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Senior Individual Accountability For Market Announcements: The UK FCA Fines Former Carillion Finance Directors

Two recent FCA fines demonstrate the FCA’s willingness to hold senior executives of listed companies to account, including for market disclosures. The FCA will rely on a low bar to hold them 'knowingly concerned', pursue...more

Major Law Reforms And Shifting SFO Guidance Impacts Corporate Criminal Enforcement In The UK

The UK continues to strengthen its approach to white collar crime and corporate investigations, with significant legal and regulatory reforms introduced in 2025 and further changes anticipated. The UK Government’s new...more

Out of sight, not out of scope: UK FCA fines and bans individual for insider dealing

The UK FCA has fined a capital markets adviser to an energy company £100,281 – and banned him from working in financial services – for insider dealing. The action illustrates the comparatively low threshold for what may...more

UK FCA Data Exfiltration Prosecutions: A Reminder Of Malicious Insider Risks

Data exfiltration via cyberattack is top-of-mind for financial services firms. Regulatory attention is primarily focused on the risk of impersonation to misappropriate funds, but there are two other angles firms would do well...more

Managing “Internal” Investment Funds And Conflicts of Interest: Recent UK FCA Action

The UK Financial Conduct Authority (FCA) has recently censured BlueCrest Capital Management (UK) LLP (BlueCrest) and secured a voluntary USD101m redress scheme for investors in a fund it managed. The action highlights the...more

FCA Consultation on Motor Finance Redress Scheme

Shortly after the London markets closed on October 7, the Financial Conduct Authority published a consultation (CP25/27) incorporating its proposed market‑wide consumer redress scheme under section 404 of the Financial...more

Executive directors “knowingly concerned” in bank’s breach of the UK listing rules

The UK Upper Tribunal (Tax and Chancery) has upheld the Financial Conduct’s Authority’s (FCA) decision to take action against two former executives of a bank for being “knowingly concerned” in the bank’s breach of the listing...more

Rebalancing risk and building trust: The FCA’s new five year strategy

The UK Financial Conduct Authority (FCA) has published its strategy for the next five years and it has a very different tone and objective to the three-year strategy it shared in 2022. This shift in tone reflects developments...more

The end of the road for (most of) the FCA's transparency proposals

Just over a year ago, the UK Financial Conduct Authority (FCA) found itself at the centre of strong industry and political feedback when it first published its controversial proposals to ‘name and shame’ firms that it had...more

New U.K. regulatory landscape: enforcement and supervision shift

This article examines the latest trends in U.K. regulatory enforcement and supervisory action and highlights the key takeaways for firms in 2025 and beyond. Over the past 18 months, the Financial Conduct Authority (FCA)...more

UK FCA proposals to publicise enforcement investigations: Unanswered questions remain

Last week, the UK Financial Conduct Authority (FCA) unveiled a 'Part 2' consultation paper detailing a revised version of its controversial proposals to publicly name firms under enforcement investigation. This development...more

UK Upper Tribunal overrules FCA finding that Julius Baer employees lacked integrity

The UK Upper Tribunal (Tribunal) has overruled Financial Conduct Authority (FCA) decisions that three former employees of Julius Baer International Limited (JBI) lacked integrity and should be prohibited. The Tribunal’s...more

Ten FCA and PRA enforcement predictions for 2023 – Part 2

This pair of posts focuses on ten less-obvious enforcement predictions that we think will shape the UK financial services investigations and enforcement landscape during 2023 and beyond. Originally published in on...more

Ten FCA and PRA enforcement predictions for 2023 – Part 1

This pair of posts focuses on ten less-obvious enforcement predictions that we think will shape the UK financial services investigations and enforcement landscape during 2023 and beyond. Originally published in Practical...more

What the FCA’s Business Plan and Strategy really means: a brave new world

The UK Financial Conduct Authority’s (FCA) shift towards consumer protection is intensifying. At the same time, it is gearing up to become a more assertive regulator, intervening more frequently, following the example of its...more

What the FCA’s Business Plan and Strategy really means: financial crime

Financial crime has been a key area of focus for the UK Financial Conduct Authority (FCA) for a number of years, attracting some of the highest financial penalties, and this looks set to continue. With improvements to FCA...more

What the FCA’s Business Plan and Strategy really means: collection and use of data

The requirement for firms to collect and report quality data has never been more important, with the UK Financial Conduct Authority’s (FCA) outcome driven strategy looking to rely on firm data to realise its plans. In this...more

What the FCA’s Business Plan and Strategy really means: digital markets

The UK Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) recently published their Business Plans for 2022/23. The FCA also published a three-year strategy. But what does it really mean for firms? ...more

FCA and PRA Enforcement Action: Trends from 2021 and Predictions for 2022

As the dust looks like it is starting to settle on the Covid-19 pandemic, the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) have been busy resuming their enforcement agendas. Originally...more

The Senior Managers and Certification Regime

Helping to prepare FMIs, payment and e-money firms for proposed implementation...more

UK corporate criminal liability reform

The UK Government has asked the Law Commission to review the law on corporate criminal liability and propose options for reform. Supporters of reform will use recent failures of the UK Serious Fraud Office to prosecute large...more

Legal agility and risk resilience: How to enhance your organisation’s readiness to withstand the next crisis

What can in-house legal, risk and compliance leaders learn from the Covid-19 pandemic and other notable crises of the past 20 years to strengthen the legal resilience of their organisations? More than any other crisis in...more

GDPR for Litigators

Virtually all evidence, whether in litigation or arbitration or relating to investigations carried out by regulators or enforcement authorities, will contain some personal data. A year on from the EU General Data Protection...more

ENRC v SFO appeal: internal corporate investigation documents were protected by privilege

Documents, including interview notes, generated by mining company ENRC during an internal corruption investigation were protected by privilege and therefore did not have to be disclosed to the Serious Fraud Office (SFO). ...more

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