FCA Enforcement: The Landscape After FX

This briefing discusses the new approach of the UK's regulator, the FCA, to regulatory enforcement of wholesale markets, as revealed by the recent settlements between the agency and five banks relating to FX manipulation. These are the largest regulatory settlements in UK history, a total of £1.1 billion (or $1.72 billion), the largest slice of a $4.3 billion total figure across four international regulators. The size of the penalties, and, perhaps more importantly, the FCA's methodology in arriving at the final figures, should be of real concern for UK-regulated entities.

The bottom line is that there is now very little room for error in compliance, especially in relation to contributing to benchmarks or other conduct affecting wholesale markets.