Insights
Regulatory Updates September 2026
Our regulatory newsletter aims to provide insight into the changes and updates that may have an impact on firms. At Objectivus, we are well positioned to provide context and support for firms working to understand such changes.
In this September issue, we cover the closure of CFD firms; the opening of the crypto authorisation window; the government’s anti-money laundering and asset recovery strategy; and several recent FCA enforcement outcomes.
CFD Firms Closing
In a press release this month, the FCA announced that twenty-one contract for difference (CFD) firms have closed since 2025, with three other firms currently cancelling their permissions.
The regulator found that many of these firms were carrying out negligible UK business, while using their authorised status to effectively mislead overseas retail investors into thinking they were covered by UK financial protection. In reality, those investors were dealing with an unregulated, linked overseas firm and so lacked this protection.
These firms faced a range of actions from the FCA, including the restriction of trading, independent reviews of their business and, in the two most serious cases, enforcement investigations being opened.
The FCA noted that consumers should use the Firm Checker on the Financial Services Register to check whether they are dealing with a UK-authorised firm or a similarly named overseas firm.
What this means for firms: The FCA is willing to act where UK authorisation is used to lend credibility to an unregulated overseas business. Authorised firms with overseas group entities, or with permissions they use very little, should review how their status is described and whether their permissions still reflect the business they actually carry out.
Crypto Authorisation Window Opens
As mentioned in June, the FCA is introducing new rules that bring crypto assets under its remit from 25 October 2027. The rules were first announced in February this year, followed by a consultation in April, with final rules published at the end of June in a series of policy statements.
The window to apply for authorisation opened on 30 September 2026 and runs until 28 February 2027 for firms seeking to use the transitional arrangements.
The FCA has also announced that it plans to consult on further changes in late 2026, before publishing further guidance in early 2027.
What this means for firms: Firms that want to use the transitional arrangements need to apply by 28 February 2027, so it is worth deciding early whether you need authorisation and which permissions to apply for. If you are a crypto firm that would like support with the new rules or your application, the Objectivus team would be glad to help.
Anti-Money Laundering and Asset Recovery Strategy
In September, the government published its new Anti-Money Laundering and Asset Recovery strategy, which set out how the Treasury and the Home Office intend to tackle money laundering and increase asset recovery over the next three years.
The strategy is backed by over £550m of investment and is built around the ideas that money laundering should not pay and that the UK should become a hostile environment for dirty money.
It sets three objectives: making the UK’s defences more effective, disrupting high-harm money laundering networks, and recovering more criminal assets. These objectives will then be delivered through three pillars: Target (focusing effort on the highest-harm risks and cutting low-value compliance activity), Integrate (joining up intelligence across the public and private sectors) and Empower (giving investigators the people, powers and technology required to act).
What this means for firms: The FCA will become the AML/CTF supervisor for legal, accountancy and trust and company service providers, reducing the number of supervisors from 25 to 3. The Government also plans to review the SARs regime, including whether to raise the suspicion threshold and to consult further on the Money Laundering Regulations.
FCA Enforcement Outcomes
The Upper Tribunal upheld Crispin Odey’s lifetime ban from working in financial services, finding that he lacked integrity.
Odey was under an internal disciplinary process for breaching a final written warning related to repeated and persistent inappropriate behaviour towards female employees. In response, the tribunal found he exerted pressure on the executive committee when he ‘feared they would not find in his favour’. This pressure included threatening to close the firm and twice dismissing the executive committee, which brought the internal disciplinary process to a halt.
The tribunal also found that the beliefs Odey relied on to justify his actions ‘reflected a warped set of values based on a strong sense of entitlement’, and that he was motivated ‘by his own self-interest and self-preservation to avoid accountability.’
Odey was fined £1.53m – a reduction from the £1.83m the FCA proposed – and all five of the FCA’s allegations were upheld.
It is important to note that the tribunal was not deciding whether the sexual misconduct allegations against Odey were true, and Mr Odey has denied them. Its findings concern how he handled the firm’s disciplinary process.
In another case, Christopher Woolcott pleaded guilty to four counts of fraud and forgery following a fake takeover bid he created for Touchstone Exploration. He will be sentenced at a later date.
He admitted to using multiple false identities and forged documents to lend credibility to his approach. As a shareholder in Touchstone Exploration, he stood to benefit financially from any rise in its share price had the bid been announced to the market.
Finally, Nurul Miah has also been banned from working in financial services. The FCA acted following a decision from the Solicitors Regulation Authority (SRA), which found that Mr Miah, who was a non-legal manager at Kingly Solicitors Limited, dishonestly caused or allowed over £28m of client money to be removed from clients’ accounts without permission. The SRA also found that more than £10m of that money was missing and had been used by Mr Miah for his own benefit.
What this means for firms: These cases show the FCA’s continuing focus on integrity, and its willingness to act on the findings of other regulators and tribunals. Firms should make sure their fitness and propriety assessments, and the way they run internal disciplinary and governance processes, would stand up to scrutiny.
If you have any questions or would like further clarity on any of the points raised, please contact us at info@objectivus.com.