This enforcement data shows the enforcement action we took in 2024/25 and it forms part of our Annual Report.
We have significantly increased the pace and focus of our enforcement work to deliver impactful deterrence. Five recent enforcement operations achieved a public outcome in under 16 months. The number of open enforcement operations fell from 188 as at 31 March 2024 to 130 as at 31 March 2025. At the same time, we issued 37 Final Notices, secured 5 criminal convictions, imposed fines of over £186m, cancelled the authorisation of 1,456 firms, and achieved 135 outcomes using our formal intervention tools.
It is important to hold firms and individuals to account when they cause significant harm to consumers or markets. It is also important to prevent wider misconduct. When taking enforcement action, we focus on achieving impactful deterrence aligned to our strategic priorities. As part of our 3-year strategy, we prioritised consumers’ needs, took strong action on market abuse and worked to reduce and prevent financial crime.
1. Spotting harm and taking early action
We are a data-led regulator, using tools to identify trends and signs of harm, and act quickly on these insights.
We record all external whistleblowing disclosures and refer them for assessment and action, if needed. Whistleblowing intelligence informs our work and can help us to prevent harm or non-compliance before it happens.
View our latest whistleblowing data[1].
Enforcement is crucial in the work of the cross-FCA Financial Promotions and Enforcement Taskforce (FPET). FPET issues warnings and alerts about firms conducting regulated activities without our authorisation. This includes issuing specific alerts to our Warning List[2]. We also refer potential investigations to other agencies, including the police.
2. Meeting our Threshold Conditions
Firms and individuals must meet minimum standards (Threshold Conditions for firms, and the Fit and Proper test for individuals) to remain authorised or approved by us. Meeting these basic standards is important to maintaining a regulated environment that consumers, investors, markets and the industry can trust.
We can cancel a firm's authorisation/registration or prohibit an individual where these standards are not met. Most Threshold Conditions cases relate to firms rather than individuals. Types of cases include when a firm has failed to:
- Submit a Directory Persons Attestation[3] (Directory Person) (to confirm that data regarding individuals maintained on the Financial Services Register is complete and correct).
- Submit a Firm Details Attestation[4] (FDA) (to confirm that data regarding firms maintained on the Financial Services Register is complete and correct).
- Pay its annual fee and the collections process has been exhausted (Fee).
- Submit a Regulatory Return (Returns).
- Carry on regulated activity related to the permissions it holds (Use it or lose it or UIOLI).
If a firm has multiple failings, it may have several cases recorded against it, for example, a Fees case and a UIOLI case.
Cases are more complex when a firm or individual fails to meet our minimum standards to the point where we believe they should no longer be authorised or approved or should be banned from providing financial services in the future. We call these ‘Failure to meet standards’ cases.
Cases opened during 2024/25
Of the cases opened during 2024/25, 3% were against individuals, and 97% (around 2,700) were against firms.
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Cases closed during 2024/25
Of the cases closed in 2024/25, 4% related to individuals and 96% (around 2,500) related to firms. When a firm has multiple open cases, and one is a UIOLI case, we typically use our UIOLI powers. The increases from 2023/24 to 2024/25 (Figure 2) reflect our ability to progress cases more efficiently now we have embedded our UIOLI powers.
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Cancellations and Prohibitions during 2024/25
No firms were cancelled solely due to a Directory Person case. Firms with a Directory Person case usually also had another case such as a UIOLI case. In these instances, the firm cancellation is recorded under UIOLI.
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Table 1: Prohibitions
| 2023/24 | 2024/25 | |
|---|---|---|
| Individual Prohibitions | 6 | 13 |
Other outcomes
In addition to cancellations, other outcomes include firms taking action to meet our required standards, and cases being discontinued in favour of other regulatory action, such as variation of permissions or ongoing supervisory oversight.
3. Interventions action
We aim to identify and respond to concerns about firms or individuals that present a risk of ongoing harm, including financial loss to consumers or to market integrity.
We use various tools to engage with firms and take early and swift action. This includes increasing use of our formal intervention tools (for example, varying or imposing requirements on a firm’s regulatory permissions) and informal tools.
During 2024/25, we achieved 135 outcomes using formal intervention tools, 4 more than last year. Overall, we had 260 new interventions cases, where we considered the use of voluntary requirements or our own initiative powers, compared to 268 in 2023/24.
Where we identify concerns or things go wrong, we generally seek to agree with the firm voluntary steps it must take to address our concerns. This helps to address risks and mitigate harm more quickly.
