On 3 June 2025, the FCA published a policy statement (PS25/5)
containing a new version of its Enforcement Guide. This follows its
earlier consultation on the subject conducted in two parts in
February and November 2024 (CP 24/2). This article contains a
summary of the key changes the FCA has made in the new guide, which
will now be referred to as ‘ENFG' rather than
‘EG'. The new ENFG came into force on 3 June 2025 for
investigations starting on or after that date.
Publication of the new ENFG concludes a process which the FCA
began in February 2024, which from its perspective was designed to
make its enforcement actions more transparent and quicker to
resolve. Aspects of the FCA's earlier proposals, particularly
the proposed ‘naming and shaming' of firms, were highly
controversial and widely reported in the media. Our previous AG
Insights articles on the consultations can be found
here and
here. As expected, the most radical of the changes that the FCA
originally
