Regal Regulatory Brief — 15 October 2026
Regal 38i83 Team | Regal Regulatory Brief | Edition: 15 October 2026
This Week at a Glance
FCA enforcement action: Three individuals arrested in a major joint FCA/NCA insider dealing operation on 13 October; two financial advisers pleaded guilty to fraud causing £2 million in client losses. (FCA, 13 October 2026)
Motor finance redress timeline confirmed: The FCA confirmed the Upper Tribunal will hear legal challenges to its motor finance compensation scheme from 16 to 26 February 2027. The scheme is partially suspended; firms must continue preparing. (FCA, 13 October 2026)
CP26/35 launched: Minimum 90-day notice period proposed for investors in non-UCITS retail schemes holding illiquid assets such as property. Feedback closes 11 December 2026. (FCA, 8 October 2026)
Compliance culture review: An FCA survey of 411 corporate finance firms found significant gaps in compliance programme design, including missing breach registers, weak whistleblowing arrangements and poor management reporting. (FCA, 8 October 2026)
Crispin Odey Final Notice: A £1,529,374 penalty and prohibition order were issued following the Upper Tribunal's finding that he lacked integrity. (FCA, 30 September 2026)
FCA Developments
CP26/35: fair redemption terms for illiquid funds. On 8 October 2026 the FCA published CP26/35 proposing that fund managers of non-UCITS retail schemes (NURS) investing in inherently illiquid assets must apply a minimum 90-day investor notice period for redemptions. Existing funds have two years to comply and must give investors at least one year's notice of any change. The proposals bring the UK into line with emerging international liquidity standards. Feedback closes 11 December 2026. (FCA, 8 October 2026)
Compliance functions in corporate finance firms. An FCA blog on 8 October 2026 reported findings from a survey of 411 firms, receiving 382 responses: 63% have compliance functions with additional business responsibilities, creating conflicts of interest; significant numbers lack breach registers, whistleblowing arrangements and management reporting. The FCA will engage further with selected firms and expects all firms to reflect on and improve their arrangements. Firms subject to Consumer Duty governance requirements should note the FCA's emphasis on compliance culture as a conduct obligation, not merely an administrative one. (FCA, 8 October 2026)
FOS chair and whistleblowing review. Liam Coleman was confirmed as permanent FOS chair on 9 October 2026 for a three-year term, having served as interim chair for the past year. Separately, the FCA's 6 October blog reported a 22% increase in whistleblowing reports in 2025/26, with 1,252 reports closed and 42% leading to direct action. An independent non-executive director has been asked to review the FCA's handling of one specific case, with findings expected early 2027. (FCA, 9 October 2026; FCA, 6 October 2026)
AML/CTF and Financial Crime
FCA insider dealing operation: three arrested. On 13 October 2026 the FCA and the National Crime Agency conducted a joint operation against a suspected organised criminal group engaged in insider dealing and money laundering. Three individuals were arrested following searches at five premises in London and Manchester; more than 30 devices were seized. The FCA secured four insider dealing convictions in 2025/26, including two sentences totalling 11 years, and fined 12 people £1.77 million for market abuse offences. (FCA, 13 October 2026)
Nexus IFA fraud: two plead guilty. Two individuals pleaded guilty at Portsmouth Crown Court on 12 October 2026 to defrauding four clients of £2 million between January 2019 and January 2023 and to using false instruments; one admitted a money laundering offence. The FCA will seek confiscation proceedings under the Proceeds of Crime Act 2002. (FCA, 13 October 2026)
Safeguarding and Payment Services
PS25/12: ongoing compliance obligations. The FCA's updated safeguarding rules under PS25/12 came into force on 7 May 2026. These obligations apply to FCA-authorised payment institutions and electronic money institutions. PRA-authorised banks are subject to separate PRA prudential requirements and are not within the PS25/12 regime. For in-scope firms, compliance requirements include daily reconciliation of relevant funds, annual safeguarding audits, resolution planning documentation, and monthly regulatory returns under CASS 15. No new FCA publications on PS25/12 were issued this week. The HM Treasury consultation on modernising the UK payments regulatory framework closed for responses in the week of 5 October 2026; firms should monitor HM Treasury's response and any follow-on FCA consultation. (FCA PS25/12, 7 August 2025; HM Treasury, 14 July 2026)
Consumer Duty
Motor finance redress: Upper Tribunal hearing confirmed. On 13 October 2026 the FCA confirmed the Upper Tribunal will hear challenges to its motor finance compensation scheme from 16 to 26 February 2027. Three lenders, Volkswagen Financial Services, Mercedes Benz Financial Services and Crédit Agricole Auto Finance, and consumer group Consumer Voice brought the challenges. The scheme is partially suspended; the FCA has directed firms to continue progressing complaints, plan for the possibility the scheme is quashed, and maintain operational readiness within statutory timescales. Consumer Duty applies to firms that distribute or manufacture products or services to retail customers. Motor finance lenders in scope of the scheme and of Consumer Duty obligations should note the FCA's expectation of continued operational readiness regardless of the legal proceedings. No new Consumer Duty guidance was published this week. (FCA, 13 October 2026)
Enforcement and Section 166
Final Notice: Robin Crispin William Odey, £1,529,374 and prohibition. The FCA issued a Final Notice on 30 September 2026 following the Upper Tribunal's decision of 14 September, which upheld all five allegations and found Odey lacked integrity. The Tribunal found he twice dismissed Odey Asset Management's executive committee to halt a disciplinary process, demonstrated reckless disregard for governance, and lacked candour with OAM, its clients and the FCA. The penalty of £1,529,374 (reduced from £1,835,200) was payable by 14 October 2026; a prohibition order was imposed. (FCA, 30 September 2026)
2026 enforcement fines. The FCA's fines register records total penalties of £19,542,773 year-to-date. The largest single penalty was £12,993,700 issued to John Wood Group PLC in March 2026 for publishing misleading financial results. (FCA, updated 1 October 2026)
Regulatory Deadlines
Deadline | Item | Source |
11 December 2026 | Feedback closes on FCA CP26/35, fair redemption terms for NURS investing in illiquid assets (minimum 90-day notice period proposals). | FCA, 8 October 2026 |
16 to 26 February 2027 | Upper Tribunal hearing of legal challenges to FCA motor finance compensation scheme. | FCA, 13 October 2026 |
Ongoing | PS25/12: full compliance required for payment institutions and e-money institutions, daily reconciliation, annual audits, resolution packs, monthly returns (in force 7 May 2026). | FCA PS25/12, 7 August 2025 |
About Regal 38i83
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The Regal Regulatory Brief is published for information only and does not constitute legal or regulatory advice. Recipients should seek independent professional advice in relation to their specific regulatory obligations. Regal 38i83 Ltd. Company number: 11449290. Contact: info@regal38i83.com
Regal 38i83 Team | info@regal38i83.com | https://regal38i83.com
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