Enforcement procedures remodelled

The introduction of partly-contested cases and elimination of later-stage penalty discounts could streamline the regulatory enforcement process but may also give rise to potential problems. Much will depend on how the changes are applied in practice, explain Louise Hodges and Jonathan Blunden.

Louise Hodges is a partner specialising in fraud and business crime litigation, and Jonathan Blunden is an associate, at Kingsley Napley in London. Contact them on lhodges@kingsleynapley.co.uk and jblunden@kingsleynapley.co.uk.

In February 2017, the Financial Conduct Authority and the Prudential Regulation Authority issued an important joint policy statement on enforcement decision-making. Of particular interest to compliance advisers are: