Elsewhere, whilst some of the predicted enforcement cases arising out of the pandemic have yet to materialise, technological change, innovation and emerging products continue to test the FCA’s stated desire to be more nimble in tackling consumer harm before it crystalises. Changes to the FCA’s decision-making processes are intended to help support the FCA in becoming a more agile regulator, there are already signs that during 2022 the FCA will look to become more assertive in the way in which it exercises its supervisory intervention powers.

Finally, the regulators’ continued focus on non-financial misconduct (NFM) and, more broadly, the role that diversity and inclusion (D&I) plays in developing a healthy organisational culture will continue to feature indication of the likely future direction of enforcement in the culture and individual conduct space.

Here we highlight the most important enforcement developments in 2021, together with the key areas we believe will impact the nature and direction of enforcement activity by the UK financial regulators during 2022.