FCA Enforcement Actions, Fines & Warnings

On 12 December 2025, the FCA published a final notice imposing a financial penalty of £44,078,500 on Nationwide Building Society for failings relating to its systems and controls for managing the risk of financial crime. Nationwide breached Principle 3 of the FCA's Principles for Businesses and associated SYSC 6 rules.   https://www.fca.org.uk/publication/final-notices/nationwide-building-society-2025.pdf

A final notice has been issued in relation to Monzo because it breached Principle 3 in failing to take reasonable care to organise and control its systems and controls for managing the risk of financial crime (in particular in connection with customer onboarding) responsibly and effectively during the Pre VREQ Period. Monzo also contravened relevant requirements imposed upon it (under section 55L(5)(a) of the Act) during the Relevant VREQ Period. https://www.fca.org.uk/publication/final-notices/monzo-bank-limited.pdf

A final notice has been issued in relation to failings in Starling Bank Limited's financial crime systems and controls as well as their breaches of a Voluntary Requirement (VREQ). https://www.fca.org.uk/publication/final-notices/starling-bank-limited-2024.pdf

On 23 September 2022, the FCA decided to impose a financial penalty on Barclays Bank Plc. The reason for this action is because Barclays Bank Plc failed to comply with Listing Rule 1.3.3 in October 2008. This matter has been referred by Barclays Bank Plc to the Upper Tribunal. The FCA’s findings and proposed action are therefore provisional and will not take effect pending determination of this matter by the Upper Tribunal. The FCA’s decision was issued on 23 September 2022 and a copy of the Decision Notice is displayed on the FCA's web site here: https://www.fca.org.uk/publication/decision-notices/barclays-bank-plc-dn-2022.pdf  

On 24 February 2022, the FCA imposed a financial penalty on Barclays Bank Plc. The reason for this action is because the firm failed to conduct its business with due skill, care and diligence and thereby breached Principle 2. As a consequence of this action, the FCA imposed a penalty of £783,800. The FCA’s action took effect on 24 February 2022 and a copy of the Final Notice is displayed on the FCA's web site here: https://www.fca.org.uk/publication/final-notices/barclays-bank-plc-2022.pdf  

On 15 December 2020, the FCA fined Barclays Bank UK PLC, Barclays Bank PLC, Clydesdale Financial Services Limited (Barclays) . The reason for this action is that between 1 April 2014 and 31 December 2018, Barclays breached Principles 6 and 3 of the Authority’s Principles for Businesses and CONC 6.7.2R, 7.2.1R and 7.3.4R from its Consumer Credit sourcebook by failing to show forbearance and due consideration to business and retail customers when they fell into arrears or experienced financial difficulties. The FCA’s action took effect on 15 December 2020 and a copy of the Final Notice is displayed on the FCA's web site here https://www.fca.org.uk/publication/final-notices/barclays-2020.pdf  

The FCA has taken enforcement action against Lloyds Bank PLC, Bank of Scotland plc, and The Mortgage Business Plc (“the Banks”) because between 7 April 2011 and 21 December 2015 (the “Relevant Period”), the Banks breached Principles 3 and 6 of the Authority’s Principles for Businesses. As a consequence of this action, the Banks received a financial penalty of £64,046,800 pursuant to section 206 of the Act. The Banks agreed to resolve all issues of fact and liability and qualified for a 30% discount under the Authority’s executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £91,495,400 on the Banks.     The FCA’s action took effect on 11 June 2020 and a copy of the Final Notice is displayed on the FCA’s web site here: https://www.fca.org.uk/publication/final-notices/lloyds-bank-plc-bank-of-scotland-plc-the-mortgage-business-plc-2020.pdf  

On 21 June 2019, the FCA has fined Bank of Scotland Plc (BOS). The reason for this action is because the Firm contravened Principle 11 (Relations with regulators) by failing to be open and cooperative in its communications with the Authority in relation to BOS’s suspicions that fraud may have taken place within its London and South East Regional Impaired Assets office headquartered in Reading (IAR) between 3 May 2007 to 16 January 2009. A serious control breakdown was discovered in early 2007 by BOS in IAR. The Director of IAR in the region, Lynden Scourfield, had been sanctioning limits and additional lending facilities beyond the scope of his authority undetected for at least three years. By 3 May 2007, BOS had identified suspicious conduct, including suspicions of fraud. On a number of occasions during the Relevant Period, internal reports within BOS referred to the issues that had been identified as the `Reading fraud’. However, it was not until July 2009, that BOS provided the Authority with full disclosure in relation to its suspicions and the report of the investigation that it had conducted. As a consequence of this action, the FCA has imposed a financial penalty of £45,500,000 (£65,000,000 pre-stage 1 discount) The FCA’s action took effect on 21 June 2019 and a copy of the Final Notice is displayed on the FCA's web site here: https://fca.org.uk/publication/final-notices/bank-of-scotland-2019.pdf  

