Why the FCA's Enforcement Transparency Matters for FATF IO3 & IO7 Effectiveness – Will Jersey and Guernsey Follow?

FORMAL ENFORCEMENT IS BEING RESERVED FOR "REAL OUTLIER CONDUCT".

• The FCA's Joint Executive Director of Enforcement, Therese Chambers, delivered a clear and welcome message [copied and linked below] this week at the IBA Anti-Corruption Conference:
• Therese Chambers said:-
• In the "vast majority" of cases, supervisory tools are the most efficient way to "get to the heart of the issue".
• Formal enforcement is being reserved for "real outlier conduct".
• This is exactly the kind of straightforward communication the market needs.
• By publicly setting out this philosophy, the FCA has done something genuinely valuable:
• It gives the regulated community predictability.
• Firms now understand the operating model: most issues will be addressed through assertive supervision and early intervention, with the full enforcement toolkit kept for the serious outliers.
• That clarity drives better behaviour and reduces unnecessary friction.
• It helps international assessors (FATF, MONEYVAL and others) understand how the UK is delivering effectiveness.

FATF IMMEDIATE OUTCOMES AND THE MONEYVAL TEST

• Concerning how the UK is delivering effectiveness, two of the most scrutinised FATF Immediate Outcomes in mutual evaluations are:-
• Immediate Outcome 3 (IO3) – Supervision:
• Assessors examine whether supervisors appropriately supervise, monitor and regulate firms commensurate with risk, and whether they use the full range of tools effectively and proportionately.
• The FCA's explicit model supervisory tools for the vast majority of cases, with formal enforcement reserved for real outliers, gives assessors clear, credible evidence of intelligent, risk-based supervision in action.
• Immediate Outcome 7 (IO7) – ML investigation and prosecution:
• Assessors look for evidence that money laundering offences (including prevention and detection laws) are properly investigated and that offenders are prosecuted and subject to effective, proportionate and dissuasive sanctions.
• A transparent enforcement philosophy helps demonstrate that the system delivers real accountability on serious cases (for example, prosecutions under Jersey's money laundering framework, including the Proceeds of Crime (Jersey) Law and related prevention and detection orders) while avoiding unnecessary escalation on lower-level issues.

JERSEY AND GUERNSEY

• For Jersey and Guernsey, being more explicit about enforcement thresholds and the circumstances in which matters progress from supervision to formal action or prosecution would help MONEYVAL assessors more easily map the jurisdictions' practices against these key outcomes.
• Both islands have worked hard on their AML/CFT/CPF frameworks and received strong overall feedback in recent MONEYVAL evaluations.
• However, the regulated community still often operates with less visibility than it should into exactly where the JFSC's and GFSC's minds are regarding enforcement and fining.
• Greater transparency here would not weaken the regulators; it would strengthen them.
• It would give firms the same kind of clarity the FCA is now providing, support a more mature compliance culture, and make it easier for assessors to see a deliberate, risk-based enforcement strategy in action.

CONCLUSION

• The FCA has demonstrated that being open about your enforcement mindset is a sign of regulatory confidence and maturity.
• Perhaps it is time for the JFSC and GFSC to consider doing the same, publicly articulating their approach to supervision versus enforcement and letting the regulated community know where their minds are on fining and public action.
• The industry would welcome it. And it would only enhance the strong international reputation both islands already enjoy.

WHAT DO YOU THINK?

• Would more explicit public guidance on enforcement priorities from the JFSC and GFSC help compliance teams and strengthen the jurisdictions' position with assessors on IO3 and IO7?

Sources / Further Reading:

• FCA Speech by Therese Chambers – "Beyond the headlines: the unseen fight against financial crime" (17 June 2026, 22ND Annual IBA Anti-Corruption Conference):
• https://www.fca.org.uk/news/speeches/beyond-headlines-unseen-fight-against-financial-crime

Beyond the headlines: the unseen fight against financial crime

Speeches First published: 17/06/2026 Last updated: 17/06/2026

Speech by Therese Chambers, joint executive director of enforcement and market oversight, delivered at the International Bar Association (IBA) Anti-Corruption Conference.

Speaker: Therese Chambers, joint executive director of enforcement and market oversightEvent: 22nd Annual IBA Anti-Corruption ConferenceDelivered: 17 June 2026 Note: This is a drafted speech and may differ from the delivered version.Reading time: 8 minutes

Key messages:

• Financial crime is becoming faster, more complex and more widespread than ever before. We are making fuller use of the tools available to us, including the credible threat of enforcement, to step in before harm escalates.  
• Enforcement is about more than just headlines. It also includes the quieter work of supervision, market oversight and proactive detection.
• A whole-system response is crucial. Regulators, law enforcement and industry need to work together to close the gaps criminals rely on. 

