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ARTICLE · 24 SEPTEMBER 2025

Non-Financial Misconduct: Navigating The Emerging Divergence Between The U.S. And U.K.

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On 2 July 2025, the UK Financial Conduct Authority (FCA) published its latest non-financial misconduct (NFM) policy statement1, which clarifies that bullying, harassment and violence qualify as misconduct under the FCA's Code...

United StatesFinance and Banking
Michelle Nicole Diamond
Michelle Nicole Diamond
Imogen Makin
Imogen Makin
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This blog post was first published by Law360 on September 17, 2025.

On 2 July 2025, the UK Financial Conduct Authority (FCA) published its latest non-financial misconduct (NFM) policy statement1, which clarifies that bullying, harassment and violence qualify as misconduct under the FCA's Code of Conduct rules and will apply to almost all financial services firms operating in the U.K. from 1 September 2026. The announcement comes amid a recent surge of high-profile workplace misconduct cases on both sides of the Atlantic, highlighting a growing transatlantic divergence between the legislative, political and regulatory approach to non-financial misconduct (NFM) in the U.S. and U.K. This trend appears likely to continue.

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