In early September 2025, the U.K. and UAE Governments conducted talks in London “to strengthen bilateral co-operation in the fight against illicit finance,” including anti-money laundering (AML) and counter terrorist finance...more
In early 2024, the UK Financial Conduct Authority (FCA) announced that it intended to make it easier for itself to publish the names of firms under investigation. This led to market-wide uproar as well as criticism in...more
A consultation paper published in early 2025 by His Majesty’s Treasury (HMT) and a parallel call for input by the UK Financial Conduct Authority (FCA) contemplated the repeal and replacement of the UK Alternative Investment...more
November and December 2025 witnessed an active period in the UK and European regulatory landscape, marked by significant regulatory developments in and affecting financial services. This alert highlights certain regulatory...more
Historically, the FCA’s position on crypto assets was consistently to repeat to consumers that “if you decide to invest in crypto then you should be prepared to lose all the money you have invested”. Suffice to say, the FCA’s...more
Motor finance agreements are often arranged on (or rather near) a motor dealership forecourt. To facilitate the sale of a vehicle, the motor dealer acts as a broker for a consumer to finance that vehicle, with the ultimate...more
OFSI reports that since 2022 and the imposition of sanctions on Russia, it has been pursuing a higher number of complex investigations, with a record number of cases being opened in recent years. This is also reflected in the...more
Back in 2018, a senior member of the Financial Conduct Authority (FCA) stated that “non-financial misconduct is misconduct, plain and simple”. Since then, the FCA has issued multiple discussion and consultation papers,...more
The types of consumer credit arrangements at issue in all of the relevant motor finance cases are “three-cornered” transactions. Motor dealers would offer a car for sale, which a member of the public would then see and wish...more
8/6/2025
/ Car Dealerships ,
Consumer Contracts ,
Consumer Lenders ,
Consumer Protection Laws ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
Lenders ,
Loans ,
Popular ,
Regulatory Oversight ,
UK
On 3 June 2025, the UK Financial Conduct Authority (FCA)’s updated Enforcement Guide (ENFG or the Guide) came into force. The ENFG, which replaces the previous Enforcement Guide (referred to as ‘EG’) from 2007, describes the...more
On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more
5/13/2025
/ Anti-Corruption ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Agencies ,
Switzerland ,
UK
We are now starting to see a real shift in the UK Financial Conduct Authority’s (FCA) Enforcement strategy following a changing of the guard in 2023, which brought in Therese Chambers and Steve Smart to be Joint Executive...more
Fraud is the most common offence in the UK, amounting to 41% of all crime. On 26 October 2023, the UK’s long-awaited Economic Crime and Corporate Transparency Act 20232 (the Act) received Royal Assent, setting out...more
2/17/2025
/ Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Governance ,
Corporate Transparency Act ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Fraud ,
Penalties ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management ,
UK
Last month, the United Kingdom Financial Conduct Authority (FCA) announced that it is considering new procedures under which it would publicly identify firms that are under investigation as soon as the investigation has been...more
4/1/2024
/ Cross-Border ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement ,
Financial Conduct Authority (FCA) ,
FSMA ,
Investigations ,
Notice Requirements ,
Securities and Exchange Commission (SEC) ,
UK ,
Willful Misconduct
The U.K. Financial Conduct Authority has published its proposed approach to publishing information about the opening and progress of investigations.1 The proposals represent a marked departure from the FCA’s current practice...more
Key Points -
Following a joint Discussion Paper in 2021 issued by the FCA and the PRA, both regulators have now issued Consultation Papers proposing new rules and guidance in relation to diversity and inclusion in the...more
10/27/2023
/ Corporate Governance ,
Corporate Misconduct ,
Criminal Convictions ,
Diversity and Inclusion Standards (D&I) ,
Ethics ,
Financial Conduct Authority (FCA) ,
Policy Statement ,
Proposed Regulation ,
Proposed Rules ,
Prudential Regulation Authority (PRA) ,
Regulatory Agenda ,
Regulatory Requirements ,
Rules of conduct ,
UK
Key Points -
-Following a joint Discussion Paper in 2021 issued by the UK Financial Conduct Authority (FCA) and the UK Prudential Regulation Authority (PRA), both regulators have now issued Consultation Papers proposing new...more
10/27/2023
/ Banking Sector ,
Disclosure Requirements ,
Discrimination ,
Diversity ,
Diversity and Inclusion Standards (D&I) ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Services Industry ,
Prudential Regulation Authority (PRA) ,
Regulatory Agenda ,
Regulatory Requirements ,
Rules of conduct ,
UK
Overview -
A survey conducted by the United Kingdom Financial Conduct Authority (FCA) in early 2022, but published only in 2023, has revealed the stark reality that the regulator is not doing enough for whistleblowers. 15...more
No financial services firm or professional welcomes an investigation by a regulator, let alone enforcement action. Each investigation proceeds differently depending on the target of the investigation, the subject matter and...more
Key Points -
The UK’s prudential and banking regulator has published a Consultation Paper proposing changes to its enforcement policies and procedures. The consultation runs until 4 August 2023.
...more
In September 2021, following the London Capital & Finance ‘mini-bonds’ scandal, the Treasury Select Committee of the UK House of Commons asked for a more “proactive” Financial Conduct Authority (FCA) that is “decisive” in its...more
Key Point -
The FCA is introducing a new Principle for Businesses, namely Principle 12: “A firm must act to deliver good outcomes for retail customers.” Firms will need to assess and evidence how they are acting to...more
Key Points -
The SEC and the FCA each publish annual reports, which can offer a useful insight into their enforcement actions.
The data in the reports only represents a snapshot of the regulators’ activities, but is...more
On 7 April 2022 the Financial Conduct Authority (FCA) released a three-year strategy for 2022-2025(the “Strategy”), setting out how the FCA aims to improve outcomes for UK consumers and markets. This was released alongside...more
The SFDR and the Taxonomy Regulation: Key Developments and What Firms Can Expect in the Coming Year -
Almost a year on from the date on which the European Union’s Sustainable Finance Disclosure Regulation (SFDR) came into...more
1/27/2022
/ Climate Change ,
Corporate Governance ,
Disclosure Requirements ,
Discussion Draft ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Reporting ,
Product Labels ,
SFDR ,
Sustainability ,
Sustainable Business Practices ,
Sustainable Finance ,
Task Force on Climate-related Financial Disclosures (TCFD) ,
UK