I’ve been practising law for over 3 decades now.

Starting out, I thought every case would be like the ones on US television: dramatic, with a big reveal and resounding outcome, all packed into a single 30-minute episode.  

But real law looks nothing like television. Hollywood doesn’t show the months, if not years, of work before we even step into a courtroom. Or the drawn-out disclosure exercises!

Like many of you, I have had cases that led to high-profile trials and newspaper headlines. Cases that exposed wrongdoing and visibly held people accountable, like:

• Fining Nationwide £44m for anti-money laundering failings.
• Securing €250m for investors from H2O Asset Management for their due diligence failures – and trying to conceal them.
• Another 7-figure fine and a ban for former Barclays CEO Jes Staley, who tried to mislead us about the nature of his relationship with Jeffrey Epstein.
• And convicting the Korfuzi siblings of insider trading, with a combined 11-year prison sentence.

Although these cases took time, they were the right response – the kind that keep the system clean and build trust. 

But running alongside this is work that, while less obvious, matters just as much: the quiet prevention of harm.  

Every day, our teams are 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. 

And working alongside firms to help them deliver good customer outcomes.

This kind of work is perpetual. And largely invisible.  

Let me give you an example.

A life sciences company was attempting to raise funding.

When we reviewed the prospectus, we realised it resembled a pump-and-dump scheme we were tracking that had already targeted other UK securities.

The proposed structure would have concentrated shares in the hands of a few bad actors, who could artificially inflate the share price through misleading online ads.

They would then cash out at the peak, leaving consumers exposed when the price suddenly collapsed.

So we stepped in and put a pause on approval.

Soon after, the company announced it was ending the fundraising entirely. We had cut harm off at the root.

And yet… there was no press release. No headline.

Does that concern you? Or does it reassure you?

Changing threat, changing model

I think it should do both.

The threat we are facing is more complex than ever. 

Technology, including AI, is accelerating the pace and scale of financial crime. 

And we have to give these criminals their dues: they are prolific innovators. 

They’re not standing still, waiting for us to catch up. They’re moving faster than traditional law enforcement can respond. 

Making the threats we are up against cheap, fast and invisible.

And while essential, traditional enforcement is expensive, slow and highly visible.

That imbalance – that gap – is where harm occurs. And if we are going to close it, we need to adapt.  

Law enforcement has the 4 Ps: 

• Prevent.
• Pursue.
• Protect.
• Prepare.

We’re doing a lot of pursuing: 42 outcomes in 2024, another 38 in 2025, and as of June 1st, 18 so far this year.

And we’re moving faster than ever before.

Since July 2024, 10 investigations have reached a public outcome within 16 months or less.

It’s promising to see whistleblowing disclosures up 20% in the past year – helping us to stop harm earlier.

But we regulate more than 40,000 firms, supervise 1,720 listed issuers, and receive 35m transaction reports every day. It’s impossible to pursue all instances of harm in the same way.

We have to do more of the ‘prevent, protect and prepare’.

Cutting off harm at the root

So we are being more visible about the ways we fight crime and tackle harm.

That includes bringing to light the no-man’s land between ‘doing nothing’ and launching a full enforcement investigation.

We are increasingly using the credible threat of enforcement to do so. Driving earlier intervention with our supervisory tools, market oversight and proactive detection. 

And doing it faster – in weeks, rather than months or years.  

The life sciences company I mentioned earlier terminated fundraising less than 2 weeks after we paused the prospectus.

That’s not a coincidence.  

Had we approved the prospectus, it would have left investors at risk of significant losses, and undermined the confidence and integrity of the market.  

But it isn’t always a rogue operator working behind the scenes.  

When we looked under the bonnet of an authorised firm providing electronic money services, we found exactly the kind of harm we exist to prevent.

Inadequate client files, high-risk clients downgraded wrongly and without explanation, and others simply waved through – including one subject to a multi-million dollar fine.  

We imposed an Own Initiative Requirement (OIREQ): no new customers or funds, and a return of what they were holding, effective immediately.  

The firm didn’t challenge our decision, and we were able to stop the harm quickly and quietly. No fine or prosecution needed.

OIREQs are so effective because they’re immediate. We can freeze assets, require firms to pay redress, stop them taking on new clients or shut them down entirely, at speed.  

But an OIREQ sits at one end of a much broader spectrum. 

Sometimes it’s a conversation, letter or targeted visit.  

When a cryptoasset firm repeatedly failed to display the right risk warnings, we engaged until the issues were fixed.  

A feedback letter and voluntary requirement were all it took to shut down a claims management company’s misleading motor finance promotions.  

In most cases, that kind of early intervention is enough.  

Further along the spectrum, we have skilled person reviews.  

In one recent case, we found serious weaknesses in a firm’s financial crime controls.

