On 8 June 2026, the Financial Conduct Authority (FCA) announced that it has commenced civil proceedings against Neil Woodford and W4.0, an investment strategy platform co-founded by Mr Woodford. It is alleged that they are providing regulated investment advice and making financial promotions through a subscription-based platform without authorisation, in breach of sections 19 and 21 of the Financial Services and Markets Act 2000 (FSMA). The FCA is seeking an injunction to stop the allegedly unlawful activities.
Background
Back in July 2025, the FCA issued a Decision Notice against Mr Woodford where he was fined £5,888,800 and banned from holding senior manager roles and managing funds for retail investors.
The FCA found that between July 2018 and June 2019, Mr Woodford and asset management firm Woodford Investment Management (WIM) made unreasonable and inappropriate investment decisions, disproportionately selling more liquid investments and buying less liquid ones. This meant that at the time of suspension, only 8% of the investments held by the fund managed by Mr Woodford could be sold within 7 days, against a regulatory requirement that investors should have been able to access their funds within 4 business days. The FCA further concluded that Mr Woodford held a defective and unreasonably narrow understanding of his responsibilities.
Both Mr Woodford and WIM have referred the Decision Notices to the Upper Tribunal (UT). The findings in the Decision Notices are therefore subject to the UT hearing.
What Mr Woodford Has Been Doing
Following the collapse of his fund management business, Mr Woodford established a new venture operating under the trading name W4.0, a company registered in the United Arab Emirates. Through this platform, Mr Woodford publishes investment-related content where members of the public, including UK readers, can access. These contents include podcasts, articles, short videos and newsletters.
The FCA alleges that, through this platform, Mr Woodford and W4.0 are providing regulated investment advice and making financial promotions, both of which require authorisation under FSMA. The FCA is of the view that the activity breaches the following sections of FSMA:
section 19: general prohibition on carrying on regulated activities without authorisation; and
section 21: restrictions on inviting or inducing another to engage in investment activity.
Comment
The line between providing regulated investment advice and simply sharing views or journalistic commentary can be difficult to draw. For a lot of practitioners, it can be challenging to provide clear guidance to clients as to where that boundary lies. The existing regulatory framework does not offer a clear and simple test, and the analysis is largely fact-sensitive.
Should the FCA's civil proceedings proceed to a full hearing, the case may provide welcome guidance for practitioners navigating this ambiguous area. A judicial determination as to what features would point towards a regulated advice would be helpful to both legal advisers and content creators.
It is also notable that W4.0 is based outside the UK. This is another example of the FCA showing a willingness to act against entities operating outside the UK but with activities directed at UK consumers. The FCA has been increasingly willing to take actions to protect retail investors from harm regardless of where the person or entity causing the harm is based. See for example our report on the FCA's action against global crypto exchange HTX. Firms and individuals based outside the UK but who have a UK consumer base should be cautious and take careful note.