We have seen some noteworthy enforcement cases in recent months. The most interesting of the crop looks like the Upper Tribunal grappling with the Macris test on identification.
As to the future, what with Andrew Green's report into FSA enforcement failures following HBOS, and the FCA telling us what it thinks of privilege claims in internal investigations, the enforcement landscape may be changing. And when you put all this in the context of an SMR regime about to go live, we live in interesting times.
We hope you find this issue useful.
With thanks to the Enforcement Watch team.