Rather than move straight to enforcement, we agreed a voluntary requirement – no new clients until the firm fixed the issues. That gave them time to make things right and protected existing customers.

And other times, we combine our tools in a coordinated way.  

In one current case, we intervened early, appointing administrators as needed to secure the position and protect consumers, while we consider next steps.

Throughout all of this, firms, of course, have legal and procedural protections. But in many cases, they cooperate and agree to restrictions without the need for us to formally exercise our powers.  

Last financial year saw a total of 369 voluntary outcomes across the FCA.

124 of those – the most complex – were supported by our Interventions Team, as well as an additional 13 where the firm wasn’t prepared to agree, and we had to exercise formal powers. Each one, a case where harm was stopped or reduced without a tribunal hearing.

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 we are facing – much of which does not originate on our shores.

A global problem calls for a global response:

Criminals don’t see national boundaries; they see opportunities to exploit the seams between differing regulatory approaches.  

The pump-and-dump scheme we disrupted didn’t start in the UK, and it won’t end here, either.

The group behind it has successfully targeted several securities in another European jurisdiction, and we are working closely with our regulatory counterparts to support their investigations.  

Our job is to make sure that wherever a criminal sees an opportunity, they find us there waiting for them.

That is the standard we should all aspire to, and it’ll take more than just parallel action.

It calls for a collective effort across everyone at the table – regulators, law enforcement and industry – built on shared intelligence, insights and practical approaches.  

We are playing our part, working closely with international bodies like the International Organization of Securities Commissions' (IOSCO) Committee on Enforcement and the Exchange of Information.  

And we are one of the largest active contributors to the Multilateral Memorandum of Understanding. We handled 341 incoming requests and made 138 outgoing ones in the last financial year alone.

Consumers and markets alike depend on that kind of coordinated response. 

And we’ve seen firsthand the difference these partnerships can make.

For instance, in one of our investigations last year – alongside the United States SEC – we were able to secure $101m in redress for investors.

Earlier this year, 17 regulators from around the world participated in our ‘finfluencer week of action’: a single coordinated push of enforcement activity, consumer awareness campaigns, and educational programmes.

In the UK alone, we issued dozens of warnings, made 120 account takedown requests for illegal content, and took criminal action against 3 individuals.

That kind of work continues today.  

Right now, we are working with counterparts including BaFin, the US Department of Justice and the Monetary Authority of Singapore to share information, trace funds and pursue cross-border criminals.

The fundamentals remain:

But none of this means we have taken our eye off the ball closer to home.

Protecting consumers. Keeping markets clean. Tackling the fraud and scams that devastate lives.  

We are not replacing those fundamentals; we are sharpening them.

The numbers speak for themselves:

• 7 criminal convictions in 2024. 
• 12 in 2025.
• And by 1 June of this year, we already had 6 convictions, and levied nearly £17m in financial penalties.

The Consumer Duty continues to set the bar for how we expect firms to treat their customers, and we will not hesitate to act where they fall short.

Our focus is now widening to include motor finance and the conduct of claims management companies, including: 

• A taskforce with the Information Commissioner's Office, Advertising Standards Authority and Solicitors Regulation Authority.
• Multiple voluntary requirements.
• Active supervisory and enforcement work, with two firms currently confirmed to be under investigation.  

It’s very much a system-wide approach, and we want to continue to deepen collaboration with partners and industry.

We’ve already published, with the National Crime Agency, 9 shared economic crime priorities. 

We’ve joined the Data Fusion project with the Bank of England and industry, to improve our ability to detect and disrupt serious organised crime.

And we’re looking forward to deepening our relationships with professional body supervisors in the legal and accountancy sectors under our new anti-money laundering jurisdiction. 

Conclusion

So, let me ask again: Does the absence of headlines concern you, or reassure you?

I hope, by now, your answer is shifting.

It is trust in our markets that gives consumers the confidence to participate, supporting competitiveness, and underpinning growth.

But that trust isn’t built by fines or headlines alone – those are just the visible tip of a much bigger iceberg. It relies on the careful, coordinated work continuing under the surface to stop bad actors before they get a foothold.

The regulator is always watching and working, even when – especially when! – you don’t realise it.

But we can’t do it all alone. The threats of today are too fast, global and adaptive for any single institution.

Where trust in our markets serves all our interests, likewise protecting that trust is a shared responsibility too.

So keep working with us.

See some suspicious transactions? Let us know early.

Have thoughts on how the system could be improved? Share them with us. You are dealing with these issues up close every day.

We don’t just want to hear your insights and ideas; we need to hear them. 

Because criminals are counting on there being gaps between us.

Let’s not give them one. 

https://www.fca.org.uk/news/speeches/beyond-headlines-unseen-fight-against-financial-crime