On 19 November 2014, the PRA issued a Final Notice to the Royal Bank of Scotland Plc, National Westminster Bank Plc and Ulster Bank Ltd (together the “Banks”), which imposed on the Banks, pursuant to section 206 of the Financial Services and Markets Act 2000, a financial penalty of £14,000,000 for breach of Principle 3 of the FSA’s (and after 1 April 2013, the PRA’s) Principles for Businesses (now the PRA’s Fundamental Rule 6).  The financial penalty was imposed on the basis that, during the period between 1 August 2010 and 10 July 2012, the Banks’ failed to meet their obligation to have adequate systems and controls to identify and manage their exposure to IT risks, in particular:  i) the RBS Group’s Technology Services function (the centralised Group IT function which provides services to the Banks) did not manage and plan changes to the RBS Group’s IT systems adequately; ii) the Technology Services Risk, Business Services Risk and Group Internal Audit (together the “The Three Lines of Defence specific to IT for the Banks through the RBS Group), did not take sufficient care to control IT risks responsibly and effectively; and  iii) the RBS Group had a limited understanding of IT operational risk. A copy of the Final Notice for RBS can be found on the Bank of England website and can be accessed using the following link: http://www.bankofengland.co.uk/pra/Documents/supervision/enforcementnotices/en201114.pdf.

On 25 November 2015, the Authority imposed a financial penalty of £72,069,400 on Barclays Bank plc (“Barclays”) for breaches of Principle 2 (due skill, care and diligence) between 23 May 2011 and 24 November 2014 (“the Relevant Period”).   Barclays agreed to settle at an early stage of the Authority’s investigation. Barclays therefore qualified for a 30% (Stage 1) discount under the Authority’s executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £80,542,000 on Barclays.  Barclays failed to minimise the risk of financial crime in connection with a multi-billion pound Transaction executed for ultra-high net worth politically exposed persons (the Clients). As a result of the confidentiality requirements, Barclays determined that’s its usual processes for dealing with PEPs and assessing financial crime risks were not appropriate for the Business Relationship. Instead, Barclays sought to address the financial crime risks associated with the Transaction in an ad hoc way. In doing so, Barclays did not exercise due skill, care and diligence. It failed to identify, assess and monitor any risks appropriately. Specifically, in breach of Principle 2: a)    Barclays’ front office and senior management failed adequately to oversee Barclays’ handling of the financial crime risks that were associated with the Business Relationship.  b)    Having classified the Clients as Sensitive PEPs, Barclays failed to appropriately identify and address through its due diligence processes a number of features of the Business Relationship that the Authority considers could have indicated a higher risk of financial crime. c)    Barclays did not follow its standard procedures that it would normally follow for establishing relationships with Sensitive PEPs or put acceptable alternative procedures in their place.   d)    Barclays failed to establish adequately the purpose and nature of the Transaction and did not sufficiently corroborate the Clients’ stated source of wealth and source of funds for the Transaction.   e)    Barclays failed to monitor appropriately the financial crime risks associated with the Business Relationship on an ongoing basis. f)    Barclays failed to maintain adequate records of the due diligence it undertook in connection with the Business Relationship and to ensure that those records were readily identifiable and capable of retrieval. As a consequence, Barclays’ threatened confidence in the UK financial system and failed to mitigate the risk to society of financial crime. A copy of the Final Notice is displayed on the Authority’s web site and can be accessed using the following link: http://www.fca.org.uk/your-fca/documents/final-notices/2015/barclays-bank-plc-nov-2015  

On 4 June 2015, the Authority imposed a financial penalty of £117,430,600 on Lloyds Bank plc, Bank of Scotland plc and Black Horse Limited (LBG) for breaches of Principle 6 (Customers' interests) of the Authority's Principles for Businesses (the Principles). LBG agreed to settle at an early stage of the Authority's investigation. LBG therefore qualified for a 30% (Stage 1) discount under the Authority's executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £167,758,035 on LBG. Between 5 March 2012 and 28 May 2013 (the Relevant Period) LBG breached Principle 6 by failing to pay due regard to the interests of its customers, and by failing to treat them fairly when handling complaints from customers who had purchased Payment Protection Insurance ('PPI'). During the Relevant Period LBG assessed customer complaints relating to in excess of 2.3 million PPI policies and rejected 37% of those complaints. In particular: (a) LBG's complaint assessment process included guidance to complaint handlers which directed them to assume that LBG's PPI sales processes were 'compliant and robust', unless notified to the contrary.  This was described to complaint handlers as the 'Overriding Principle'.  The Overriding Principle was unfair to customers because: (i) there was a risk that it created a default assumption that LBG had not mis-sold the PPI policy that an individual customer was complaining about; (ii) customers may not have had the opportunity to provide evidence to enable the complaint handler to reach a fair outcome; and (iii) in some situations it affected the judgements made by complaint handlers who relied on it to rebut credible customer testimony and to not fully investigate customer complaints. (b) LBG failed to take into account information about Sales Process Failings identified from Root Cause Analysis when assessing complaints.  This was unfair to customers because it meant: (i) LBG failed to give balanced consideration to all available evidence; and (ii) the unfair effects of the Overriding Principle were compounded because this evidence was not available to complaint handlers to counter the assumption, created by the Overriding Principle, that LBG had not mis-sold the PPI policy that an individual customer was complaining about. (c) Where LBG complaint handlers relied on the Overriding Principle to reject customer complaints instead of investigating the actual circumstances of the complaint, there was a risk that the final decision letters did not accurately reflect the complaint handler's assessment of the complaint and reasons for the rejection.  This was unfair as it may have dissuaded some customers with valid complaints from providing further information to LBG to challenge the decision, or referring their complaint to the Financial Ombudsman Service. (d) The above failings resulted in a significant number of customer complaints being unfairly rejected. A copy of the Final Notice is displayed on the Authority's web site and can be accessed using the following link: http://fca.org.uk/static/fca/documents/lloyds-banking-group-2015.pdf