Table 2 shows, during 2024/25 the number of voluntary outcomes supported by Enforcement increased by 18% compared with the previous year:
Table 2: Voluntary outcomes
| 2023/24 | 2024/25 | |
|---|---|---|
| Voluntary Requirements / written undertakings | 104 | 119 |
| Variation of Permission (VVOP) | 1 | 0 |
| Direction under ML Regs (VDIR) | 1 | 6 |
| Total | 106 | 125 |
Where appropriate we exercise our formal powers to impose requirements on a firm’s permissions (OIREQs), to vary a firm’s permissions (OIVOPs) or to give directions under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (OIDIRs).
During 2024/25 Enforcement supported the following own initiative outcomes:
Table 3: Own initiative outcomes
| 2023/24 | 2024/25 | |
|---|---|---|
| Own initiative requirements (OIREQ) | 17 | 7 |
| Own initiative variation of a firm’s permission (OIVOP) | 2 | 0 |
| Joint OIREQ / OIVOP | 3 | 3 |
| Own initiative directions under the Money Laundering Regulations 2017 (OIDIR) | 1 | 0 |
| Own initiative variation of a Senior Management Function holder’s approval (OIVAP) | 2 | 0 |
| Total | 25 | 10 |
A few of the own initiative actions taken during 2024/25 remain subject to a potential challenge from the firm, either through representations to the decision-maker or through a reference to the Upper Tribunal.
Table 3 shows a decrease in the use of our own initiative powers against firms compared to the previous year. There has been a significant increase in the number of voluntary outcomes achieved this year. This reflects our strategy of early engagement with firms and encouraging them to correct issues voluntarily.
4. Enforcement operations
We investigate firms and individuals for potential regulatory breaches or criminal offences. This can lead to prosecution or enforcement action with various outcomes including, imprisonment, redress for consumers, financial penalties, banning people from performing functions relating to regulated activities and public censures. We also get court orders to protect assets and make them available to compensate consumers.
We open an enforcement operation when we have decided to appoint investigators under relevant legislation (typically Pt XI of the Financial Services & Markets Act 2000).
We investigate a wide range of potential misconduct including:
- insider dealing, market abuse and market manipulation
- firms and individuals carrying on regulated activities without authorisation, in breach of the general prohibition and/or contravening restrictions on financial promotions
- firms that sell unsuitable products or services to consumers, mishandle client money and assets, or have governance and systemic issues
- suspected fraud by firms authorised by us
- inadequate financial crime systems and controls
We also take action against individuals under the Senior Managers and Certification Regime (SM&CR), Statements of Principle and Code of Practice for Approved Persons (APER) and/or fitness and properness regimes.
The data reported reflects the number of enforcement operations. A single operation may involve investigations into multiple firm(s) and/or individuals at any one time.
As at 31 March 2025, we had 130 open enforcement operations, down from 188 in 2023/24.
We have reported our operations data based on our strategic priorities for 2022 to 2025:
- reducing and preventing financial crime (for example, shortcomings in anti-money laundering systems and controls and instances of fraud on consumers)
- putting consumers’ needs first
- strengthening the UK’s position in global wholesale markets
- other (for example, serious misconduct, that does not directly align to 1 of the 3 strategic priorities above)
We categorise each operation as criminal, civil or regulatory based on the nature of the breaches or offences. When we open an operation, we do not prejudge the outcome. If we are investigating a potential breach that might lead to either criminal, civil or regulatory action, we open those cases on a dual-track basis.
Current operations as at 31 March 2025 by type of operation and strategic commitment
Figures in parentheses represent the equivalent figures as at 31 March 2024.
Table 4: Current operations as at 31 March 2025 by type of operation and strategic commitment
| Regulatory | Criminal | Dual track | Civil | Total | |
|---|---|---|---|---|---|
| Reducing and preventing financial crime | 13 (14) | 37 (37) | 17 (21) | 8 (11) | 75 (83) |
| Strengthening Wholesale Markets | 19 (29) | 6 (5) | 7 (21) | 0 (0) | 32 (55) |
| Putting consumers' needs first | 12 (34) | 0 (0) | 0 (1) | 1 (0) | 13 (35) |
| Other | 10 (14) | 0 (0) | 0 (1) | 0 (0) | 10 (15) |
| Total | 54 (91) | 43 (42) | 24 (44) | 9 (11) | 130 (188) |
Duration of Enforcement operations
The speed of investigations and the length of time that an investigation may remain open depends upon various factors, including:
- the level of cooperation from subjects of investigations, including legal cooperation
- the complexity of the issues under investigation
- the volume of data and evidence to be obtained and reviewed
- whether the subject contests our findings
- delays in the justice system
We have significantly increased the pace and focus of our enforcement work to deliver impactful deterrence. Five recent operations achieved a public outcome in under 16 months.
