Key facts
- The FCA is expanding its Conduct Rules to cover serious non-financial misconduct such as bullying and harassment.
- These new rules will apply to approximately 30,000 UK financial services firms starting September 1, 2026.
- The FCA's focus on culture is evidenced by recent enforcement actions against individuals for lack of integrity and governance failures.
- Record-keeping is central to the FCA's investigative process, with documentary evidence playing a key role.
- The FCA's approach emphasizes that historical behavior remains relevant if the underlying mindset has not changed.
The UK's Financial Conduct Authority (FCA) is set to significantly alter how financial services firms manage workplace culture, conduct, and inclusion, with new regulations taking effect from September 1, 2026. While plans for mandatory diversity and inclusion rules have been shelved, the FCA is placing a heightened emphasis on firm culture and non-financial misconduct (NFM).
These upcoming rules will extend the FCA's Conduct Rules to encompass serious non-financial misconduct, including bullying, harassment, and discrimination, across nearly all UK financial services firms. Previously, these rules primarily applied to banks, but their expansion will bring approximately 30,000 additional organizations under a stricter conduct regime. Firms will be required to ensure that substantiated personal misconduct is addressed.
Recent cases highlight the FCA's enforcement approach. The March 2026 Final Notice against Kasim Garipoglu concluded he lacked honesty and integrity due to a pattern of behavior including disregard for AML obligations, undermining compliance staff, and providing false information to regulators. The FCA deemed this a "tone-from-the-top" failure that fostered a culture where compliance was seen as an obstacle.
Similarly, the FCA's March 2025 decision to fine and ban Crispin Odey for lack of integrity focused on his alleged frustration of disciplinary processes and disregard for governance. This case, currently before the Upper Tribunal, underscores the FCA's scrutiny of how internal processes are handled when allegations involve powerful founders.
Both cases emphasize that culture is demonstrated through decisions, escalations, record-keeping, and the allowance of internal challenge. The FCA's focus on documentary evidence, such as email chains and audit trails, underscores the importance of robust record-keeping in investigations. The regulator also indicated that historical behavior remains relevant if an individual continues to defend their past conduct.