Jurisdiction(s):
United Kingdom

UK FCA enforcement: 2025 outlook—early interventions, selective investigation announcements, rising Section 166 reviews, and intensified focus on financial crime

Published on: 19 December 2024

Published by a Law360 reporter

Legal News

Article summary

2024 burst into life, as the FCA signalled in February 2024 a significant policy shift to identify publicly, at an earlier stage, firms under enforcement inquiry, and to run swifter, more streamlined investigations, alongside other measures. The FCA’s notice of a consultation on enhancing transparency around enforcement work provoked public outcry from practitioners and, unusually, from politicians alike. Answering broad criticism, on 28 November 2024 the FCA then issued a second part to the consultation. This substantially reworked the proposals in substance, making clear that, if implemented in practice, only a very limited number of extra proactive announcements would be made when set against the existing current approach to publicity and announcements. The FCA has clearly pivoted to earlier intervention and to deploying tools short of formal enforcement probes. Many in practice observe what amounts to a clearing of the decks, as the FCA closes older matters opened under the previous enforcement chief without initiating a comparable volume of fresh cases in number or scope. The FCA has also placed growing emphasis on data and analytics to intervene much sooner and so avert harm. On subject matter, however, the FCA’s priorities have, as expected, largely stayed overall constant; the...

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