Financial Services: 2020 Enforcement Trends - Sara Cody, Linklaters Financial Regulation & Counsel PSL

Financial Services: 2020 Enforcement Trends - Sara Cody, Linklaters Financial Regulation & Counsel PSL

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 LexisNexis interviewed Sara Cody, Counsel PSL in the Financial Regulation Group at Linklaters earlier in the year.

Sara is also consulting editor of LexisPSL Financial Services, (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 Standard Life and Prudential for mis-selling annuities, and Carphone Warehouse for mis-selling insurance [...]


Click here for the full interview:

Enforcement Trends for 2020: Interview with Sara Cody

For further news, legal and regulatory updates and to sign up to alerts, see the Financial Services industry blog.


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About the author:

Amy is an established writer and researcher, having contributed to publications, such as The Law Society, LPM, City A.M. and Financial IT. Her role at LexisNexis UK involved leading content and thought leadership, as well as writing research reports, including "The Bellwether Report 2020, Covid-19: The next chapter" and "Are medium-sized firms the change-makers in legal?"