Working together to deliver our enforcement priorities

Speaker: Therese Chambers, joint executive director of enforcement and market oversight
Event: NYU’s Program on Corporate Compliance and Enforcement Spring Conference
Delivered: 11 April 2025
Note: this is the speech as drafted and may differ from the delivered version

Key messages:

• The FCA has a strong, productive history of working with partner agencies in the US, and we will continue to do so.
• Our enforcement action is about deterrence. Action to deter misconduct needs to be timely and visible.
• Our enforcement priorities for the next five years are about keeping dirty money out of the financial ecosystem, cracking down on regulated firms being used as vehicles for fraud, and protecting the integrity of UK markets.

Introduction

It’s so wonderful to be here on this beautiful campus in one of my favourite cities in the world.

I see that April is Reunion season here at NYU Law. ‘Reunion ’25’ is celebrating the grad classes from every five years from 1975 to 2020.

It’s in that spirit of reunions – of old friends and colleagues catching up – that I speak to you here today.

Being in New York this week got me thinking about one of my first times coming to the US as part of my job at the Financial Conduct Authority (FCA).

Some of you will remember the global conduct scandals around rate rigging of LIBOR and FX, over 10 years ago now.

Multiple international institutions were under investigation for their role.

The scale and international nature of the misconduct was unprecedented, and an unprecedented international response was required.

As we all know, those cases ended with multi-billion dollar fines and multiple prosecutions on both sides of the Atlantic.

Achieving that required international co-operation and co-ordination on a scale that was simply different to anything I had seen before.

Now a decade later, I’m here with you again to talk about the importance of our working relationship.

And how together, different people, from different backgrounds, but with a common purpose, can combat the complex challenges facing both of our countries today.

Change and new challenges

Last summer, the UK had a change of government and ruling party – the first in 14 years.

From day one, the new government has made economic growth its biggest priority.

And it has made clear that every regulator in the UK has its part to play – perhaps none greater than the FCA.

As I said, this is a reunion, so let me catch you up on what we’re doing – and what we are prioritising.

A few weeks ago, the FCA launched its new 5-year strategy to take us to 2030. We committed to being a smarter regulator, supporting growth and innovation, helping consumers, and fighting crime.

To fight financial crime we will act with pace to stop harm, disrupt criminals, and back firms to be an effective line of defence.

That’s where our Enforcement team come in.

Increased pace, focus and transparency

Enforcement is all about deterrence.

We are speeding up our investigations, doing fewer investigations faster.

Five recent investigations achieved an outcome in 16 months or less, compared to a prior average of 42 months.

Which means we are better placed to tell the story of what we are doing than ever before. Because to deter bad actors, we need to trumpet the value and impact of our work.

Enforcement needs to be loud and in your face.

London as an international financial centre

High standards of regulation, including effective enforcement, are a crucial part of what makes London such a successful international financial centre.

We’re world-leading in commercial insurance, derivatives, debt issuance, foreign exchange and commodities trading.

Our asset management and fintech sectors are second in size only to the US.

Many, if not all, of the US firms you represent have a London footprint.

Some will have entities that are directly authorised and regulated by us.

Others will have trading operations that participate in UK markets.

The way we regulate and enforce in London matters to all of you.

Our areas of focus

What are the areas that you need to have on your radar?

Well, in a nutshell, here are the things we care about:

1. Keeping dirty money out of the financial ecosystem.
2. Taking swift action where we see regulated firms being used as vehicles for fraud.
3. Keeping our markets clean.
4. Developing a safe crypto regime that protects consumers.

The first theme of keeping dirty money out of the financial ecosystem is a huge priority for us and firms have a critical role to play through their anti-money laundering systems and controls.

We have a strong track record of taking forceful action where we identify shortcomings in this area.

