Newsletter covering insights and themes from our enforcement work.
About this edition
On 3 June 2025, we published our updated Enforcement Guide[2] (ENFG). In this, we amended our publicity policy[3] to achieve greater transparency.
In the first edition of Enforcement Watch, we cover our:
- Updated publicity policy in action.
- Enforcement case priorities.
- International partnerships.
1. Our publicity policy in action
Under the updated policy, we can:
Name firms in exceptional circumstances
Our updated publicity policy retains the ‘exceptional circumstances’ test. The FCA will only name a firm or individual subject to an enforcement investigation if this test is met.
React to public announcements
We can reactively announce investigations where it is already in the public domain.
Announce investigations without naming firms
We can also announce that a firm is under investigation, without identifying them.
Identify firms carrying out unauthorised business
Nearly all providers of financial services in the UK require our permission to operate. When we investigate unauthorised business, we can name a firm under investigation if desirable to warn consumers or help the investigation.
When we open a case, we will always consider whether to announce and regularly revisit this through the course of the investigation. In deciding whether to make an announcement, we consider the potential prejudice that we believe may be caused to any persons who are, or are likely to be, a subject of the investigation.
Between 3 June and 31 December 2025, we opened 23 enforcement operations.
- In 6 of those, we are only investigating individuals. The bar for announcing an investigation into an individual is high, and none of the 6 so far have met that bar.
- We have confirmed 3 investigations into listed issuers following an announcement by the firm. These were our investigations into John Wood Group plc[5], Drax Group plc[6] and WH Smith plc[7].
- Two investigations have been opened regarding unauthorised business activity. We have decided not to announce those investigations yet for operational reasons, however we are keeping that under review.
- We have opened 12 operations into authorised firms, naming one firm under investigation. We decided our investigation into The Claims Protection Agency Limited[8] (TCPA) met the ‘exceptional circumstances’ test. TCPA filed a judicial review application challenging our decision to announce, which was dismissed. We set out further details below.
- And we have confirmed investigations into 2 insurers in the home and travel markets, without naming them.
- In the remaining operations, we considered the exceptional circumstances test, as set out above. However, we did not think the threshold had been met in these cases but are keeping the position under review.
1.1. Investigating a motor finance claims management company
On 2 January 2026, we announced that The Claims Protection Agency Limited (TCPA), an authorised claims management company, is under enforcement investigation following concerns about how it promoted potential motor finance claims.
We decided the exceptional circumstances test in ENFG 4.1.4G was met, primarily to protect consumers by ensuring they had clear and timely information about their options.
Motor finance – why this matters
Concerns about harm in motor finance have been a longstanding focus for the FCA.
After identifying risks in the sector, we banned the use of discretionary commission models[9] in 2021. This led to a significant increase in complaints and litigation, and in January 2024 we began work to assess whether widespread misconduct had occurred.
While that work progressed, we temporarily extended complaint-handling time limits for firms and later consulted on a proposed redress scheme for affected customers.
Throughout this period, we reminded consumers they did not need to use a claims management company (CMC) or law firm to seek compensation and that doing so could reduce any redress they received.
Read the latest on our work on the motor finance sector[10].
Our concerns about CMC conduct
Alongside this, we monitored the behaviour of claims management companies (CMCs) operating in the motor finance space.
We identified risks that some promotions and customer communications were unclear, misleading or unfair, potentially leading consumers to make decisions without understanding their choices or the costs involved.
In July 2025, we wrote to all CMCs[11] to reinforce expectations around compliant financial promotions and warned that we would intervene where firms fell short.
The investigation into TCPA
TCPA’s business involved identifying potential motor finance claims and referring consumers to partner law firms. It promoted its services across a range of media, including a social media campaign featuring a prominent public figure.
We raised concerns about some of these financial promotions in July and August 2025. The firm subsequently applied for, and we accepted, a voluntary requirement requiring it to stop onboarding new customers and to withdraw existing promotions.
In light of these concerns, we appointed a team of investigators to determine whether TCPA may have breached our rules with its advertising and sales tactics. The investigation is looking at:
- What customers were told about the amount of redress they might get.
- Whether customers were told they could make a claim for free.
- Whether customers were pressurised to sign up.
We should make clear that in respect of the investigation, we have not reached any conclusions on whether the firm breached any regulatory requirements.
Why we announced the investigation
On 1 September 2025, we notified TCPA that we intended to make the investigation public. We considered the exceptional circumstances threshold in ENFG 4.1.4G to be met. One of our key reasons was consumer protection – we wanted TCPA’s customers to be aware of our concerns so they could properly consider their next steps.
TCPA challenged this decision through judicial review.
