UK Financial Conduct Authority Issues Final Rules Concerning Whistleblowers

On October 6, 2015, the UK Financial Conduct Authority ("FCA") issued final rules formalizing whistleblower procedures to be implemented by certain banks, building societies, credit unions, investment firms, and insurance and reinsurance companies.¹ While the FCA's final rules do not go as far as those promulgated by the U.S. Securities and Exchange Commission, which provide for whistleblower bounties in certain successful cases, they are consistent with a global trend to encourage whistleblowers and look harshly on employers who would appear to engage in retaliation. And although the final rules are officially binding for only a subset of UK financial institutions, the FCA has made clear it considers them best practices for all UK regulated entities.² Importantly for U.S. and Asian banks, the FCA is currently considering whether it will apply these rules to UK branches of overseas banks.³ As a result, financial institutions that fall under the FCA's regulatory regime