On 4 June 2015, the Authority imposed a financial penalty of £117,430,600 on Lloyds Bank plc, Bank of Scotland plc and Black Horse Limited (LBG) for breaches of Principle 6 (Customers' interests) of the Authority's Principles for Businesses (the Principles). LBG agreed to settle at an early stage of the Authority's investigation. LBG therefore qualified for a 30% (Stage 1) discount under the Authority's executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £167,758,035 on LBG. Between 5 March 2012 and 28 May 2013 (the Relevant Period) LBG breached Principle 6 by failing to pay due regard to the interests of its customers, and by failing to treat them fairly when handling complaints from customers who had purchased Payment Protection Insurance ('PPI'). During the Relevant Period LBG assessed customer complaints relating to in excess of 2.3 million PPI policies and rejected 37% of those complaints. In particular: (a) LBG's complaint assessment process included guidance to complaint handlers which directed them to assume that LBG's PPI sales processes were 'compliant and robust', unless notified to the contrary.  This was described to complaint handlers as the 'Overriding Principle'.  The Overriding Principle was unfair to customers because: (i) there was a risk that it created a default assumption that LBG had not mis-sold the PPI policy that an individual customer was complaining about; (ii) customers may not have had the opportunity to provide evidence to enable the complaint handler to reach a fair outcome; and (iii) in some situations it affected the judgements made by complaint handlers who relied on it to rebut credible customer testimony and to not fully investigate customer complaints. (b) LBG failed to take into account information about Sales Process Failings identified from Root Cause Analysis when assessing complaints.  This was unfair to customers because it meant: (i) LBG failed to give balanced consideration to all available evidence; and (ii) the unfair effects of the Overriding Principle were compounded because this evidence was not available to complaint handlers to counter the assumption, created by the Overriding Principle, that LBG had not mis-sold the PPI policy that an individual customer was complaining about. (c) Where LBG complaint handlers relied on the Overriding Principle to reject customer complaints instead of investigating the actual circumstances of the complaint, there was a risk that the final decision letters did not accurately reflect the complaint handler's assessment of the complaint and reasons for the rejection.  This was unfair as it may have dissuaded some customers with valid complaints from providing further information to LBG to challenge the decision, or referring their complaint to the Financial Ombudsman Service. (d) The above failings resulted in a significant number of customer complaints being unfairly rejected. A copy of the Final Notice is displayed on the Authority's web site and can be accessed using the following link: http://fca.org.uk/static/fca/documents/lloyds-banking-group-2015.pdf

The Financial Conduct Authority (the “FCA”) has imposed a financial penalty of £284,432,000 on Barclays Bank Plc, FRN 122702, 1 Churchill Place, London, E14 5HP.   The FCA’s action took effect on 20 May 2015 and a copy of the Final Notice, which sets out the reason for the action, is displayed on the FCA's web site and can be accessed using the following link:   https://www.fca.org.uk/your-fca/documents/final-notices/2015/barclays-bank-plc The reason for this action is that Barclays failed properly to control its London voice trading operations in its G10 spot FX; Emerging Market spot FX and G10 and EM FX options businesses and its G10 and EM FX sales operations associated with its FX business.  

On 24 February 2015, the Authority imposed a financial penalty of £17,607,000 on Aviva Investors Global Services Limited (Aviva Investors) for breaches of Principles 3 (Management and Control) and 8 (Conflicts of Interest) of the Authority's Principles for Businesses (the Principles) in the FCA's Handbook, as well as for breaches of the COBs rules. Aviva Investors agreed to settle at an early stage of the Authority's investigation. It therefore qualified for a 30% (Stage 1) discount under the Authority's executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £25,152,900 on Aviva Investors. Aviva Investors failed to properly implement systems and controls adequate to control the conflicts of interest created by the side-by-side management of hedge funds with high performance fees and other funds with lower performance fees. The combination of a poor control environment and the incentive to favour their interests over those of customers led to the risk that traders would cherry pick. In May of 2013, Aviva Investors found evidence that two traders had delayed booking trades, improperly allocated trades and cherry picked. £135,000,000 in compensation was paid to eight funds that Aviva Investors identified may have been impacted by the poor control environment. A copy of the Final Notice is displayed on the Authority's web site and can be accessed using the following link: http://www.fca.org.uk/your-fca/documents/final-notices/2015/aviva-investors

