Introduction
Source: FCA Speech – “Our Agenda to Combat Market Abuse”
Our agenda to combat market abuse | FCA
The Financial Conduct Authority (FCA) has laid out its renewed strategy to combat market abuse across UK financial markets in a detailed speech delivered by Therese Chambers, Joint Executive Director of Enforcement and Market Oversight. Delivered at the City and Financial Global Market Abuse and Market Manipulation Summit on 28 April 2025, Chambers’ speech highlights how the regulator plans to respond to growing complexity in financial crime and rising expectations for issuers and intermediaries alike.
A Strategic Framework: The "Three Ps"
At the core of the FCA’s approach is the “Three Ps” framework:
- Predictable: Clear communication, consistent expectations, and transparent regulatory signals to help firms align with FCA priorities.
- Proportionate: Streamlined data collection and regulatory processes, with a focus on minimising unnecessary burdens while retaining effective oversight.
- Purposeful: Targeted and outcome-oriented enforcement, focused on preventing harm and deterring serious misconduct.
This new strategy supports the FCA’s broader 5-year vision to 2030 and emphasises integrity as foundational to long-term economic growth and investor trust.
Key Enforcement Priorities
1. Organised Crime Groups (OCGs): A Rising Threat
OCGs now account for approximately 25% of all Suspicious Transaction and Order Reports (STORs) submitted to the FCA. Chambers noted that OCGs are responsible for over £500 million in suspicious trading profits since 2022. The FCA is intensifying efforts to identify, disrupt, and prosecute these groups using a full suite of enforcement tools, including data analytics, inter-agency cooperation, and pre-emptive disruption.
2. Strategic Leaks and Unlawful Disclosure
The FCA is increasingly concerned by deliberate leaks of material non-public information, particularly around M&A activity. These disclosures often appear in the press prior to Regulatory Information Service announcements, undermining market fairness. Chambers confirmed that the FCA and Takeover Panel are jointly investigating suspected leaks and are engaging directly with investment banks to address the issue.
3. Transaction Reporting Reform
A consultation paper will be issued later in 2025 to reform transaction reporting requirements, with the following aims:
- Eliminate low-value or duplicative reporting fields
- Prioritise reporting obligations where surveillance value is high (e.g., CFDs, FX)
- Reduce the compliance burden without weakening market oversight
The FCA received 76 million transaction reports in a single day during recent market volatility, more than double the usual daily average. This highlights the importance of streamlined and scalable data systems.
Collaborative Market Integrity: Everyone Has a Piece of the Puzzle
Chambers used the metaphor of a jigsaw puzzle to emphasise the FCA’s reliance on firms as co-stewards of market integrity. She urged proactive cooperation and noted that over 70% of FCA market abuse investigations now originate from STORs.
Firms were encouraged to:
- Offboard clients that no longer fit their risk appetite
- Invest in controls to restrict access to inside information
- Report concerns without delay
- Engage constructively through forums, consultations, and bilateral dialogue
Innovation and Growth: A Balancing Act
The FCA is also exploring new, proportionate models to support capital formation while preserving integrity. A notable example is PISCES (Private Intermittent Securities and Capital Exchange System), a proposed mechanism for trading private company shares outside the MAR regime. This reflects the regulator’s willingness to take calculated risks to support innovation, where appropriate.
Implications for Listed Companies
Chambers' speech serves as both a roadmap and a warning. Firms that fail to maintain effective controls will face assertive regulatory response, while those that engage early and maintain transparency will find a more collaborative partner in the FCA.
Now is a critical moment for listed companies to:
- Review insider list and delay of disclosure processes
- Assess the adequacy of MAR-related systems and governance
- Prepare for changes to transaction reporting obligations
- Ensure audit-readiness for FCA scrutiny or investigation triggers
How InsiderList Helps Issuers Stay Ahead
InsiderList supports listed companies in managing their MAR obligations efficiently, securely, and in line with FCA expectations. Our platform enables:
- Real-time, auditable insider list management
- Automated PDMR notifications and acknowledgements
- Delay of disclosure logging with approval workflows
- Reduced manual processes and reporting risks
As the FCA sharpens its focus on integrity, governance, and enforcement, InsiderList offers firms the structure, transparency, and control required to respond with confidence.
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