NERA Economic Consulting Releases Mid-Year Financial Conduct Authority Trends Report; FCA on Track to Impose Record-breaking Fines Against Firms and Individuals for 2015/16 Financial Year

15 October 2015

London—During the first six months of the current financial year, the Financial Conduct Authority (FCA) has already imposed £794 million in fines and penalties, and is thus on track to exceed the unprecedented £1.4 billion in fines and penalties it imposed during the 2014/15 financial year, according to an annual report by NERA Economic Consulting, Trends in Regulatory Enforcement in UK Financial Markets: 2015/16 Mid-Year Report.

While the largest recent fines on firms have been imposed for manipulation of foreign exchange and interbank lending benchmarks such as LIBOR, the average size of fines relating to other conduct is also increasing, suggesting that tougher enforcement may persist even after the current wave of exceptionally benchmark-related fines.

Despite the rhetorical emphasis placed by the FCA on enforcement against individuals, the number and aggregate amount of fines against individuals has remained low for several years. In 2014/15, aggregate fine amounts rose to £7.1 million—higher than in the prior two years, but still below the peak of nearly £20 million in 2011/12. Over the first six months of 2015/16, the FCA imposed just five fines on individuals totalling less than £850,000, a pace of £1.7 million per annum. However, several large fines under or subject to appeal, as well as key policy changes relating to market abuse and regulation of senior managers, may change this picture going forward.

Trends in Regulatory Enforcement in UK Financial Markets 2015/16 Mid-Year Report analyses trends based on NERA's proprietary database of fines and other enforcement activity by the FCA and FSA. The report also provides a discussion of recent developments in enforcement, and looks ahead to how fines and enforcement may evolve in light of emerging conduct issues and relevant legal and regulatory changes.

Additional Highlights

  • Fines for FX manipulation amounted to £1.11 billion in 2014/15, nearly 80% of the total, and fines for FX and interbank rate manipulation combined have accounted for £2.16 billion, more than two-thirds of the £3.05 billion in fines imposed over the past three and a half financial years.
  • 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.
  • Interbank rate and FX fines dominate the 10 largest fines against firms—six of the top 10 were issued in connection with the foreign exchange manipulation scandal, and two are related to interbank benchmark manipulation.
  • 28 individuals were indicted by the FCA in the three years up to 31 March 2015; with another three indicted so far this year.
  • The FCA secured a jail sentence in 2012/13 for one individual involved in boiler room fraud, and two individuals who were charged in 2014/15 for conducting unauthorised business and unauthorised investment schemes. Overall, the FCA investigations have now led to 54 convictions, 27 of which relate to insider dealing cases.

NERA's "Trends" Series

NERA has been analysing trends in enforcement and shareholder class action litigation for more than 20 years. In addition to this report, NERA publishes annual US and Canada Trends studies.

Trends in Regulatory Enforcement in UK Financial Markets 2015/16 Mid-Year Report may be downloaded from:

Media Contacts

Robert Patton
Associate Director
+44 20 7659 8620

Benjamin Seggerson
Senior Manager
+1 202 466 9232


About NERA

NERA Economic Consulting ( is a global firm of experts dedicated to applying economic, finance, and quantitative principles to complex business and legal challenges. For more than six decades, we have been creating strategies, studies, reports, expert testimony, and policy recommendations for government authorities and the world’s leading law firms and corporations. We bring academic rigor, objectivity, and real-world industry experience to issues arising from competition, regulation, public policy, strategy, finance, and litigation.

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