The wheels of justice turn slowly, but grind exceedingly
fine, goes the old saying. At least one part of that is true. Cases
dating back to the financial crisis are only now, a decade on,
finally over; cases relating to benchmark manipulation are largely
complete, but some still drag on. Criminal trials are
on-going.
The regulatory pipeline is long. As such, the best guide for the
enforcement action we will be discussing in two or three
years’ time are the cases already beginning or in progress
today. As we note elsewhere in this report (see John Byrne’s
article: Knowing the Rules), regulatory notices, announcements and
speeches all offer powerful clues as to the big issues of tomorrow
for enforcement, too. Already in the first half of 2018, we see
some consistent trends with previous years in the areas of actions
against firms for failings relating to firm management (corporate
governance), AML, regulatory reporting and conduct of business such
as mis-selling and
