In the first six months of the current financial year, the Financial Conduct Authority (FCA) has already imposed £794 million in fines and penalties, according to NERA’s new report, Trends in Regulatory Enforcement in UK Financial Markets. Authored by NERA Associate Director Robert Patton and Economic Analyst Marcin Pruski, the report analyses trends based on NERA’s database of fines and other enforcement activity by the FCA and its predecessor, the Financial Services Authority (FSA).

Among the report’s findings is that the FCA has continued to levy “big-stick fines,” at least against firms, having imposed an unprecedented £1.4 billion in fines and penalties in the 2014/15 financial year, which it is on pace to exceed in 2015/16. The 2014/15 fines alone exceed cumulative fines levied by the FCA and the FSA in all previous years combined. This level of fines and penalties is also more than three times the level of aggregate fines in each of the preceding two financial years, 2012/13 and 2013/14, each of which in turn was unprecedented in comparison with earlier years.

In addition, excluding fines for interbank manipulation and FX, the aggregate amount of fines against firms has still risen, albeit to less stratospheric levels. The average fine against firms, excluding those for FX and interbank rate manipulation, has risen from £5.0 million in 2012/13 to £40.3 million in 2015/16 to date. The median fine against firms in the first half of 2015/16 has reached £20.7 million, approximately 50% more than the median in 2014/2015 and about three and a half times the median in 2012/13.

It is possible, however, that more benchmark fines could follow—as of 1 April 2015, seven additional UK-based financial benchmarks have been brought within the scope of FCA regulation. These include the WM/Reuters London 4pm Closing Spot Rate, ISDAFIX, London Gold Fixing and the LBMA Silver Price, and the ICE Brent Index.