Trust and reputation

TheCityUK response to the FCA’s proposal on enforcement investigations approach

29 April 2024
3 minutes
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Our response to FCA CP24/2 ‘Our Enforcement Guide and publicising enforcement investigations – a new approach’

  • TheCityUK acknowledges the importance of enforcement in the FCA's role of consumer protection, but questions the efficacy of the proposals in CP24/2 in advancing this objective.
  • The proposals do not support the FCA's primary goals of protecting the financial system's integrity and promoting effective competition.
  • The proposals are not proportionate and do not align with the FCA’s new secondary objective concerning international competitiveness, diverging from approaches in other leading financial centres.
  • Implementation risks damaging the UK’s international competitiveness and diminishing its appeal as a business and investment destination, which could stifle industry growth and the broader economy.
  • The proposals could harm businesses under investigation, who are entitled to the presumption of innocence, without demonstrating clear, outweighing benefits.
  • A stronger deterrent effect could be achieved by the FCA announcing investigations into specific misconduct types without naming firms or individuals.