Our data refers to 2 stages of an operation: the investigation stage and the post-investigation stage. The investigation stage starts when we open an enforcement operation. It runs throughout the case team’s investigation and, if needed, includes legal review and settlement. After the investigation, an operation may close, settle, or lead to proceedings before the Regulatory Decisions Committee (RDC) or contested litigation in the criminal or civil courts or Upper Tribunal. The post-investigation stage comprises investigations that are before the RDC or in contested litigation.
The duration data refers to when we decided to open an enforcement operation and the stage the operation had reached as at 31 March 2025.
In criminal proceedings, an operation stays open after a conviction while any confiscation orders under the Proceeds of Crime Act 2002 remain outstanding. The duration data includes 2 current operations, which are over 60 months old and on hold, because a defendant has absconded.
Figures in parentheses represent the equivalent figures as at 31 March 2024.
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Table 5: Age of current operations in the investigation stage as at 31 March 2025
| Investigation Stage | 0-24 months | 24-48 months | 48-60 months | 60+ months | Total |
|---|---|---|---|---|---|
| Regulatory | 14 (18) | 12 (29) | 3 (10) | 4 (4) | 33 (61) |
| Criminal | 9 (8) | 5 (5) | 0 (1) | 1 (3) | 15 (17) |
| Dual Track | 13 (24) | 6 (13) | 0 (2) | 2 (3) | 21 (42) |
| Civil | 1 (0) | 0 (1) | 1 (0) | 1 (1) | 3 (2) |
| Total Number of operations | 37 (50) | 23 (48) | 4 (13) | 8 (11) | 72 (122) |
Table 6: Age of current operations that have proceeded through the investigation stage and are now in the post-investigation stage as at 31 March 2025
| Post-investigation stage | 0-24 months | 24-48 months | 48-60 months | 60+ months | Total |
|---|---|---|---|---|---|
| Regulatory | 0 (1) | 3 (1) | 1 (4) | 17 (24) | 21 (30) |
| Criminal | 0 (0) | 3 (4) | 4 (0) | 21 (21) | 28 (25) |
| Dual Track | 1 (0) | 2 (0) | 0 (0) | 0 (2) | 3 (2) |
| Civil | 1 (0) | 0 (3) | 0 (2) | 5 (4) | 6 (9) |
| Total Number of operations | 2 (1) | 8 (8) | 5 (6) | 43 (51) | 58 (66) |
Operations opened
We opened 23 operations in 2024/25, compared to 25 in 2023/24. Figures in parentheses represent the equivalent figures for the period 1 April 2023 to 31 March 2024.
Table 7: Number of operations opened from 1 April 2024 to 31 March 2025
| 2024/25 | Regulatory | Criminal | Dual track | Civil | Total |
|---|---|---|---|---|---|
| Reducing and preventing financial crime | 6 (1) | 5 (4) | 5 (8) | 1 (0) | 17 (13) |
| Strengthening Wholesale Markets | 2 (3) | 0 (0) | 0 (3) | 0 (0) | 2 (6) |
| Putting consumers' needs first | 1 (3) | 0 (0) | 0 (0) | 1 (0) | 2 (3) |
| Other | 2 (2) | 0 (0) | 0 (1) | 0 (0) | 2 (3) |
| Total | 11 (9) | 5 (4) | 5 (12) | 2 (0) | 23 (25) |
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Operations closed
We closed 81 operations in 2024/25, compared to 60 in 2023/24.
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Operations closed 1 April 2024 to 31 March 2025 by duration
Table 8 sets out the age of the operations by duration. This data represents the period from our decision to open an enforcement operation to case closure on our case management system. Figures in parentheses represent the equivalent figures for the period 1 April 2023 to 31 March 2024.
Table 8: Operations Closed 1 April 2024 to 31 March 2025 by duration
| 0-24 months | 24-48 months | 48-60 months | 60+ months | Total | |
|---|---|---|---|---|---|
| Regulatory | 6 (9) | 27 (13) | 8 (7) | 15 (16) | 56 (45) |
| Criminal | 0 (1) | 3 (1) | 0 (0) | 4 (0) | 7 (2) |
| Dual track | 3 (5) | 8 (4) | 1 (0) | 2 (0) | 14 (9) |
| Civil | 0 (1) | 3 (1) | 0 (2) | 1 (0) | 4 (4) |
| Total number of operations | 9 (16) | 41 (19) | 9 (9) | 22 (16) | 81 (60) |
Enforcement outcomes
A single operation may investigate multiple firm(s) and/or individual(s) at any one time. This means we may achieve several outcomes as part of a single operation. So, we report enforcement outcomes at subject level rather than operation level.
