HSBC fined for AML failures

FCA Intervention Guidance welcomed but digital notifications should be mandated

In our recent report Probate or Pro-wait – how to make the hardest part of life easier, we recounted a story of how a bereaved widow had to contact more than 20 individual organisations to inform them that her husband had died. We also reported that nearly three in four (72%) of 2,000 UK adults surveyed agreed that every bank and utility company should have a specific death notification service similar to the ‘Tell Us Once’ service provided by the Government.

We are delighted, therefore, to learn that the Financial Conduct Authority (FCA) has published new guidance on how banks should treat customers in vulnerable circumstances – including bereavement – following a review of current practices (published 12 April 2025).

‘Good’ firms, it identified, had clear customer policies and procedures with regard to vulnerability, which often set out the expected timeframe for staff to process registration of bereavement and Power of Attorney (PoA) cases.

The FCA also identified where things needed to improve. In some cases, there was clear evidence of poor practice or lack of awareness of internal policies, exacerbating the distress for customers and their representatives when they did not get the support they needed. Staff did not always acknowledge that customers were noticeably upset, even though failing to recognise and respond sensitively can have a direct impact on the customer’s confidence in engaging with financial services.

There are several recommendations as to how firms might consider adapting their bereavement customer journeys to help ensure they are as straightforward and flexible as possible. It is also encouraging to know that most firms that the FCA engaged with have dedicated bereavement teams.

What especially stuck out for me, however, was the common issue shared across multiple banks and financial services providers: customers (particularly in bereavement processes) had to repeat information when speaking to different staff members, or had their cases delayed or dropped altogether because they had been ‘lost’ in the firm’s systems, risking further distress and upset.

The FCA also highlighted how fragmented customer relationship management (CRM) systems across business lines could make it harder to keep track of cases and process them efficiently. ‘We encourage firms to focus on ensuring customer journeys are fit for purpose across legal entities, to reduce the risk that consumers do not get their needs met or must repeat information unnecessarily,’ it says.

It is especially interesting because it taps into our opinion – borne out by our research – that the lack of any universally agreed, digitally-based process for death notifications within the private sector is contributing to a more stressful bereavement experience.

As owners of the bereavement notification services NotifyNOW and Settld, we have previously called on the FCA and the Government to go much further in their plans to require firms to accept digital death verification. We have also long believed that third-party providers should be mandated to have a dedicated bereavement team and minimum Key Performance Indicators in how the bereaved are handled. It seems that the FCA agrees.

Every bank, utility company and service provider – and not just those regulated by the FCA – should have a consistent death notification service and much better signposting is needed to steer consumers to the help available in explaining how the process works.

The guidance from the FCA is a welcome first step – but it needs to go further. We should harness the momentum that is now being generated and accelerate the appointment of a Bereavement ‘Tsar’ within the Government to champion the better treatment of consumers managing a death.

We need a powerful voice with the authority to hold firms to account. Guidance is the first stage, but what’s really needed is mandatory action.

For a copy of our report, Probate or Pro-wait – how to make the hardest part of life easier, go to https://estate-registry.co.uk/probatereport/

By Phil Hickson – SVP, Global Partnerships at The Estate Registry

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