In Compliance Week, McGuireWoods’ Francesca Titus Comments on FCA’s Shifting Enforcement Strategy

April 17, 2026

Compliance Week  quoted McGuireWoods London partner Francesca Titus in a March 11, 2026, article examining the Financial Conduct Authority’s evolving approach to enforcement and the implications for regulated firms across the United Kingdom. The article explores how the regulator’s push toward more selective, outcomes-focused investigations is reshaping the compliance landscape.

FCA enforcement actions increased by 43% in 2025 compared to the prior year, even as the total value of fines fell significantly, Compliance Week reported. The trend reflects a broader strategic pivot: rather than pursuing a small number of large, resource-intensive cases, the FCA is expanding its enforcement reach while placing greater compliance obligations on firms themselves.

“Historically, too many investigations were opened on a lack of credible evidence of wrongdoing,” said Titus, a partner in the firm’s Government Investigations & White Collar Litigation Practice Group. “Now the FCA is selecting the right cases for enforcement, and the majority of operations end in a regulatory outcome rather than no further action.”

At the same time, Titus highlighted the cost pressures that accompany the FCA’s expectations of greater self-monitoring by firms. “The FCA have at least acknowledged that there is often great cost in having financial crime controls in place, but offers no solutions to ever rising costs,” she said.

Titus emphasized that the FCA’s posture should not be read as punitive for its own sake. She explained that the regulator “tries to support firms that have made genuine mistakes to right their own wrongs, rather than take a heavy-handed approach.” She cautioned that this model depends on firms acting proactively, “taking steps to resolve issues early, compensating customers, and ensuring errors cannot happen again.”