Enforcement Watch

Enforcement Watch

Issue 23
Adam Epstein

Editor's Note

This edition highlights some real variety in the last 4 months of enforcement related activity and news. At one end, we consider some culture-focussed developments. At the other, we examine the implications on enforcement of a US appeal judgment. And the period is bookended by two significant speeches that send messages on the FCA's future approach to enforcement, one speech on investigations and the other on enforcement trends. We hope you find this edition interesting.

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Enforcement Case Highlights

10 July 2017: FCA fines compliance officer in respect of pensions transfers and re-iterates its pensions focus - read more

19 July 2017: How a US determination could cause headaches for the FCA and PRA - read more

8 August 2017: The Upper Tribunal Fines and Imposes a SIF Ban on Charles Palmer - read more

On the Horizon

Symington Outlines the FCA's Approach to Investigations - read more

Banking Standards Board consults on guidance for SMCR certification processes - read more

FCA consults on roll-out of SMCR to all authorised firms - read more

Consumer credit firms and complaints handling – are there problems down the line? - read more

Mark Steward speech reflects on FCA enforcement trends - read more

FCA fines compliance officer in respect of pensions transfers and re-iterates its pensions focus

FCA fines compliance officer in respect of pensions transfers and re-iterates its pensions focus

The FCA has fined David Samuel Watters £75,000 and removed his CF10 controlled function.

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How a US determination could cause headaches for the FCA and PRA

How a US determination could cause headaches for the FCA and PRA

The US Court of Appeals of the 2nd Circuit published a decision on 19 July 2017 that could potentially cause some real problems in relation to UK regulatory actions that have a US connection.

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The Upper Tribunal Fines and Imposes a SIF Ban on Charles Palmer

The Upper Tribunal fines and imposes a SIF ban on Charles Palmer

The Upper Tribunal has upheld an RDC decision to fine Mr Palmer £86,961 and to prohibit him from holding any Significant Influence Function (SIF).

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Symington Outlines the FCA's Approach to Investigations

Symington outlines the FCA's approach to investigations

On 15 June 2017, Jamie Symington (Director of Investigations at the Financial Conduct Authority) delivered a speech about the FCA's evolving approach to investigations.

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Banking Standards Board consults on guidance for SMCR certification processes

Banking Standards Board consults on guidance for SMCR certification processes

On 13 July 2017, the Banking Standards Board (BSB) published its consultation on guidance to help Banks navigate the process of certification under the Senior Management and Certification Regime (SMCR).

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FCA publishes its Business Plan

FCA consults on roll-out of SMCR to all authorised firms

As readers of this publication will be aware, the FCA has long planned to roll-out the Senior Managers and Certification Regime (SMCR) to all authorised firms (it currently just applies to Banks, certain investment firms and certain insurers).

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Deutsche Bank Libor/Euribor settlement includes substantial Principle 11 fine

Consumer credit firms and complaints handling – are there problems down the line?

The FCA has written to consumer credit firms a Dear CEO letter dated 13 September 2017 about complaints handling.

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Mark Steward speech reflects on FCA enforcement trends

Mark Steward speech reflects on FCA enforcement trends

In a speech on 20 September 2017, Mark Steward outlined some trends in FCA enforcement, and gave some indications about the future.

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