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Enforcement Watch Roundup

Issue 47: October 2025

Enforcement Watch Roundup

Editor's note

Guy Wilkes - Mishcon de Reya
Guy Wilkes, Partner

It's been a very active few months for the FCA both in terms of settled disciplinary cases and successes in the Upper Tribunal. The highlight, certainly measured in terms of media coverage was the Upper Tribunal decision against Jes Staley former CEO of Barclays Bank. At one level the outcome was perhaps inevitable, Mr Staley was found to have mislead the FCA - like in the case of the H2O former CEO Lars Windhorst. However the circumstances of Staley are very unusual, his misleading statements were in response to queries from the FCA about his relationship with Jeffrey Epstein. This raised the question: without any evidence of wrongdoing, should the FCA really be diving into such personal territory?

In the latest edition of Enforcement Watch, we cover more in this same vein, including essential reading on the Tribunal cases of Lopez, Staley and Donaldson for anyone engaging in penalty negotiations with the FCA, analysis of its key focus on AML with one case against Barclays being settled only 3 months after commencement, and the FCA's current trend of using criminal powers - such as in the case of confiscation proceedings against convicted fraudsters, Oxford and much more.

News
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Upper Tribunal moderates the FCA’s enthusiasm for high fines

The Financial Conduct Authority (FCA) has enjoyed a string of successes in the Upper Tribunal during this Enforcement Watch period. However, in every case where the FCA has prevailed, the Tribunal has imposed lower penalties than those originally decided by the FCA.

News
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FCA confiscates just under £300,000 from convicted fraudsters

On 5 August 2025, the FCA secured a further confiscation order in respect of a fourth defendant, Reuben Akpojaro, in connection with an investment fraud. Following the earlier confiscation orders obtained on 14 May 2025 against Raheel Mirza, Cameron Vickers and Opeyemi Solaja, the orders now total £293,726.16.

News
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Upper Tribunal upholds FCA's prohibition against Jes Staley

On 26 June 2025, the Upper Tribunal upheld the Financial Conduct Authority's ("FCA") decision to prohibit ex-Barclays CEO James (Jes) Staley from performing any senior management or significant influence function in relation to any regulated person pursuant to s56 of the Financial Services and Markets Act 2000 ("FSMA").

News
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How clean is the market, according to the FCA?

The Financial Conduct Authority (FCA) has recently published its latest Market Cleanliness (MC) report for the UK equity market. The report looks at the level of abnormal movement in share price 48 hours before a takeover announcement. The statistics produced are one of the tools the FCA uses to monitor activity that might be insider dealing.

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