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Financial Conduct Authority (FCA) Corporate Misconduct

WilmerHale

New FCA Rules on Non-Financial Misconduct

WilmerHale on

Last week, the FCA published its long-awaited policy statement containing amendments to the FCA’s Code of Conduct (“COCON”) aimed at combatting non-financial misconduct (“NFM”). NFM can amount to a breach of FCA rules in any...more

Goodwin

FCA Non-Financial Misconduct Rules: Private Fund Managers, Fintechs, and Other Non-Banks Firmly in Scope

Goodwin on

In a previous alert, “FCA D&I Standards for Large Firms Abandoned (for now), Non-financial Misconduct Rules Delayed (but Still Important),” we discussed the proposals put forward by the UK Financial Conduct Authority (FCA)...more

BCLP

The Long-Awaited FCA Paper on Non-financial Misconduct – Was It Worth the Wait?

BCLP on

On 2 July 2025, the FCA published a further consultation paper on “tackling non-financial misconduct in financial services”. The industry has been eagerly awaiting publication of this paper, in the hope that it will address...more

BCLP

FCA Draft Guidance on Non-financial Misconduct Published Today

BCLP on

The Financial Conduct Authority (FCA) has published its most recent paper on non-financial misconduct (NFM), clarifying its expectations on bullying and harassment in financial services....more

Latham & Watkins LLP

FCA Sets Out Next Steps on Its Approach to Non-Financial Misconduct

Latham & Watkins LLP on

On 2 July 2025, the FCA published its long-awaited proposed next steps on addressing non-financial misconduct (NFM) in financial services. In a joint Consultation Paper and Policy Statement (CP25/18), the regulator is...more

BCLP

Upper Tribunal Ruling in the Case of Craig Donaldson and David Arden (Metro Bank)

BCLP on

The Upper Tribunal has upheld the FCA’s decision that the CEO and CFO of Metro Bank were knowingly concerned in the Bank’s breach of the Listing Rules....more

A&O Shearman

Proposed action against Crispin Odey: A different approach to tackling non-financial misconduct

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published the full details of its proposal to fine and ban the fund manager, Crispin Odey, for lacking integrity. But the FCA’s proposed action against Mr Odey does not rely on his...more

Goodwin

FCA D&I Standards for Large Firms Abandoned (for now), Non-financial Misconduct Rules Delayed (but Still Important)

Goodwin on

In a previous alert, we discussed the proposals put forward by the UK Financial Conduct Authority (FCA) for all FCA-authorised firms to better integrate non-financial misconduct (NFM) considerations into their senior manager...more

Proskauer - Regulatory & Compliance

UK Financial Regulators Drop Diversity and Inclusion Rules but Keep Culture in Focus

On 11 March 2025, the UK’s financial regulators confirmed they have decided not to move forward with proposed diversity and inclusion (D&I) rules for financial firms. This decision in a letter by the Financial Conduct...more

Latham & Watkins LLP

FCA and PRA Announce Intention to Drop Reform Proposals

Latham & Watkins LLP on

The regulators have said they will not pursue their proposals on announcing enforcement investigations and on D&I. On 12 March 2025, the FCA and PRA made important announcements regarding the long-awaited outcomes on certain...more

Goodwin

Non-financial Misconduct and Culture: A Reminder for FCA-Regulated Firms in the UK

Goodwin on

Firm culture remains a key topic on the Financial Conduct Authority’s (FCA’s) radar this year. In a previous alert, we discussed the FCA’s proposals for all FCA-authorised firms to better integrate non-financial misconduct...more

Cadwalader, Wickersham & Taft LLP

New Whistleblower Reward Schemes Would Dramatically Increase Enforcement Risk for UK Corporates and Regulated Firms

Quick read - It is all but inevitable that UK enforcement agencies will start paying for information about organisational misconduct.  In the US, whistleblower reward schemes have generated tens of billions of dollars in...more

BCLP

Regulatory Focus on Non-Financial Misconduct: Where are we headed in 2025?

BCLP on

The FCA’s focus, in the six years since #MeToo began, upon tackling ‘non-financial misconduct’ (broadly, poor interpersonal behaviour) in the financial services sector has sometimes been said to be a bit odd and/or not the...more

A&O Shearman

The FCA's non-financial misconduct survey: decoding the findings

A&O Shearman on

In February 2024, the FCA sent a survey to 1,028 wholesale firms (insurers, market intermediaries, banks and brokers) asking about recorded incidents of non-financial misconduct between 2021 and 2023. With a 96% response...more

WilmerHale

FCA Survey Results Reveal Rise In Nonfinancial Misconduct

WilmerHale on

Make no mistake, nonfinancial misconduct remains at the top of the Financial Conduct Authority's agenda. Originally published in Law360 - November 26, 2024....more

A&O Shearman

UK Financial Conduct Authority Publishes the Findings of Its Culture and Non-Financial Misconduct Survey

A&O Shearman on

The U.K. Financial Conduct Authority has published the findings from its non-financial misconduct survey. The survey, sent to 1,028 wholesale banks, brokers and insurance firms in February, aimed to examine how firms detect...more

Latham & Watkins LLP

FCA Publishes Results of Non-Financial Misconduct Survey

Latham & Watkins LLP on

The data provides important insights to assist firms with their ongoing work in this area. On 25 October 2024, the FCA published the results of a survey on non-financial misconduct it undertook earlier in the year...more

Cohen & Gresser LLP

UK Options for Whistleblower Financial Incentive Programmes in Economic Crime Investigations

Cohen & Gresser LLP on

On 13th February 2024, in a wide-ranging speech, the Director of the UK Serious Fraud Office (SFO), Nick Ephgrave, publicly stated his provisional support for financial incentives to whistleblowers in allegations of...more

American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more

Mayer Brown

The insurance sector responds to the FCA's non-financial misconduct survey

Mayer Brown on

Last week, firms in the insurance sector submitted their responses to the recent survey issued by the Financial Conduct Authority ('FCA') into non-financial misconduct....more

WilmerHale

Toxic Culture Review: FCA Statutory Demand for Non-Financial Misconduct Data

WilmerHale on

“The wholesale insurance market in particular has a long way to go in having an inclusive culture...areas for improvement include...preventing and handling non-financial misconduct,” stated the Financial Conduct Authority...more

Akin Gump Strauss Hauer & Feld LLP

FCA and PRA Publish Consultation on New Rules relating to Non-Financial Misconduct

Key Points - Following a joint Discussion Paper in 2021 issued by the FCA and the PRA, both regulators have now issued Consultation Papers proposing new rules and guidance in relation to diversity and inclusion in the...more

Ankura

Non-Financial Misconduct: Will The Crispin Odey Case Reshape Investigations Into Behavioral Misconduct for the Financial Services...

Ankura on

It has been a summer of revelations leaving the financial services sector facing uncertainty and increased scrutiny on how allegations of behavioral misconduct might be managed going forward. This came after multiple...more

Latham & Watkins LLP

The FCA’s Approach to Non-Financial Misconduct - Latest Cases and Observations

Latham & Watkins LLP on

The FCA has long since regarded non-financial misconduct as potentially relevant to the integrity and reputation elements of a regulated individual’s fitness and propriety. While not formally defined, non-financial misconduct...more

Proskauer Rose LLP

SMCR – Top Priorities for 2020/21

Proskauer Rose LLP on

Originally published on February 24, 2020. Updated as of July 1, 2020. The UK senior managers and certification regime ("SMCR") overhauled the accountability regime for individuals working in UK financial services firms...more

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