Incredible Deterrence? The FSA’s New Proposals on Enforcement Penalties

Jul 2009 | Client publication/article

Just weeks after Hector Sants, the Chief Executive of the FSA, warned that market participants should be "very frightened" of the FSA, on 06 July 2009 the FSA published plans for a new, tougher framework for determining the level of enforcement financial penalties, aimed, it says, at "hitting companies and individuals in the pocket where it hurts". This is the latest instalment in the FSA’s move to create an enforcement regime which achieves "credible deterrence".

This briefing paper summarises the main proposals in the FSA’s consultation paper, CP09/19 ("Enforcement financial penalties"), and then focuses on some of the potential implications for market participants of the FSA’s new approach.


Jan Putnis (partner), Ewan Brown (partner)
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