On 17 June 2026, Therese Chambers, the Financial Conduct Authority (FCA)’s joint executive director of enforcement and market oversight, delivered a speech entitled “Beyond the headlines: the unseen fight against financial crime”. In that speech, she described how the FCA now chooses to use the various different “tools” available to it rather than necessarily following the route of the more traditional enforcement process of the FCA’s issuing Warning, Decision and Final Notices, hearings before the RDC, the Upper Tribunal or both, and potential financial penalties and public censures.
This would include disciplinary action against individuals under S. 66 of the Financial Services and Markets Act 2000 (FSMA) or enforcement action against authorised firms for breach of relevant requirements under S. 205-207 of FSMA - let us call them “formal enforcement actions”.
One of her key messages is that “financial crime” is becoming faster, more complex and more widespread. In response, the FCA are making fuller use of the tools available to them, including the credible threat of enforcement, to step in before harm escalates.
Having referred to a number of headline-making formal enforcement actions, she noted that although these cases took time, they were the right response to keep the system clean and build trust.
However, running alongside such formal enforcement actions, she highlighted the FCA’s pursuit of other processes which are “less obvious”, but are equally important in achieving “the quiet prevention of harm”.
Ms. Chambers cites the following examples:
- Monitoring market integrity, looking for a sign that something is wrong long before it becomes visible to anyone else.
- Reviewing financial promotions and taking down misleading adverts before they reach consumers.
- Identifying a prospectus that resembled a pump-and-dump scheme, pausing its approval, and leading to the fundraising being withdrawn.
“Changing threat, changing model”
Ms. Chambers said the threats the FCA are facing are now more complex than ever with technology, including AI, accelerating the pace and scale of financial crime.
Criminals “are prolific innovators”, moving faster than traditional law enforcement can respond.
While traditional enforcement was essential, it was also “expensive, slow and highly visible”, creating a gap where harm occurs.
To close that gap, the FCA need to adapt. Ms. Chambers refers to for enforcement aspects.
- Prevent.
- Pursue.
- Protect.
- Prepare.
She referred to “a lot of pursuing” with 42 outcomes in 2024, another 38 in 2025, and as of June 1st, 18 so far this year. They are also pursuing investigations to an outcome more quickly than ever before.
Whistleblowing disclosures made to the FCA have increased by 20% in the past year – helping the FCA to stop harm earlier.
At the same time, given the size of the regulated firm and listed issuer population, and the FCA’s receiving 35 million transaction reports every day, she said “[i]t’s impossible to pursue all instances of harm in the same way”.
“Cutting off harm at the root”
In being more visible about the ways they fight crime and tackle harm, Ms. Chambers referred to the “no-man’s land between ‘doing nothing’ and launching a full enforcement investigation”.
This includes increased use of the credible threat of enforcement and driving earlier intervention using their supervisory tools and market oversight.
Ms. Chambers highlights their imposition in one specific case of an Own Initiative Requirement (OIREQ) requiring the firm concerned to take on no new customers or funds, and a return funds currently held to customers. The firm did not challenge that OIREQ decision, and the FCA were able to “stop the harm quickly and quietly. No fine or prosecution needed”, noting that OIREQs are so effective because they are immediate.
In terms of other tools, at the other end of the spectrum is a conversation, a letter or targeted visit. Further along the spectrum, the FCA use skilled person reviews.
Ms. Chambers referred to another case involving serious weaknesses in a firm’s financial crime controls, and where they agreed a voluntary requirement (VREQ) rather than moving straight to enforcement.
Ms. Chambers also referenced a current case where the FCA intervened early by appointing administrators to secure the position and protect consumers while we consider next steps.
Legal and procedural protections and voluntary outcomes
Ms. Chambers claims that firms have legal and procedural protections, but that in many cases, they cooperate and agree to restrictions without the need for the formal exercise our powers (presumably agreeing to sign up to a VREQ (S.55L(5)(a) of FSMA) or a Voluntary Variation of Permissions under s. 55H of FSMA (VVOP).
In the last financial year, Ms. Chambers said there were a total of 369 voluntary outcomes across the FCA.
124 of those – the most complex – were supported by the FCA’s Interventions Team, as well as an additional 13 where the firm concerned was not prepared to agree, and where the FCA had to exercise formal powers. Ms. Chambers added:-
“These outcomes are not separate from our enforcement work. They are our enforcement work – even if they don’t look like the kind you’re used to”.
They also speak to the volume and pace of what the FCA are facing.
A global problem calls for a global response
In relation international/cross border matters, Ms. Chambers highlighted the FCA’s role in cooperating with overseas regulators.
The fundamentals remain
Ms. Chambers said that none of their international cooperation meant the FCA have taken their eye off the ball closer to home, protecting consumers, keeping markets clean and tackling fraud and scams. The FCA were not replacing those fundamentals but are sharpening them, referring to 19 convictions in 2024/5.
The Consumer Duty continues to set the bar for how the FCA expect firms to treat their customers, and the FCA will not hesitate to act where they fall short.
Ms Chambers argues that the absence of headlines should not be a concern, saying that trust in markets is not built by fines or headlines alone – those are just the visible tip of a much bigger iceberg.
Our view
There appears to have been a significant reduction in what I have referred to as formal enforcement actions. This was reflected in our earlier article here in relation to the FCA’s annual enforcement data describing its enforcement action taken in the year to 31 March 2025.
Ms. Chambers confirms that the FCA is instead resorting to other tools and in particular what one might have previously thought of as supervisory requirements rather than a means to enforce against wrongdoing. The extensive use of “voluntary requirements” is striking, but we question the assertion that although firms have legal and procedural protections, they nevertheless chose not to exercise those rights to object, and instead “cooperate and agree to restrictions without the need for the formal exercise our powers”. The reality is that regulated firms will often find themselves having little choice but to “volunteer” to comply with requirements defined by the FCA for fear of (i) being characterised as uncooperative with their regulator (ii) potentially facing even more onerous requirements being imposed under the FCA’s “own initiative” powers or (iii) facing formal enforcement action, with the risk of financial penalties and public censure. Once a voluntary requirement has been agreed, the firm has no direct right of recourse to challenge their voluntary commitment, which is often open ended in duration. The FCA is never put to proof on its case and if serious misconduct is involved, it may be in the interests of regulatory justice that allegations are tested and either proven or rejected.