The Financial Conduct Authority (FCA) imposed a fine on the Royal Bank of Scotland Plc, (RBS) National Westminster Bank Plc (NatWest) and Ulster Bank Ltd (Ulster Bank) (together the Banks) £42 million for IT failures which occurred in June 2012 and meant that the Banks' customers could not access banking services. The Banks breached Principle 3 of the FCA Principles for Business in that they failed to take reasonable care to organise and control their affairs responsibly and effectively, with adequate risk management systems. The Banks agreed to settle at an early stage of the Authority's investigation and therefore qualified for a 30% (Stage 1) discount under the FCA's executive settlement procedures. Were it not for this discount the FCA would have imposed a financial penalty of £60,000,000 on the Banks. The actual cause of the IT incident was a software compatibility problem with the underlying cause being the Banks' failure to put in place adequate systems and controls to identify and manage their exposure to IT risks. The IT failure affected over 6.5 million customers in the United Kingdom for several weeks. Over the course of that period customers could not use online banking facilities to access their accounts or obtain accurate account balances from ATMs; customers were unable to make timely mortgage payments; customers were left without cash in foreign countries; the Banks applied incorrect credit and debit interest to customers' accounts and produced inaccurate bank statements; and some organisations were unable to meet their payroll commitments or finalise their audited accounts.

The Financial Conduct Authority (the FCA) imposed a financial penalty of £217,000,000 on The Royal Bank of Scotland plc (RBS) of 26 St. Andrew Square, Edinburgh, EH2 2YB. The FCA's action took effect on 11 November 2014 and a copy of the Final Notice, which sets out the reasons for the action is displayed on the FCA's website and can be accessed via the following link: http://www.fca.org.uk/static/documents/final-notices/final-notice-rbs.pdf The foreign exchange market (FX market) is one of the largest and most liquid markets in the world. Its integrity is of central importance to the UK and global financial systems. Over a period of five years, RBS failed properly to control its London voice trading operations in the G10 spot FX market, with the result that traders in this part of its business were able to behave in a manner that put RBS's interests ahead of the interests of its clients, other market participants and the wider UK financial system. The FCA expects firms to identify, assess and manage appropriately the risks that their business poses to the markets in which they operate and to preserve market integrity, irrespective of whether or not those markets are regulated. The FCA also expects firms to promote a culture which requires their staff to have regard to the impact of their behaviour on clients, other participants in those markets and the financial markets as a whole. RBS's failure adequately to control its London voice trading operations in the G10 spot FX market is extremely serious. The importance of this market and its widespread use by market participants throughout the financial system means that misconduct relating to it has potentially damaging and far-reaching consequences for the G10 spot FX market and financial markets generally. The failings described in the Final Notice undermine confidence in the UK financial system and put its integrity at risk. RBS breached Principle 3 of the FCA's Principles for Businesses in the period from 1 January 2008 to 15 October 2013 (the Relevant Period) by failing to take reasonable care to organise and control its affairs responsibly and effectively with adequate risk management systems in relation to G10 spot FX voice trading in London. References in the Final Notice to RBS's G10 spot FX trading business refer to its relevant voice trading desk based in London. During the Relevant Period, RBS did not exercise adequate and effective control over its G10 spot FX trading business. RBS relied primarily upon its front office FX business to identify, assess and manage risks arising in that business. The front office failed adequately to discharge these responsibilities with regard to obvious risks associated with confidentiality, conflicts of interest and trading conduct. The right values and culture were not sufficiently embedded in RBS's G10 spot FX trading business, which resulted in it acting in RBS's own interests as described in the Final Notice without proper regard for the interests of its clients, other market participants or the wider UK financial system. The lack of proper control by RBS over the activities of its G10 spot FX traders in London undermined market integrity and meant that misconduct went undetected for a number of years. RBS's control and risk functions failed to challenge effectively the management of these risks in the G10 spot FX trading business. RBS's failings in this regard allowed the following behaviours to occur in its G10 spot FX trading business: (1) Attempts to manipulate the WMR and the ECB fix rates, alone or in collusion with traders at other firms, for RBS's own benefit and to the potential detriment of certain of its clients and/or other market participants; (2) Attempts to trigger clients' stop loss orders for RBS's own benefit and to the potential detriment of those clients and/or other market participants; and (3) Inappropriate sharing of confidential information with traders at oter firms, including specific client identities and, as part of (1) and (2) above, information about clients' orders. These failings occurred in circumstances where certain of those responsible for managing front office matters were aware of and/or at times involved in behaviours described above. They also occurred despite the fact that risks around confidentiality were highlighted when RBS received client complaints in October 2010 and January 2012, and, in November 2011, a trader questioned whether it was inappropriate to share information with traders at other firms or with clients. RBS was on notice about misconduct associated with LIBOR / EURIBOR during the Relevant Period. The FCA issued a Final Notice and a financial penalty against RBS on 6 February 2013 in relation to benchmark setting for LIBOR. Against this background, RBS engaged in an extensive remediation programme across its businesses in response to LIBOR / EURIBOR, including taking important steps to promote changes to culture and values. Despite these improvements, the steps taken during the Relevant Period in its G10 spot FX trading business did not adequately address the root causes that gave rise to failings described in the Final Notice. The FCA has considered the nature and extent of co-operation provided by RBS during the course of its investigation. The FCA acknowledges that RBS acted promptly in bringing the behaviours referred to in the Final Notice to the FCA's attention. RBS has also provided extremely good co-operation and taken significant steps to assist the FCA in its investigation. RBS is continuing to undertake remedial action and has committed significant resources to improving the business practices and associated controls relating to its FX operations. The FCA recognises the work already undertaken by RBS in this regard. The Final Notice relates solely to RBS's conduct in its G10 spot FX trading business in London. It makes no criticism of any entities other than the firms engaged in misconduct as described in the Final Notice.

