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UK financial regulation: FCA enforcement roundup Winter 2026—Nationwide AML fine, insider dealing, first data protection prosecution, Tribunal/Court disclosure rulings, cryptoasset regime proposals, and non‑financial misconduct guidance

Published on: 19 February 2026

Published by a LexisNexis Financial Services expert
Legal News
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Introduction by Guy Wilkes, partner and Lexis+ Consulting Editorial Board member

Welcome to Mishcon de Reya’s Enforcement Watch, our triannual survey of enforcement activity and what lies ahead. Over the past four months, the FCA has flexed its enforcement muscle. The standout case: a £44 million fine for Nationwide over AML systems failings. Familiar issues, yet a sanction that spotlights supervisory priorities. Once more, the FCA applied a proportionality adjustment without explaining its method. The regulator is also broadening use of criminal powers, achieving its first data protection prosecution while sustaining pressure on insider dealing. Two notable disclosure rulings – on cross‑border confidentiality duties and collateral use of materials in Tribunal proceedings – carry significant implications for firms under scrutiny. Looking forward, the FCA’s December plans for comprehensive cryptoasset rules (effective 2027) signal a fundamental shift, and final guidance on non‑financial misconduct prompts the question: will it in practice change enforcement? In this edition, we explore these developments and more, providing essential analysis for regulated firms navigating an evolving landscape.

FCA intensifies insider dealing enforcement

Guy Wilkes and Molly Vann

The FCA has stepped up its pursuit of insider dealing, with a spate of enforcement actions concluding in late period...

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