Tag Archives: Martin Coombes

UK Market Conduct – Avoiding Governance and Oversight Pitfalls

by Matthew Nunan, Michelle M. Kirshner, Martin Coombes, and Chris Hickey

The UK Financial Conduct Authority (“FCA”) continues to show a desire to take action in sectors of the financial services industry where there has been traditionally less supervisory oversight and to push the importance of firm’s internal governance and oversight structures. Enforcement cases are often used as a way to convey key messages to such sectors, and an important Final Notice[1] was published on Monday 23 November 2020 when the FCA imposed a fine of nearly £3.5m on TFS-ICAP Limited for breaches of Principle 2 (due skill, care and diligence), Principle 3 (reasonable care in organising and controlling its affairs responsibly and effectively) and Principle 5 (proper standards of market conduct) of the Authority’s Principles for Businesses. Continue reading →

The Challenge of Addressing Non-Financial Misconduct in UK Regulated Firms

by Matthew Nunan and Martin Coombes

Many UK regulated firms will be currently (re-)assessing staff as fit and proper and training staff on the Financial Conduct Authority’s (FCA’s) (or the Prudential Regulation Authority’s (PRA’s)) Conduct Rules. The FCA has recently banned three individuals from working in the financial services industry for non-financial misconduct outside the workplace. The enforcement actions are, therefore, a timely reminder for regulated firms that the FCA has indicated it will bring an increased focus on how firms deal with non-financial misconduct by employees, both within and outside of the workplace. Continue reading →