On 23 September 2014, the Authority imposed a financial penalty of £37,745,000 on Barclays Bank plc (Barclays) for breaches of Principles 3 (Management and Control) and 10 (Clients' Assets) of the Authority's Principles for Businesses (the Principles) and associated Client Asset Rules (CASS) in the FCA's Handbook. Barclays agreed to settle at an early stage of the Authority's investigation. Barclays therefore qualified for a 30% (Stage 1) discount under the Authority's executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £53,921,619 on Barclays. Barclays failed to adequately protect approximately £16.5 billion of clients' safe custody assets between 1 November 2007 and 24 January 2012 (the Relevant Period). The Authority found significant deficiencies in Barclays' systems and controls in the opening, on-going operation and monitoring of external safe custody accounts, and failures in arranging adequate protection for certain of the safe custody assets for which it was responsible. Specifically, in relation to its safe custody assets arrangements in its Investment Banking Division, during the Relevant Period Barclays breached: a) Principle 3: by failing to take reasonable care to organise and control its affairs responsibly with adequate risk management systems in order to ensure that it: i. had in place adequate organisational arrangements in respect of safe custody assets; and ii. implemented and maintained adequate policies and procedures to detect and manage its safe custody asset risks. b) Principle 10: by failing to arrange adequate protection for safe custody assets when it was responsible for them. Barclays' failings also meant that it breached CASS 1A.2.8R, 6.2.1R, 6.2.2R, 6.3.1R, 6.5.1R, 6.5.2R and 6.5.6R. As a consequence of Barclays' breaches its' clients were at risk of incurring extra costs, lengthy delays or losing their assets if Barclays had become insolvent during the Relevant Period. A copy of the Final Notice is displayed on the Authority's web site and can be accessed using the following link: http://www.fca.org.uk/your-fca/documents/final-notices/2014/barclays-bank-plc-sept-2014

On 28 July 2014, the FCA imposed on Lloyds Bank plc and Bank of Scotland plc a financial penalty of £105,000,000 (split evenly between the two firms and discounted from £150,000,000 for early settlement) in respect of breaches of Principle 3 and 5 of the FCA's Principles for Businesses. The Firms committed misconduct by breaching Principle 5 and Principle 3 of the Authority's Principles for Businesses through manipulating submissions to two benchmark reference rates, the Repo Rate and LIBOR, in order to seek to manipulate those rates. The Final Notice can be found at the following link. http://www.fca.org.uk/static/documents/final-notices/lloyds-bank-of-scotland.pdf

On 28 July 2014, the FCA imposed on Lloyds Bank plc and Bank of Scotland plc a financial penalty of £105,000,000 (split evenly between the two firms and discounted from £150,000,000 for early settlement) in respect of breaches of Principle 3 and 5 of the FCA's Principles for Businesses. The Firms committed misconduct by breaching Principle 5 and Principle 3 of the Authority's Principles for Businesses through manipulating submissions to two benchmark reference rates, the Repo Rate and LIBOR, in order to seek to manipulate those rates. The Final Notice can be found at the following link. http://www.fca.org.uk/static/documents/final-notices/lloyds-bank-of-scotland.pdf

