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Articles by Anna James
FCA Publishes Final Policy Position on Announcing Enforcement Investigations | JD Supra
The regulator has dropped its proposed “public interest” test, but will take certain aspects of its proposals forwards. On 3 June 2025, the FCA published its final policy (PS25/5) on announcing enforcement investigations, along with its updated Enforcement Guide, ending a rather turbulent consultation process.
FCA and PRA Announce Intention to Drop Reform Proposals
The regulators have said they will not pursue their proposals on announcing enforcement investigations and on D&I. On 12 March 2025, the FCA and PRA made important announcements regarding the long-awaited outcomes on certain key policy proposals. The FCA published a letter addressed to the Treasury Select Committee and accompanying statement, while the PRA also published a letter to the Treasury Select Committee.
FCA Publishes Revised Proposals for Announcing Enforcement Investigations | JD Supra
The regulator has significantly rowed back on aspects of the proposals following industry and government feedback. On 28 November 2024, the FCA published revised proposals for announcing enforcement investigations. The original consultation, launched in February 2024, proved to be one of the most controversial proposals put forward by the regulator and received an unprecedented response from industry and the government (for more detail on the original proposals, see this Latham blog post).
FCA Consults on Plans to Announce Enforcement Investigations | JD Supra
The FCA plans to streamline its approach to enforcement and publicise investigations at an early stage. On 27 February 2024, the FCA published a Consultation Paper (CP24/2) on its proposed new approach to publicising enforcement investigations and changes to the FCA Enforcement Guide (EG). The FCA also published a related speech given by Therese Chambers, joint Executive Director of Enforcement and Market Oversight.
FCA Consults on Plans to Announce Enforcement Investigations
The FCA plans to streamline its approach to enforcement and publicise investigations at an early stage. By Andrea Monks, Rob Moulton, Nell Perks, Anna James, and Charlotte Collins On 27 February 2024, the FCA published a Consultation Paper (CP24/2) on its proposed new approach to publicising enforcement investigations and changes to the FCA Enforcement Guide (EG). The FCA also published a related speech given by Therese Chambers, joint Executive Director of Enforcement and Market Oversight.
FCA Consults on Plans to Announce Enforcement Investigations
The FCA plans to streamline its approach to enforcement and publicise investigations at an early stage. On 27 February 2024, the FCA published a Consultation Paper (CP24/2) on its proposed new approach to publicising enforcement investigations and changes to the FCA Enforcement Guide (EG). The FCA also published a related speech given by Therese Chambers, joint Executive Director of Enforcement and Market Oversight.
Bank of England Unveils Changes to the PRA’s Approach to Enforcement
Recent changes to the PRA’s approach to enforcement show an increased focus on expediting the investigative process and incentivising early admissions. On 30 January 2024, the Bank of England (the Bank) unveiled a number of changes to the Prudential Regulation Authority’s (the PRA’s) approach to enforcement (PS1/24), including the introduction of an Early Account Scheme and Enhanced Settlement Discount.
UK Court Clarifies Important Issues Relating to Proprietary Interests in Trust Assets | JD Supra
The Court of Appeal ruled that losing proprietary rights under foreign law could invalidate personal claims against third party recipients of trust assets. On 27 January 2022, the UK Court of Appeal unanimously dismissed an appeal brought by Saad Investments Company Limited (SICL) and its liquidators[1].
UK Court Clarifies Important Issues Relating to Proprietary Interests in Trust Assets
The Court of Appeal ruled that losing proprietary rights under foreign law could invalidate personal claims against third party recipients of trust assets. By Daniel Smith and Anna James On 27 January 2022, the UK Court of Appeal unanimously dismissed an appeal brought by Saad Investments Company Limited (SICL) and its liquidators[1].
High Court Clarifies Consequences of Late Part 36 Offer Acceptance | JD Supra
The decision highlights a potential tactical advantage of late acceptance in certain circumstances. In Roxanne Pallett v. MGN Limited,[1] the High Court held that the usual costs consequences of accepting a Part 36 offer do not apply if a party accepts a Part 36 offer outside the “relevant period”, meaning the offeree is not bound to pay the offeror’s costs.
High Court Clarifies Consequences of Late Part 36 Offer Acceptance
The decision highlights a potential tactical advantage of late acceptance in certain circumstances. By Jon Holland and Anna James In Roxanne Pallett v. MGN Limited,[1] the High Court held that the usual costs consequences of accepting a Part 36 offer do not apply if a party accepts a Part 36 offer outside the “relevant period”, meaning the offeree is not bound to pay the offeror’s costs.
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