Non-financial misconduct refers to serious behaviors unrelated to an individual's professional financial responsibilities, yet they raise concerns about their overall fitness and propriety. Examples include bullying, harassment (including sexual harassment), violence, discrimination, or other actions that undermine trust and inclusivity. These incidents might happen off-duty—at a social event, online, or in personal life—but if they come to light, they can signal deeper character issues that affect professional judgment.

As we hit the midpoint of 2025, the UK's Financial Conduct Authority (FCA) is in full swing with its ambitious regulatory reforms, aimed at boosting the competitiveness of the asset management sector while safeguarding market integrity. For Alternative Investment Fund Managers (AIFMs), advisory firms, and investment managers, this means a landscape of opportunities—but also a minefield of challenges. The removal of the "small registered AIFM" category, streamlined Senior Managers and Certification Regime (SM&CR) updates, and tweaks to MiFID II research payments are game-changers. Yet, with application timelines stretching 6–12 months and costs piling up to £30,000–£75,000 (including FCA fees of £2,720–£10,880), getting it wrong can delay launches or trigger costly revisions.

Part 4A regulated firms are subject to the Senior Managers and Certification Regime (SM&CR). UBOs, defined under MLR 2017 as individuals with significant control (e.g., >25% ownership or voting rights), are distinct from SMF applicants or controllers but may overlap in smaller firms. Here, we analyse whether UBOs of Part 4A firms require DBS checks, considering FCA and MLR requirements.

The UK’s fight against economic crime has taken a significant step forward with the implementation of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). This landmark legislation introduces stricter regulations for company directors and Persons with Significant Control (PSCs), particularly around identity verification and anti-money laundering (AML) compliance.

The Financial Conduct Authority (FCA) has been making waves in the UK financial sector, and its latest move is a bold one. On July 16, 2025, the FCA slapped Barclays Bank UK PLC and Barclays Bank PLC with a hefty £42 million fine for significant lapses in their financial crime risk management. This action underscores the regulator’s ongoing commitment to keeping UK markets clean and ensuring consumers are protected from financial misconduct.

I read the Crispin Odey Notice of Decision published by the FCA on 17 March 2025.  Whilst the overall actions of Mr Odey are incredulous and many will be commenting on that part of it, particularly the lack of integrity, I thought that the determination of the fine was interesting so have summarised the process here.  We should note that the FCA’s decision has been referred to the Upper Tribunal, so this may not be the final outcome for Mr Odey. 

As of March 2025, the UK's asset management industry has experienced significant regulatory changes aimed at enhancing transparency, investor protection, and market competitiveness. Below is an overview of the key developments:​