1. On 23 May 2014, the FCA imposed a penalty of £26,033,500 on Barclays Bank PLC (Barclays) for breaches of Principles 3 and 8, for failing to manage conflicts of interest, as well as systems and controls failings in relation to the London Gold Fixing. Were it not for the Stage 1 settlement discount, the penalty would have been £37,190,800. Conflicts of Interest 2. Between 7 June 2004 and 21 March 2013 (Relevant Period), Barclays breached Principle 8 by failing to adequately manage certain conflicts of interest between itself and its customers. In particular, Barclays failed to adequately manage the inherent conflict of interest that existed from (i) Barclays participating in the Gold Fixing and contributing to the price fixed during the Gold Fixing, while at the same time also (ii) selling to customers options products that referenced, and were dependent on, the price of gold fixed in the Gold Fixing, by not putting in place policies, procedures, systems and training in relation to the Gold Fixing which would have adequately enabled its staff to properly identify and manage the risks arising from this inherent conflict of interest. 3. Barclays' lack of specific training and guidance, given the absence of clear and sufficiently-tailored policies and procedures with respect to the Gold Fixing, meant that Barclays' personnel (including supervisors) may have been unaware of which conflicts of interest they should pay particular attention to in relation to the Gold Fixing. 4. On 28 June 2012 the risk created by Barclays' failure to adequately manage the inherent conflict of interest was realised when a Barclays trader participated actively in the 3:00 p.m. Gold Fixing even though he was responsible for risk-managing an options contract that was dependent on the price of gold fixed in that Gold Fixing. The Barclays trader placed orders with intention of increasing the likelihood that the price of gold would fix below a certain level, preferring his interests over those of a customer. Systems and controls failings 5. For the following reasons, Barclays breached Principle 3 by failing to take reasonable care to organise and control its affairs responsibly and effectively with adequate risk management systems in relation to the London Gold Fixing process: (i) During the Relevant Period Barclays failed to create or implement adequate policies or procedures to properly manage the way in which Barclays' traders participated in the Gold Fixing; (ii) During the Relevant Period Barclays failed to provide adequate specific training to Precious Metals Desk staff in relation to their participation in the Gold Fixing; and (iii) During the Relevant Period Barclays failed to create systems and reports that allowed for adequate monitoring of its traders' activity in connection with the Gold Fixing. The systems and reports did not formally record orders placed by traders in the Gold Fixing until 5 February 2013 and did not identify Gold Fixing transactions separately from general gold spot trades until 21 March 2013.

On the 24 February 2014 the Financial Conduct Authority (the FCA) imposed on Forex Capital Markets Limited and FXCM Securities Limited (together FXCM Ltd) a financial penalty of £4,000,000 in respect of Breaches of Principle 6 and Principle 11 of the FCA's Principles for Businesses. FXCM Limited settled at an early stage of the Authority's investigation and therefore qualified for a 20% (Stage 2) discount under the Authority's executive settlement procedures. Were it not for the discount, the Authority would have imposed a fine of £5,000,000. Principle 6 breach Between 1 August 2006 and 17 December 2010, FXCM Ltd treated its customers unfairly as it failed to pass on favourable price movements to its customers and instead the FXCM group retained the benefit, reducing the customers' ability to profit from trading in rolling spot forex trades. Principle 11 breach Between July 2010 and August 2011, FXCM Ltd failed to be sufficiently open and co-operative and disclose to the Authority information of which it would reasonably expect notice, namely: 1. the fact that in July 2010 US authorities had begun to investigate FXCM Group company in relation FXCM LLC's (US sister company) order execution policies; and 2. the subsequent decision by the FXCM Group company to settle with the US authorities and pay redress to its US customers who had suffered detriment due to asymmetric pricing. A copy of the Final Notice, which sets out the reason for the action, is displayed on the FCA's web site and can be accessed using the following link: http://www.fca.org.uk/your-fca/documents/final-notices/2014/forex-capital-markets-limited.

On 10 December 2013 the FCA imposed a combined financial penalty of £28,038,800 on Lloyds TSB Bank plc and Bank of Scotland plc (the Firms) for breaching Principle 3 of the FCA's Principles for Businesses. The breaches occurred between 1 January 2010 and 31 March 2012 (the Relevant Period). The Firms settled at an early stage of the FCA's investigation. They therefore qualified for a 20% (Stage 2) discount under the FCA's executive settlement procedures. Were it not for this discount, the penalty would have been £35,048,500. The penalty is due to serious failings in the Firms' systems and controls governing financial incentives given to sales staff in LTSB, Halifax and BOS branches. These staff sold protection and investment products to customers on an advised basis (advisers). Advisers' incentives included higher risk features, such as variable salaries and bonus thresholds (giving disproportionate rewards for marginal sales). It meant advisers who met sales targets qualified for substantial salary rises and bonuses, while advisers who did not faced salary reductions. There was also a significant bias towards sales of protection products. There was, therefore, a significant risk that, if not adequately controlled, advisers would make inappropriate sales to customers to reach salary and bonus thresholds. The Firms' systems and controls were not appropriately focused on these specific higher risk features. In particular, the Firms failed to supplement routine business monitoring with appropriately risk-based monitoring that also focused on the risk profile of advisers. Further, while advisers had to meet certain competency standards to be eligible for salary rises and bonuses, this control was flawed as advisers could meet the standards even where the Firms had identified issues with their sales. The Firms' failure to manage and control adequately the risks from advisers' incentives derived from serious deficiencies in their governance over this area. There was a collective failure of the Firms' senior management to identify sufficiently advisers' incentives as a key area of risk requiring specific and robust oversight. The Firms are carrying out a review of sales conducted by higher risk advisers during the Relevant Period, and will provide redress to customers where appropriate.