Table 9: Enforcement outcomes
| 2023/24 | 2024/25 | ||
|---|---|---|---|
| Number of Final Notices* | Enforcement | 21 | 37 |
| Threshold Conditions Team | 295 | 863 | |
| Total | 316 | 900 | |
| Number of Financial Penalties | Firms | 8 | 16 |
| Individuals | 4 | 13 | |
| Total | 12 | 29 | |
| Total value of Financial Penalties | Firms | £38,359,140 | £179,096,835 |
| Individuals | £4,229,700 | £7,315,673 | |
| Total | £42,588,840** | £186,412,508 | |
| Number of Prohibitions (including partial) | Enforcement | 13 | 17 |
| Threshold Conditions Team | 6 | 13 | |
| Total | 19 | 30 | |
| Number of Cancellations (Threshold Conditions Team) | Total | 851 | 1456 |
| Number of Public Censures | Total | 10 | 3 |
| Number of Criminal Convictions* | Total | 11 | 5 |
| Number of Criminal Confiscation orders* | Total | 2 | 6 |
| Value of Criminal Confiscation orders | Total | £0.9m | £6.88m |
*Including Notices relating to Money Laundering Regulations 2007 and Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. An Enforcement Final Notice may contain several outcomes. These outcomes have been listed in their respective area.
**The 2023/24 financial penalties include x3 competition fines.
5. Asset Protection and Recovery
As at 31 March 2025, we had a total of 43 restraint or civil freezing orders with an estimated value of over £61m. Of this, we obtained 3 new restraint orders during 2024/25.
Table 10: Total number of restraint or civil freezing orders with value as at 31 March 2025
| Number of orders | Estimated value | |
|---|---|---|
| Restraint | 43 | £61.5m |
| Civil freezing | 0 | £0 |
| Total | 43 | £61.5m |
Table 11: New restraint or civil freezing orders obtained between 1 April 2024 - 31 March 2025
| Total no of orders | Estimated Value | |
|---|---|---|
| Restraint | 3 | £4.5m |
| Civil freezing | 0 | £0 |
| Total | 3 | £4.5m |
Proceeds of Crime Act: Confiscation orders
We continue to enforce confiscation orders to secure compensation for victims to deprive criminals of the financial benefit gained from crime. In 2024/25 we secured 6 confiscation orders totalling £6.88m.
If there are consumer losses, the Court may order that compensation be paid to victims from the recovered confiscation money. If there are no identified victims, or the recovered money exceeds the amount of compensation ordered, the excess is paid to the Home Office.
We are a member of the Asset Recovery Incentivisation Scheme. As part of this scheme, we receive a portion of the money recovered and paid to the Home Office following successful proceedings conducted under the Proceeds of Crime Act 2002.
Funds secured for consumers and investors
Where appropriate, we aim to secure redress for consumers who have suffered harm or return funds to investors. We secured an estimated £442.3m for investors and consumers through redress schemes or settlements agreed as part of an enforcement outcome or via civil proceedings.
In addition, in 5 cases we reduced the amount of a financial penalty in favour of payments to the Financial Services Compensation Scheme (FSCS), to contribute towards redress owed to impacted consumers.
Table 12: Funds secured for consumers and investors between 1 April 2024 to 31 March 2025
| Category | Amount |
|---|---|
| Redress schemes or settlements | £442.3m |
| Payments to FSCS alongside 5 enforcement outcomes (such as a prohibition order) | £105,100 |
| TOTAL | £442.4m |
The figures in Table 12 do not include the value of voluntary redress schemes operated by firms. In 3 enforcement operations concluded in 2024/25, in addition to a financial penalty, firms operated voluntary redress schemes with a total estimated value of £354.6m. We reduced the amount of the financial penalty imposed by us in those cases as a result.
6. Law and international
Our investigations are increasingly international, and the misconduct we tackle often involves multiple jurisdictions.
Effective cooperation with international regulators and law enforcement agencies is vital to the work we do, particularly for tackling online harm and new products.
We dedicate significant resources to building, maintaining, and strengthening international cooperation. We take steps to ensure all appropriate actions are taken to help international partners protect financial markets and prevent harm.
Our powers to seek information needed for investigations, including helping foreign regulators, are vital in making sure investigations involving multiple jurisdictions can be conducted properly. We continue to use these powers effectively.
Our work with international groups
We work closely with international groups like the International Organisation of Securities Commission’s (IOSCO) committee on enforcement and the exchange of information to tackle cross-border misconduct.
We continue to be the largest user of IOSCO’s Multilateral Memorandum of Understanding (MMoU). We also receive the largest number of requests for help under this agreement.
One of our directors, Andrea Bowe, is currently Chair of IOSCO’s MMoU Monitoring Group. This group is focused on the continued success of, and full compliance with, this essential cooperation agreement. We anticipate continuing to implement positive change in this area in the coming year.