Here are four items of interest for regulatory investigations lawyers from the newly published Regulatory Initiatives Grid (RIG), two to look forward to before summer and two for the second half of the year:

  1. ‘Name and shame’ proposal: The new RIG reflects the FCA’s 11 March 2025 letter to the Treasury Select Committee confirming they will not take forward the proposal to shift from an exceptional circumstances test to a public interest test for announcing investigations into regulated firms; but will take forward other aspects of their proposals including reactively confirming investigations already in the public domain; notifications focussed on activities potentially outside the regulatory perimeter; and more detailed anonymised information on issues under investigation. A ‘key milestone’ is planned for Q2 (i.e. by end of June 2025). 
  1. Non-financial misconduct: The FCA reiterates its continued prioritisation of work to tackle non-financial misconduct so that all regulated firms are subject to the same standards. In order to align with changes to legislation they are taking some further time to get this right and will set out next steps by the end of June 2025.
  1. Redress Guidance: In last year’s update to the RIG, the FCA said that it was planning to publish a Consultation Paper (CP) in Q1 on proposed rules and guidance relating to expectations of firms identifying and conducting firm led redress exercises. The new RIG references the joint call for input it published with the FOS in November 2024 seeking views on how to modernise the redress system with a deadline for responses of 30 January 2025 and indicates that the FCA now intends to issue a CP on any proposed changes in H2 2025 (i.e. by the end of the year).   
  1. Money Laundering: The Treasury is developing a package of changes to the MLRs 2017 in response to the 2024 consultation on improving their effectiveness (which closed on 9 June 2024). The consultation included consideration of strengthening coordination through, for example, information sharing by supervisors on risks and threats; clarifying how regulated firms should complete and use risk assessments; and also reviewing the role of the Trust Registration Service including in the investigation of money laundering and terrorist financing.  The RIG indicates that the Government will bring forward a package of changes to the MLRs “in 2025” and that a “key milestone” is planned for Q4 (i.e. between October and the end of the year). 

We are closely following these topics and will continue to keep an eye on developments including the key milestones flagged. For further information on the Grid please see here.