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ARTICLE · 24 DECEMBER 2024

What FCA's 2024 Changes Suggest For Enforcement In 2025

WilmerHale
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The FCA is shifting toward early intervention and increased use of data-driven methods, while maintaining focus on financial crime and exploring controversial policy changes on transparency. Firms must enhance compliance to mitigate scrutiny.

United KingdomFinance and Banking
Imogen Makin
Imogen Makin
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"The FCA's approach to enforcement is changing." So stated Therese Chambers, joint executive director of enforcement and market oversight at the Financial Conduct Authority, speaking in September to the Association for Financial Markets in Europe's Annual European Compliance and Legal Conference in London.1 Over the last year, we have already seen change at the FCA, and apparently, more is to come.

The year started with a bang, with the FCA announcing in February a potential policy change involving the early and public naming of entities under enforcement investigations, and quicker, more efficient investigations, among other proposals.2

The FCA's announcement of its consultation on greater transparency of enforcement investigations was met with uproar from both practitioners and, unusually, politicians. In response to widespread criticism, on Nov. 28 the FCA published part two of the consultation. This significantly amended the proposals, clarifying that if the

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