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Are you interested to understand the priorities of the FCA regarding 2020 Enforcement Trends, the impact of the Senior Managers & Certification Regime (SM&CR) and the general trends linking FCA investigations?

Our Financial Services team at ÀÏ˾»úÎçÒ¹¸£Àû interviewed Sara Cody, Counsel PSL in the Financial Regulation Group at Linklaters earlier in the year.

Sara is also consulting editor of  (click here if you are not a current subscriber).

What do you see as the key focus for FCA Enforcement in 2020?

Key areas of focus in the coming year are likely to include operational resilience and cyber-security, along with anti-money laundering (AML) and a continued focus on culture.

How will the FCA’s scrutiny of firm culture be translated into enforcement?

It’s quite interesting to consider how culture feeds into enforcement, as opposed to being a broader supervisory concern. The Financial Conduct Authority (FCA) can’t simply fine a firm for bad culture; it’s too nebulous. However, the FCA can fine firms for decisions and practices that arise out of a poor culture, such as sales procedures that fail to put the customer first. Last year, for example, we saw the FCA cite an aggressive sales culture as a factor in its decisions to fine  and  for mis-selling annuities, and  for mis-selling insurance [...]

Click here for the full interview:

Enforcement Trends for 2020: Interview with Sara Cody

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