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ARTICLE · 14 OCTOBER 2024

Conflicts Of Interest: Recent UK Action

Hogan Lovells Cadwalader
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The UK Financial Conduct Authority's (FCA) recent Court of Appeal victory emphasizes the importance of robust conflicts of interest policies, requiring firms to ensure effective conflict mitigation measures and provide clients with clear disclosures.

United KingdomFinance and Banking
Alix Prentice
Alix Prentice
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The UK's Financial Conduct Authority ("FCA") has recently successfully applied to the Court of Appeal to uphold an earlier decision to impose requirements for redress in relation to conflicts of interest. This decision serves as a timely reminder to firms to review, and if necessary refresh, conflicts of interest policies and procedures. 

Regulatory Background

Principle 8 of the FCA's Principles for Business requires that a firm must manage conflicts of interest fairly, between itself and its customers and between a customer and another client. Firms are obliged to take all reasonable steps to identify conflicts and have effective organisational arrangements that are aimed at preventing conflicts from constituting or giving rise to a material risk of damage to the interests of clients. When those arrangements are not sufficient to ensure, with a reasonable degree of confidence, that the risks can be prevented, firms must give sufficient disclosure to their clients.

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