The FCA recently wrote to the Financial Services Regulation Committee with an update on its enforcement approach. Buried in that letter was a striking number: between 3 June 2025 and 30 April 2026, the regulator opened 33 new enforcement operations.
That's roughly three new investigations every month. For independent financial advisers, this is worth paying attention to—not because you're likely to be investigated, but because the patterns in FCA enforcement tell you exactly where the regulator is focusing its attention.
The backstory: why this letter matters
This correspondence follows the FCA's controversial consultation (CP24/2) on publicising more enforcement investigations at an earlier stage. The proposal drew significant pushback from the industry, with concerns about reputational damage to firms before any wrongdoing was proven.
The FCA acknowledged in its letter that the reaction to CP24/2 "reinforced its commitment to be as predictable as it can be when consulting on policy changes." In plain English: they heard the criticism and are trying to be more transparent about their regulatory approach.
What does this mean practically? The FCA wants you to understand its enforcement priorities clearly enough that you can avoid problems in the first place. They'd rather prevent breaches than punish them—at least in theory.
Where the 33 investigations are likely focused
The FCA doesn't break down these 33 cases by type in the letter, but we can make educated guesses based on the regulator's stated priorities and recent public actions:
Financial promotions remain a major focus. The same week this letter emerged, the FCA issued warnings about misleading social media adverts from claims management companies. They've been clear that poor-quality financial promotions—whether from regulated firms or their appointed representatives—are firmly in their sights.
Consumer Duty compliance is another obvious area. The Duty came into force in July 2023, and the FCA has repeatedly said it will take action against firms that aren't delivering good outcomes for customers. After giving firms time to embed the new requirements, enforcement was always going to follow.
Anti-money laundering continues to generate cases. Just this month, the FCA moved to place Euro Exchange Securities UK Ltd into special administration over suspected financial crime risk. AML failures remain one of the fastest routes to enforcement action.
What this means for your practice
If you're running a compliant IFA practice, 33 investigations across the entire financial services sector isn't cause for panic. But it should prompt some practical reflection.
Review your financial promotions. Every social media post, every email newsletter, every piece of marketing material you produce is a financial promotion if it promotes your services. The FCA has made clear it's watching digital channels closely. Are your posts clear, fair and not misleading? Do they include appropriate risk warnings? Could a reasonable person misunderstand what you're offering?
Document your Consumer Duty thinking. If the FCA came calling tomorrow, could you demonstrate how you've considered customer outcomes in your advice process? The firms that get into trouble often can't show their working. Good intentions aren't enough—you need evidence.
Check your appointed representatives. If you have ARs, their compliance is your compliance. The FCA has been explicit that principals will be held accountable for AR failings. Review what they're putting out into the world.
The predictability point
One line in the FCA's letter deserves highlighting. They say that being "as predictable as it can be" is "an explicit commitment in its current five year strategy."
This is actually useful for advisers. A predictable regulator is one you can plan around. Read the FCA's sector letters, follow their enforcement announcements, pay attention to their Dear CEO communications. They're telling you what they care about. The firms that get caught out are usually the ones who weren't paying attention to signals that were there all along.
The motor finance claims management enforcement actions are a perfect example. The FCA warned about misleading promotions in this space repeatedly before launching investigations. The pattern was visible months in advance.
Practical steps for this week
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Pull up your last ten social media posts. Read them as if you were an FCA reviewer. Anything that makes you slightly uncomfortable?
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Check when you last reviewed your compliance monitoring programme. If it's been more than six months, schedule a review.
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If you use any third parties for marketing, verify they understand financial promotion rules. Their mistakes become your problem.
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Make sure your professional indemnity insurance is current and adequate. Enforcement investigations are expensive even when you've done nothing wrong.
The FCA opening 33 enforcement operations in 11 months isn't a crisis—it's the regulator doing its job. Your job is to make sure you're not giving them reasons to add you to the list.
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