Mischon de Reya’s Enforcement Watch—Autumn 2025
Financial Services analysis: Mishcon de Reya‘s Financial Services and White Collar Crime & Investigations teams, examines the latest developments in enforcement, analysing: the Financial Conduct Authority’s (FCA) fines against Monzo Bank for anti-money laundering (AML) failures and Barclays Bank for financial crime control failings involving WealthTek and Stunt & Co; the Upper Tribunal judgments in the cases of Lopez Gonzalez, Sheth and Urra, Donaldson and Arden, and Jes Staley; and the FCA’s prohibition and £1m fine against H2O’s former deputy CEO, Jean-Noel Alba, for misleading the regulator. The edition also highlights the FCA’s prosecution of Daniel Pugh for a £1.3m Ponzi scheme, and its confiscation of nearly £300,000 from convicted fraudsters. Further analysis explores the FCA’s focus on non-financial misconduct and workplace relationships ahead of the 2026 COCON rule changes, alongside insights from the FCA’s latest Market Cleanliness Report revealing an increase in suspicious pre-takeover trading activity.