Shifting geopolitical dynamics have seen a wave of changes across the international investigations and enforcement landscape. In this edition, we focus on some of the most significant of these changes – from the issue of new cooperation guidelines by the Serious Fraud Office (SFO) to the abandonment by the Financial Conduct Authority (
Joe Smallshaw
Supreme Court publishes its judgment in the Hopcraft case
Today marks a significant milestone for the motor finance sector as the Supreme Court has handed down its much-anticipated judgment in the Hopcraft case.
In a landmark decision, the Supreme Court has found that fiduciary duties are not to be found where the intermediary has an independent commercial interest. Whilst this decision will come as…
Financial crime controls in the spotlight – lessons learned in relation to FCA supervisory powers and expectations
The FCA’s recent publication of a Final Notice in respect of Monzo Bank Limited (the Firm) provides a number of key takeaways for regulated firms in relation to FCA supervisory powers and expectations with respect to financial crime frameworks. A summary of these is set out below but for more detail on the Final…
Global Regulation Tomorrow Plus: Non-Financial Misconduct: New rules & guidance from the FCA’s Consultation Paper 25/18
In the latest episode of Global Regulation Tomorrow Plus we discuss the Financial Conduct Authority’s (FCA) expansion of the Conduct Rules (COCON) to non-banks, the evolving expectations around workplace culture, and the practical implications for firms’ policies and procedures including some next steps that firms should be considering.
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New FCA Conduct Rule and Consultation on Non-Financial Misconduct Guidance
- a Policy Statement regarding a change to its Code of Conduct (COCON); and
- a Consultation on additional guidance in the COCON and the Fit and
Latest whistleblowing data: FCA Prescribed Persons Annual Report 2024/25
Whistleblowing continues to provide a vital role in uncovering wrongdoing in the financial services sector. The latest FCA development in this area is its Prescribed Persons Annual Report 2024/25, which was published on 24 June 2025. This report contains an update on the FCA’s whistleblowing data, as well as a summary of the FCA’s…
FCA updates its Enforcement Guide
The Financial Conduct Authority (FCA) has published the updated version of its Enforcement Guide (now to be known under the new acronym ENFG, in place of the old ENF), which came into force on 3 June 2025. It has implemented the bulk of its proposed changes to streamline its enforcement guidance, although…
FTPF: Considerations for In-house Lawyers
The new failure to prevent fraud (FtPF) offence, which will come into effect on 1 September 2025, poses some potential challenges for an in-house legal team (Legal Team) including anticipating and mitigating associated risks such as:
(1) the risk that a member of the Legal Team commits an underlying fraud offence…
New briefing note: Spotlight on Solicitors Regulation Authority (SRA) Guidance – Part one, reporting misconduct and conducting internal investigations
Our latest briefing forms part of a new series looking in detail at the SRA’s guidance for in-house teams, issued following a thematic review of the sector, recognising the growth and importance of the in-house role and the unique pressures to which in-house solicitors can be subject. The guidance covers six topics and does not…
FCA drops ‘name and shame’ and D&I proposals: key takeaways for firms
- to implement a new public interest test for announcing investigations into regulated firms (known as the ‘name and shame’