We successfully prosecuted NatWest[1], one of the UK’s largest banks, for a catalogue of failings in the way it monitored and scrutinised a series of transactions, with one customer depositing £365m (US$468m) with NatWest, a substantial proportion of which was actual dirty money deposited in bags of cash at its branches. NatWest was slapped with a £264m (US$338m) fine for its offences.

We fined Santander £107.7m[2] (US$137.3m) for failing to adequately manage the money laundering risks posed by its Business Banking customers. This included failing to obtain sufficient information to understand the nature of a customer’s business, inadequate verification of whether customers in fact carried on that business, and the absence of an effective framework for ongoing customer monitoring. 

And we have continued to take action against firms for failings including:

• Firms growing rapidly but their anti-money laundering and sanctions screening controls falling behind.
• Firms failing to act promptly to rectify known defects in their transaction monitoring systems.
• Firms performing inadequate customer due diligence and deploying flawed customer and country risk rating methodologies.

Keeping dirty money out of the financial ecosystem means maintaining high standards, proactive monitoring, and relying on international collaboration and digital tools.

That’s how we create a fair, transparent and trustworthy environment for financial services.

Technology will be a gamechanger for firms when it comes to their controls, as well as supporting our detection efforts.

There are plenty of smart fintech solutions in development that we are watching with interest and which we will support through our Innovation Hub[3].  

We also want to make sure that regulation is appropriately risk-based, so that industry can calibrate its efforts effectively. And we are interested to understand how digital ID could support enhanced verification methods.

We have an open mind in exploring these issues. But in the meantime, we continue to spend considerable resource and effort in policing this important area and we will continue to do so.

Let me move to my second theme. It’s no surprise, is it, that we see fraud as a major priority?

We will not tolerate fraud by regulated firms. Simple as that.

The trust and confidence of consumers and investors in regulated firms is critical to the UK growth story.

As well as being a regulator, we are also a criminal prosecutor, and we have record levels of prosecutions underway.

Through our fraud practice, we close firms down, hold to account those who have betrayed their customers’ trust, secure long prison sentences and ensure that criminals do not retain one cent of their ill-gotten gains.

We prioritise redress for victims. The wheels of English justice can sometimes turn slowly, but we do all we can so that they grind exceedingly fine.

But fraudsters operate in a wider ecosystem. They tend to have bank accounts.

I have just been speaking about our focus on anti-money laundering systems and controls.

An important aspect of that is having systems in place that can identify the indicia of fraud.

I hope your firms and clients have robust anti-fraud controls in place. If you provide banking for fraudsters, we will scrutinise those controls with care.

That third theme of market integrity weighs on my mind a lot. The integrity of our markets is vital, not just equity markets but across the full range of Fixed Income, Currencies and Commodities where the UK occupies an enviable global position.

We are all familiar with the way insider dealing and market manipulation can knock confidence in our markets. We continue to be very active in this space.

And there’s no escaping the growing threat posed by organised crime groups (OCGs) or OCGs infiltrating global markets.

Firms have an important role to play in keeping markets clean; they need to be vigilant in detecting signs of criminality.

Firms need to have the right systems and controls in place to catch those transactions that raise suspicions or warrant further analysis.

And we keep a close eye on the effectiveness of those controls, with a steady stream of enforcement outcomes to ensure high standards of transaction reporting are met. Firms should have zero tolerance for market abuse.

And that takes me into the final theme I want to call out: crypto.

We want to develop a safe, competitive and sustainable crypto sector in the UK. One that allows for innovation and is underpinned by market integrity and consumer trust.

We are engaging with government, industry, consumers and our regulatory partners to help get the future rules right.

We currently regulate firms for anti-money laundering purposes and crypto financial promotions. Regulation in the UK is limited right now, but we have used our existing powers to encourage the industry to develop strong consumer standards that better protect people.

For example, we have used our existing powers to keep firms that are unable to meet the minimum standards for preventing financial crime out of the UK. As of February of this year, only 50 out of 351 firms have met our standards to be registered.

