FCA Regulatory Brief – Priority Actions for Firms
Brief12 May 2025

FCA Regulatory Brief – Priority Actions for Firms

The FCA's recent activities highlight its focus on several key areas: conduct and culture, tech adoption, data and reporting efficiency, and global reach. The blog emphasizes that firms should proactively align with these themes to prepare for future supervision.

MC

MEMA Consultants

Regulatory Intelligence

At A Glance

Fast takeaways for decision-makers.

  • 1Conduct & culture – rising whistle-blowing cases and fresh insider-dealing convictions foreshadow tougher enforcement.
  • 2Tech adoption – new live-testing proposals for AI and a roadmap for crypto-trading venues demand forward-looking risk controls.
  • 3Data & reporting efficiency – streamlined consumer-credit returns signal a broader “smarter reporting” push.
  • 4Global reach – speeches on UK-China cooperation and the appointment of a dedicated payments lead underscore growing cross-border scrutiny.

Source Notes

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

Top-ten developments, why they matter, and 30-day actions

FCA

FCA Source

The FCA’s output over the past fortnight sharpened its focus on:

  • Conduct & culture – rising whistle-blowing cases and fresh insider-dealing convictions foreshadow tougher enforcement.
  • Tech adoption – new live-testing proposals for AI and a roadmap for crypto-trading venues demand forward-looking risk controls.
  • Data & reporting efficiency – streamlined consumer-credit returns signal a broader “smarter reporting” push.
  • Global reach – speeches on UK-China cooperation and the appointment of a dedicated payments lead underscore growing cross-border scrutiny.

Firms that proactively map these themes to their SM&CR accountability, Consumer Duty evidence and operational-resilience plans will be best placed for the 2025/ 26 supervisory cycle.

Top-ten developments, why they matter, and 30-day actions

# Release & date Why it matters What firms should do within 30 days
1 Whistle-blowing data Q1 2025 – 12 May FCA 468 cases closed; enforcement or s166 action followed in 2.6 % of closures, with conduct and market-abuse themes dominant
  • Audit whistle-blowing channels for speed, anonymity and root-cause capture; brief SMF16/17

  • Trend analysis to feed next annual conduct-risk report

2 PS25/4 – pooled-fund research payment option – 9 May FCA Restores joint-payment accounts, reversing MiFID II unbundling constraints for UCITS/AIF managers
  • Redraft research-procurement & inducement policies

3 Insider-dealing conviction – 9 May FCA Professional traders pleaded guilty; FCA stresses personal accountability and will seek confiscation orders
  • Refresh MAR training for all trading staff

  • Test STOR thresholds and escalation timelines

4 Review of smaller asset managers – 8 May FCA Liquidity stress-testing and valuation controls weakest; targeted follow-ups expected
  • Gap-analyse findings against current controls

  • Reverse-stress-test high-beta funds and log results in risk register

5 David Geale appointed Exec Director Payments & Digital Finance – 8 May FCA Signals consolidation of PSR into FCA and intensified scrutiny of payments, open-banking and crypto sectors
  • Map payments and crypto activities to SMF owners

  • Engage with National Payments Vision consultations

6 Consumer-credit data-return overhaul – 7 May FCA New return replaces two existing returns and pauses four more, cutting 28 % of questions Identify changed fields; align IT schemas Update data-governance policy and brief finance teams
7 Crypto trading-platform roadmap (DP25/1) – 2 May FCA Frames future rules on intermediaries, staking, lending and DeFi; feedback due 13 June
  • Form working group to draft response

  • Quantify capital, safeguarding and systems impact for each crypto activity

8 Restriction on Direct Trading Technologies – 2 May FCA Own-initiative requirement freezes CFD broker for governance and FR&C failings, showing faster supervisory intervention
  • Re-test wind-down plan triggers and liquidity buffers

  • Re-assess CFD and market-making controls

9 AI live-testing service engagement paper – 29 Apr FCA Proposed sandbox allows 12-18-month live validation of AI models starting Sept 2025
  • Catalogue current/planned AI use-cases

  • Align model-risk framework with testing requirements; prepare sandbox application

10 Speech: strengthening UK-China financial partnership – 12 May FCA FCA chair highlights deeper cooperation on green finance, wealth management and supervision
  • Review data-transfer and outsourcing clauses for PRC exposure

  • Add geopolitical-risk lens to 2025 ICAAP/ORSA updates

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