Enforcement Watch Roundup

Editor's note

Welcome to Mishcon de Reya's Enforcement Watch, your ultimate destination for the freshest insights and analysis on PRA and FCA regulatory enforcement. This edition is extra special as we celebrate the 15th anniversary of Enforcement Watch. For a decade and a half, we've been your trusted guide through the ever-changing regulatory landscape. Today, we're thrilled to embark on a new journey with me, Guy Wilkes, taking the editorial helm from my esteemed colleague, Adam Epstein.

Read the full note

Enforcement highlights

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a pen on a table in a conference room with people talking in the background

SRA takes action against BNP Paribas lawyer for the use of offensive language and nicknames – what does the case mean for FCA enforcement?

The Solicitors Regulation Authority (SRA) has ordered Benedict Foster, the former head of legal for debt and equity capital markets at BNP Paribas, to pay £31,000 following a hearing in the Solicitors Disciplinary Tribunal. During his tenure at BNP Paribas between December 2020 and September 2021, Foster was found to have regularly used offensive, inappropriate and sometimes racist nicknames in the office environment when referring to his colleagues.

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Examining the FCA's Decision Notice against Crispin Odey

On 17 March 2025, the Financial Conduct Authority ('FCA') published a Decision Notice against Robin Crispin Odey, the founder of Odey Asset Management LLP ('OAM'), imposing a fine of £1,835,200 and prohibiting him from performing regulated activities in the financial services industry.

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FCA imposes £9.2 million fine on London Metal Exchange for market disorder

On 19 March 2025, the Financial Conduct Authority (FCA) issued the London Metal Exchange (LME) with a Final Notice, imposing a financial penalty of £9,245,900 following the LME's failure to maintain orderly trading during a period of extreme market stress in March 2022, particularly concerning the three month nickel futures contract.

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PRA imposes £72,000 fine on a former Notified Non-Executive Director

On 2 April 2025, the Prudential Regulation Authority (PRA) imposed a financial penalty of £72,000 on George Jay Hambro, a former Notified Non-Executive Director (NED) of Wyelands Bank Plc (Wyelands) for breaching Individual Conduct Rule 2, which requires individuals to act with "due skill, care and diligence".

On the horizon

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Retiring the Payment Systems Regulator

On 11 March 2025, the Government announced that the Payment Systems Regulator (PSR) will be abolished as part of a wider plan to reduce regulatory burden on businesses and drive economic growth in the UK.

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The FCA's increased focus on financial crime

In recent years, financial crime has climbed to the top of the Financial Conduct Authority's (FCA) agenda. The FCA has implemented a series of measures aimed at strengthening the integrity of financial markets and protecting consumers. The FCA's new five year strategy, prioritises fighting financial crime and is expected to increase enforcement actions, as the regulator seeks to deter misconduct and ensure compliance.

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The FCA's agenda to combat market abuse

On 28 April 2025, Therese Chambers, the Joint Executive Director of Enforcement and Market Oversight at the FCA, delivered a speech, outlining the FCA's strategic approach to tackling market abuse. She emphasised the "three Ps": being predictable, proportionate, and purposeful, and how the FCA's work on market abuse permeates all areas of the FCA's recently launched five year strategy.

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