In a recent speech, FCA Director of Enforcement and Market Oversight Mark Steward again made clear that the FCA is prepared to use its power to bring criminal proceedings for breaches of anti-money laundering (AML) obligations set out under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). Mr Steward stated that it was time for the FCA to give ‘effect to the full intention of the…

In this on-demand webinar, members of our Regulatory, Compliance and Investigations team in London, France, the US and Hong Kong give their thoughts on likely regulatory enforcement and sanctions trends for the rest of this year based on recent enforcement cases and forward looking statements from the regulators. Topics discussed include individual accountability, anti-money laundering and cybersecurity. To access the webinar, please click the below link and enter your details when requested.   https://event.on24.com/wcc/r/1900629/CE0C95915E3A7CF20DB873DC36966D7B…

On 1 April 2019, the FCA announced that there will be an independent investigation into the failure of London Capital & Finance (LC&F). The FCA stated that the investigation should cover: whether the existing regulatory system adequately protects retail purchasers of mini-bonds from unacceptable levels of harm; and the FCA’s supervision of LC&F. LC&F was the issuer of mini-bonds which it stated it used to make loans to corporate borrowers to provide capital for further…

The Financial Conduct Authority (FCA) has fined a multinational investment bank and financial services company (the Firm) £27,599,400 for failing to ensure it provided complete and accurate information to approximately 86 million reportable transactions and erroneously reporting 49 million transactions to the FCA. The Final Notice states that over a period of more than nine years, the Firm made 135 million errors in transaction reporting, which was in breach of FCA rules. The FCA found…

On 21 February 2019, the FCA fined two asset management firms for breach of competition law.  No fine was imposed on the other asset management firm, Newton Investment Management Limited (Newton), as it had been given immunity under the competition leniency programme.  This decision followed the FCA’s announcement on 4 February 2019 that it had fined Paul Stephany, a former fund manager at Newton, £32,200 for his conduct in relation to an Initial Public Offering…

On 18 February 2019, the UK’s Information Commissioner’s Office and FCA published an updated memorandum of understanding setting out the terms of the relationship between them, including the exchange of information in relation to potential failures of systems and controls in relation to data security and related investigations. The MOU comes in the context of the FCA’s increased focus on and enforcement of data protection and cyber security issues and follows the ICO and FCA’s…

On 21 January 2019, the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, issued a £5,000 fine against R. Raphael Bank & Sons plc, trading as Raphaels Bank, for dealing with £200 belonging to an unidentified designated person in violation of EU sanctions against Egypt (implemented in the UK under the Egypt (Asset-Freezing) Regulations 2011). This is the first civil monetary penalty imposed by OFSI using its new powers under Part 8 of…