The High Court dismissed the claim, and the Court of Appeal refused permission to appeal. The High Court’s 2-part judgment, released on 23 October 2025 and 2 January 2026, confirmed that we had correctly interpreted ENFG 4.1.4G and that our decision to name the firm was reasonable. The Court accepted that we had identified the potential prejudice to TCPA but found that this was outweighed by the need to protect consumers.
2. Enforcement case priorities
The 23 enforcement operations we have opened since 3 June 2025 cover a wide range of suspected misconduct.
- 18 operations are investigating regulatory breaches.
- 4 consider criminal and regulatory offences.
- In one, we are only investigating criminal offences.
They include investigations into:
Individual responsibility
We’re investigating individuals’ potential responsibility for regulatory failings, such as:
- Providing false information to the FCA.
- Suspected fraud[12].
- Misappropriation of funds.
Listed issuers
We’re investigating potential market disclosure issues.
Unauthorised business
We’re investigating suspected unauthorised business, particularly in the cryptoasset sector, where entities provide cryptoasset services while not registered under the Money Laundering Regulations[13].
Firms that provide services to other financial institutions should check that their customers hold the requisite permissions to undertake the activities they offer.
Fair value
We’re investigating 6 potential Consumer Duty[14] breaches by firms, particularly in relation to fair value for consumers.
Fair value requires firms to assess whether the price the customer pays for a product or service is reasonable compared to the overall benefits.
Two of our Consumer Duty investigations concern insurance firms, and they were the most serious cases identified in our multi-firm work.
In some Consumer Duty cases, we have used supervisory tools, including voluntary or own initiative requirements, to protect consumers while investigations continue.
Inadequate oversight
We’re investigating suspected systems and controls failings, where authorised firms may have caused harm through inadequate oversight of systems or relying on third party providers that did not meet standards.
The harm caused in these cases includes customers:
- Unable to access information about their accounts.
- Experiencing delayed responses to complaints.
- Facing mishandled claims.
Adequacy of controls
We’re investigating concerns around the adequacy of firms’ financial crime controls.
Firms are key to preventing financial crime, and we will act where we suspect inadequate controls are enabling such crime to occur.
Consumer investment and asset management
We’re investigating 5 firms in the consumer investment and asset management sectors, looking into suspicions of:
- Misleading consumers and third parties with false statements.
- Failing to recognise conflicts of interest.
Before a firm reaches enforcement, our supervisory approach[15] allows them the opportunity to do the right thing before we open an investigation.
The factors that lead to us opening an investigation are unique. However, some of the reasons that led us to decide to use our enforcement tools in these cases include where we suspect:
- Repeated failures to be open with us about our concerns.
- Failing to put things right promptly, where our supervisory work has highlighted significant concerns.
- Deliberately misleading the FCA, consumers or the markets.
- Causing significant harm to consumers through fraud, severe disruption to services and misappropriation of assets.
3. International partnerships
We work closely with partners across the globe, including law enforcement agencies and regulators. These partnerships support our work to detect and disrupt crime and misconduct and take enforcement action.
Our membership of the International Organisation of Securities Commissions (IOSCO) is a key part of this. Over 130 jurisdictions are signed up to IOSCO memorandums of understanding. They agreed to get and share information to help each other’s enforcement work.
In December 2025, Nicholas Hills, one of our enforcement directors, was elected by IOSCO members to continue our leadership as chair of the group that monitors how the memorandums work. We have used that leadership role to spearhead reforms to further strengthen cooperation.
We are one of the biggest users across the globe of the IOSCO agreements; last year we sent and received a total of 476 requests for information. These global partnerships are extremely valuable to our cross-border investigations. They enable us to quickly get hold of information from around the world to build our cases, including witness statements, banking records, transaction data, communication records and more. See, for example, our investigation into Bluecrest[16]. The support we give other regulators in disrupting crime and tackling misconduct is also frequently acknowledged, for example, in this recent US SEC market manipulation case[17].
The IOSCO framework complements our international information-gathering tools via mutual legal assistance channels and the Crime (Overseas Production Orders) Act (COPO).
In criminal investigations, we now receive electronic data from service providers based in the US much faster. We achieved this by getting court orders in the UK through COPO, which can then be served direct on providers in the US. Before, it could take over a year to get this kind of information via other mutual legal assistance channels. With COPO, it takes a few weeks. In 2025, we successfully made several requests via this route to support ongoing market abuse work and will use this across our criminal portfolio where relevant.
International collaboration is key to tackling online frauds and scams. Bad actors and platform providers are often based outside the UK. We worked with partners at IOSCO to issue a joint statement[18] in May 2025. And in June, we led an international crackdown on illegal finfluencers[19], joining forces with regulators from around the world.
In 2026, we will continue to work with international partners to tackle global concerns.
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