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Enforcement Watch Roundup

Issue 50: October 2026

Enforcement Watch Roundup

Editor's note

Guy Wilkes

Fifty editions ago, Enforcement Watch launched with a youthful Adam Epstein as editor, declaring, "At various times, I have heard regulators talk about getting tough. Now for the first time we are seeing them act on their rhetoric," reporting a then-record £2.8m individual fine and the beginnings of what became Operation Tabernula. It is a mark of how far the landscape has moved that this edition finds us discussing commitments decisions, non-financial misconduct, and immigration-adjacent fraud, rather than the FSA's first tentative fines. 

Elsewhere in this issue we look back across all fifty editions, tracing enforcement's journey from the birth of the Twin Peaks regime and LIBOR, through the Tribunal's increasingly pointed criticism of FCA decision-making, to today's faster-paced enforcement under Therese Chambers and Steve Smart, and, in a companion piece, the four themes we see recurring throughout: the calculation and justification of financial penalties, the regulator's approach to publicity, the rise of individual accountability, and a broader redefinition of what enforcement is for. 

To celebrate this 50th edition we are holding a stellar live event on 15 October 2026 at the Royal College of Surgeons in London, hosted by Adam Epstein, where Tracey McDermott CBE, Tim Herrington, Javan Herberg KC and myself will be examining and dissecting the key enforcement highlights of the previous 16 years. 

News
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Fifty issues of Enforcement Watch

Marking its 50th edition, Enforcement Watch reviews FCA enforcement trends, landmark cases, regulatory shifts and the evolving landscape of financial crime.

News
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Examining the Upper Tribunal's decision in Odey v FCA

The Upper Tribunal upheld the FCA's decision to ban Crispin Odey from the financial services industry, finding that he lacked integrity by removing OAM executive committees that were investigating his conduct.

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