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Enforcement Watch Roundup

Issue 40: May 2023

Enforcement Watch Roundup

Editor's Note

Adam Epstein - Mishcon de Reya

Whilst the first senior manager outcome under the SMCR regime is interesting, what may be more interesting for enforcement watchers is what is to come.

Read the full note

Enforcement Highlights


First SMCR fine imposed for failed IT migration in 2018

On 13 April 2023, the Prudential Regulation Authority (PRA) imposed a financial penalty of £116,000 on Carlos Abarca, TSB Bank's former Chief Information Officer (CIO), for his failures overseeing the IT migration in 2018. This led to disruption for millions of the Bank's customers and ongoing disruption to the Bank's 550 branches.

On the Horizon

Abstract glass building

FCA issues warning to payment firms

The FCA sent a Dear CEO Letter dated 16 March 2023 to CEOs of payment firms (broadly meaning firms registered under the Payment Services Regulations and the Electronic Money Regulations). It requires firms to take appropriate action to deliver three fundamental outcomes.


What the new FCA Business Plan means for enforcement

On 5 April 2023, the FCA published its Business Plan for 2023/2024, setting out how it will continue to deliver its Strategy. The Strategy, published last year, identified three themes where the regulator would strengthen its focus


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