of concern identified by the FCA include firms’ appropriateness assessments and AML systems and controls. More generally, the FCA is concerned that there is a high risk that CFD providers are not meeting regulatory requirements when taking on new clients or are failing to do enough to prevent financial crime, or both.