On 10 December 2013 the FCA imposed a combined financial penalty of £28,038,800 on Lloyds TSB Bank plc and Bank of Scotland plc (the Firms) for breaching Principle 3 of the FCA's Principles for Businesses. The breaches occurred between 1 January 2010 and 31 March 2012 (the Relevant Period). The Firms settled at an early stage of the FCA's investigation. They therefore qualified for a 20% (Stage 2) discount under the FCA's executive settlement procedures. Were it not for this discount, the penalty would have been £35,048,500. The penalty is due to serious failings in the Firms' systems and controls governing financial incentives given to sales staff in LTSB, Halifax and BOS branches. These staff sold protection and investment products to customers on an advised basis (advisers). Advisers' incentives included higher risk features, such as variable salaries and bonus thresholds (giving disproportionate rewards for marginal sales). It meant advisers who met sales targets qualified for substantial salary rises and bonuses, while advisers who did not faced salary reductions. There was also a significant bias towards sales of protection products. There was, therefore, a significant risk that, if not adequately controlled, advisers would make inappropriate sales to customers to reach salary and bonus thresholds. The Firms' systems and controls were not appropriately focused on these specific higher risk features. In particular, the Firms failed to supplement routine business monitoring with appropriately risk-based monitoring that also focused on the risk profile of advisers. Further, while advisers had to meet certain competency standards to be eligible for salary rises and bonuses, this control was flawed as advisers could meet the standards even where the Firms had identified issues with their sales. The Firms' failure to manage and control adequately the risks from advisers' incentives derived from serious deficiencies in their governance over this area. There was a collective failure of the Firms' senior management to identify sufficiently advisers' incentives as a key area of risk requiring specific and robust oversight. The Firms are carrying out a review of sales conducted by higher risk advisers during the Relevant Period, and will provide redress to customers where appropriate.

On 15 February 2013 the FSA imposed a financial penalty of £4,315,000 on Lloyds TSB Bank Plc, Lloyds TSB Scotland Plc and Bank of Scotland Plc (together Lloyds Banking Group, LBG) by way of a single Final Notice. The penalty relates to LBG's failure to pay redress promptly to PPI complainants between 5 May 2011 and 9 March 2012 (the Relevant Period). LBG agreed to settle at an early stage of the FSA's investigation. It therefore qualified for a 30% (Stage 1) discount under the FSA's executive settlement procedures. Were it not for this discount, the FSA would have imposed a financial penalty of £6,164,327 on LBG. During the Relevant Period, LBG sent 582,206 decision letters to PPI complainants, agreeing to pay redress to them. In order to comply with its regulatory obligation to pay redress promptly, LBG aimed to make payment within 28 days of these decision letters. However, LBG failed to do so in up to 140,209 (24%) cases. 24,589 (4%) cases inadvertently dropped out of LBG's PPI redress payments process, and remedial action had to be taken subsequently to ensure those payments were made. These payments were identified as a result of customers telephoning LBG to chase payments and media attention. Following this, LBG carried out an investigation. LBG breached the FSA's Principles and rules by failing to: 1) take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems (Principle 3); and 2) comply promptly with offers of redress which LBG had made and which had been accepted by PPI complainants (DISP 1.4.1R(5)). In particular: (1) LBG failed to establish an adequate process for preparing redress payments to send to PPI complainants. In addition to a lack of initial planning by LBG, LBG's staff engaged on the redress process did not have the collective knowledge and experience to ensure that the process worked properly; (2) As a result, there were a number of serious deficiencies in LBG's PPI payment preparation framework. These deficiencies related to the way LBG processed data relating to customers' PPI redress payments before this data was sent to the separate payments area. LBG's system was heavily reliant on manual processes and data transfers which could not cope with high volumes of PPI payments of varying complexity. There was ineffective tracking of cases through the process and a lack of co-ordination between multiple redress sites. Customers' payment details were subjected to poor data governance and there was a lack of controls, including no control at all for the reconciliation of PPI payments. In addition, parts of the process were under resourced; (3) LBG failed to monitor effectively whether it was making all payments of PPI redress promptly. Nor did it gather sufficient management information to enable it to identify, in a timely manner, the full nature and extent of the payment failings; and (4) LBG's risk governance framework in respect of its process for preparing redress payments to send to PPI complainants was ineffective. An effective risk function would have assisted LBG to identify and address, in a timely way, the systems and controls deficiencies in its process. As a result of these failings, up to 140,209 (24%) customers whose complaints were upheld in full or in part were not paid redress within 28 days of LBG's decision letters to customers. Approximately 87,000 (15%) of these customers had to wait over 45 days, 56,000 (9.7%) over 60 days, 29,000 (5%) over 90 days and some 8,800 (1%) over 6 months (these have subsequently been paid, other than where they involve exceptional customer circumstances and are still being addressed). Although LBG has taken steps to ensure that these customers have not been financially disadvantaged by the delays by paying interest at 8% per annum on the outstanding redress figure where appropriate, the average redress due to each customer was £2,733 and customers wereonvenienced by the delay. When customers telephoned LBG to enquire about the non-receipt of the payments they had been expecting, the deficiencies in its processes meant that LBG was unable to fast-track the payment to the customer, inform them when payment would be made, or explain why it had been delayed. LBG has since completed a comprehensive reconciliation of its PPI redress payments to ensure that all customers due PPI redress have been correctly paid and compensated for any delay in receiving their payment. Once the deficiencies in its process had been identified, LBG quickly conducted the reconciliation review and improved its processes to address the failings identified in this notice, including the rapid implementation of a PPI payment validation tool intended to ensure that any future issues regarding delayed payments are immediately identified and corrected.

