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Enforcement Watch Roundup

Issue 49: May 2026

Enforcement Watch Roundup

Editor's note

Guy Wilkes - Mishcon de Reya

It has been a busy few months for both the FCA and the PRA, with a string of significant enforcement decisions across regulated firms and individuals alike. The standout case is arguably the Upper Tribunal's ruling in the Banque Havilland case, where the Tribunal agreed the conduct was serious – rating it at the highest level – yet slashed the FCA's £10 million penalty by 60% on the basis that the original figure was "arbitrary" and inadequately reasoned. The decision will sharpen focus on the FCA's longstanding reluctance to show its workings when calculating fines, and may well encourage other firms to challenge penalties without conceding the merits.

In this edition, we cover more in the same vein, including analysis of the FCA's £12.9 million fine against John Wood Group for financial misstatement, the conclusion of the eight-year Carillion saga with a fine against its former CEO, two landmark PRA firsts –  the Bank of London case marking the PRA's first action for breach of Fundamental Rule 1, and the UK Insurance case as the inaugural use of the PRA's Early Account Scheme – the FCA's prohibition of Kasim Garipoglu following a decade-long AML investigation, and the Supreme Court's important clarification on principal firm liability in Kession Capital.

News
low angle view of a building
Former chief executive of Carillion plc drops legal challenge against the FCA's £237,000 fine

The former chief executive of Carillion plc, Richard Howson, has been fined £237,000 for his role in misleading statements being issued by Carillion and being knowingly concerned in breaches of Market Abuse Regulations and the Listing Rules by the company. This decision comes more than eight years after Carillion entered compulsory liquidation and further to Mr Howson's decision to withdraw his challenge to the FCA's findings.

News
a close up of a building
FCA fines John Wood Group PLC £12,993,700 for misleading financial reporting and control failures

On 3 March, the Financial Conduct Authority issued John Wood Group PLC ("Wood Group") with a Final Notice imposing a financial penalty of £12,993,700 for publishing inaccurate information in its financial results for FY22, FY23 and HY24. Wood Group agreed to resolve the matter and qualified for a 30% Stage 1 settlement discount; were it not for this discount, the penalty would have been £18,562,500.

News
A man looking out of a glass building over a city
"Aml is the most idotic [sic] thing I have ever heard in my business life" - FCA prohibits Kasim Garipoglu for lack of honesty and integrity

On 13 March, the Financial Conduct Authority issued a Final Notice, imposing a prohibition on Kasim Garipoglu, as a result of misconduct (in respect of the underlying conduct, and his subsequent engagement with the FCA) between April 2012 and December 2022. The Final Notice followed a reference by Mr Garipoglu to the Upper Tribunal and an appeal to the Court of Appeal, both of which were struck out. However, the FCA was not able to fine Mr Garipoglu due to the period that has elapsed since he was an approved person.

News
London banks at night
PRA fines The Bank of London for failing to act with integrity

On 24 March, the Prudential Regulation Authority, announced that it had imposed a £2million fine on the fintech, Bank of London, and its parent company, Oplyse Holdings, for a number of failings, including failing to conduct its business with integrity.

News
People standing at window in corporate building
Kession Capital v KVB Consultants: Principal Firm Responsibility for Appointed Representatives

On 1 April, the Supreme Court unanimously allowed the appeal in Kession Capital Ltd (in Liquidation) v KVB Consultants Ltd [2026] UKSC 11, overturning the Court of Appeal majority. The decision clarifies the scope of a principal firm's responsibility under section 39 of the Financial Services and Markets Act 2000 when its appointed representative acts outside the terms of its appointment.

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