We’re helping UK consumers protect themselves against unfair or misleading crypto financial promotions. During the first year of our financial promotion regime, from October 2023–October 2024, we issued 1,700 consumer alerts related to firms illegally promoting cryptoassets. 56 apps were removed from UK app stores; and over 900 crypto-related scam websites were taken down.

Last July, we took enforcement action against part of the Coinbase Group[4]. That Coinbase entity onboarded many thousands of high risk customers, despite the fact we had imposed formal restrictions to prevent it from doing exactly that. Funds deposited by those customers were used to execute multiple cryptoasset transactions through other Coinbase Group entities, totalling around US$226m.

These failings increased the risk that criminals could use part of the Coinbase Group to launder the proceeds of crime. As I said at the time, we will not tolerate such laxity which jeopardises the integrity of our markets.

The FCA’s international work

I hope the fact I’m here today in person to relay this message drives home how much we at the FCA value our working relationships with US partners.

This has always been the case. It will continue to be now and in the years ahead.

Because experience has taught us that international co-operation is mutually beneficial. We cannot progress some of our cases without your help, and you cannot progress some of yours without ours.

So, it’s in all our interests for us to offer and accept help in pursuit of our common goals.

Much of the misconduct we see is cross-border, with perpetrators and victims scattered around the globe. That’s particularly true of online frauds and scams.

We have the track record to prove that this international collaboration works.

A recent example is the long-running story of corruption, non-existent fishing boats in Mozambique and multiple regulatory and law enforcement interventions here, in the UK and Switzerland, known as “tuna bonds”. We reached a global settlement with Credit Suisse worth around US$475m[5] in respect of corruption in Mozambique. It was a complex case, and what happened as a result had profound consequences for the people of Mozambique.

The impact of tainted transactions included a debt crisis, financial turmoil and economic harm for ordinary people.

In the UK, we discounted our penalty in light of Credit Suisse’s agreement to forgive US$200m of debt owed by the Republic of Mozambique because of these tainted loans.

Mozambique also brought proceedings against Credit Suisse and other parties in the English Courts.

The proceedings in the English High Court were resolved in July 2024 with several settlements (including by Credit Suisse group companies) and a judgment awarding over US$2 billion in Mozambique’s favour against the Privinvest Group.

There is a final chapter in this story. Earlier this year, the FCA banned two managing directors from Credit Suisse[6] from working in the UK financial sector. Their names were Andrew Pearse and Surjan Singh. Both had pleaded guilty to money laundering and accepting kickbacks. Both had been convicted here in the US for arranging corrupt loans to the Republic of Mozambique.

This is a good example of how our work benefits from international cooperation. It shows that we are not scared of a fight, that we will act where harm has occurred outside the UK but that impacts the UK, and when it is the right thing to do.

Our enforcement action isn’t just about firms, it’s also about individual accountability and responsibility.

It is important that senior leaders at the firms we regulate are open, transparent and honest with us, and are held to account where their actions, or indeed their failure to act, results in harm.

Let me give you an example. We decided to prohibit Jes Staley[7], who you may know from his days leading JP Morgan before he joined Barclays as CEO, from being a senior manager at any firm authorised by us. We say that Mr Staley recklessly misled the FCA regarding the nature of his relationship and dealings with Mr Epstein. Whilst we are awaiting the Tribunal’s decision, it is a case that highlights the premium the FCA places on the integrity of senior individuals.

Conclusion

I’ve spoken about some big ideas. And some big challenges.

What’s clear to me, and I hope to you now too, is no one country or state agency can tackle these complex problems alone.

It has never been more important for us to fall back on and trust our longstanding friendship.

It makes me think again of the alumni of NYU Law getting back together in a few weeks for their reunions, trading memories and war stories.

I think of our strong relationships with US agencies in the same way. Life-long friends, bonded by hard work and mutual respect, tested by tough cases.

Understanding that we all stand a better chance to achieve our goals by helping one another out, as all good friends do.