On 15 February 2013 the FSA imposed a financial penalty of £4,315,000 on Lloyds TSB Bank Plc, Lloyds TSB Scotland Plc and Bank of Scotland Plc (together Lloyds Banking Group, LBG) by way of a single Final Notice. The penalty relates to LBG's failure to pay redress promptly to PPI complainants between 5 May 2011 and 9 March 2012 (the Relevant Period). LBG agreed to settle at an early stage of the FSA's investigation. It therefore qualified for a 30% (Stage 1) discount under the FSA's executive settlement procedures. Were it not for this discount, the FSA would have imposed a financial penalty of £6,164,327 on LBG. During the Relevant Period, LBG sent 582,206 decision letters to PPI complainants, agreeing to pay redress to them. In order to comply with its regulatory obligation to pay redress promptly, LBG aimed to make payment within 28 days of these decision letters. However, LBG failed to do so in up to 140,209 (24%) cases. 24,589 (4%) cases inadvertently dropped out of LBG's PPI redress payments process, and remedial action had to be taken subsequently to ensure those payments were made. These payments were identified as a result of customers telephoning LBG to chase payments and media attention. Following this, LBG carried out an investigation. LBG breached the FSA's Principles and rules by failing to: 1) take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems (Principle 3); and 2) comply promptly with offers of redress which LBG had made and which had been accepted by PPI complainants (DISP 1.4.1R(5)). In particular: (1) LBG failed to establish an adequate process for preparing redress payments to send to PPI complainants. In addition to a lack of initial planning by LBG, LBG's staff engaged on the redress process did not have the collective knowledge and experience to ensure that the process worked properly; (2) As a result, there were a number of serious deficiencies in LBG's PPI payment preparation framework. These deficiencies related to the way LBG processed data relating to customers' PPI redress payments before this data was sent to the separate payments area. LBG's system was heavily reliant on manual processes and data transfers which could not cope with high volumes of PPI payments of varying complexity. There was ineffective tracking of cases through the process and a lack of co-ordination between multiple redress sites. Customers' payment details were subjected to poor data governance and there was a lack of controls, including no control at all for the reconciliation of PPI payments. In addition, parts of the process were under resourced; (3) LBG failed to monitor effectively whether it was making all payments of PPI redress promptly. Nor did it gather sufficient management information to enable it to identify, in a timely manner, the full nature and extent of the payment failings; and (4) LBG's risk governance framework in respect of its process for preparing redress payments to send to PPI complainants was ineffective. An effective risk function would have assisted LBG to identify and address, in a timely way, the systems and controls deficiencies in its process. As a result of these failings, up to 140,209 (24%) customers whose complaints were upheld in full or in part were not paid redress within 28 days of LBG's decision letters to customers. Approximately 87,000 (15%) of these customers had to wait over 45 days, 56,000 (9.7%) over 60 days, 29,000 (5%) over 90 days and some 8,800 (1%) over 6 months (these have subsequently been paid, other than where they involve exceptional customer circumstances and are still being addressed). Although LBG has taken steps to ensure that these customers have not been financially disadvantaged by the delays by paying interest at 8% per annum on the outstanding redress figure where appropriate, the average redress due to each customer was £2,733 and customers wereonvenienced by the delay. When customers telephoned LBG to enquire about the non-receipt of the payments they had been expecting, the deficiencies in its processes meant that LBG was unable to fast-track the payment to the customer, inform them when payment would be made, or explain why it had been delayed. LBG has since completed a comprehensive reconciliation of its PPI redress payments to ensure that all customers due PPI redress have been correctly paid and compensated for any delay in receiving their payment. Once the deficiencies in its process had been identified, LBG quickly conducted the reconciliation review and improved its processes to address the failings identified in this notice, including the rapid implementation of a PPI payment validation tool intended to ensure that any future issues regarding delayed payments are immediately identified and corrected.