Regulatory gap analysis: Crispin Odey FCA Decision Notice

The FCA’s decision on Odey comes at a pivotal time, as the regulator is preparing to publish its requirements on non-financial misconduct (NFM) later this year. We expect the regulator will make it clear that behaviour such as bullying, harassment and other forms of misconduct are not merely internal HR issues - they are regulatory matters, and the FCA are watching. 

The Odey case is a powerful reminder that culture and conduct are not insignificant issues - they are fundamental to a firm’s operational resilience and regulatory standing. A dominant, unchecked personality at the top can unravel years of progress on governance, compliance and ethical standards. The FCA has made it clear that a toxic culture is not only a reputational risk but also a supervisory concern. 

Firms must now take a proactive approach to identifying cultural weaknesses, strengthening governance and embedding accountability at all levels. The key question for every financial services firm is not whether they will face a cultural or governance challenge, but whether they are prepared to address it before it escalates into a regulatory or reputational crisis. 

To help you get started, we have prepared some key questions on the core topics identified within the Crispin Odey FCA Decision Notice in our gap analysis below. 

Firms that fail to address these issues risk not only regulatory consequences but also long-term damage to their reputation and employee trust. Now is the time to act – to find out how we can help you, get in touch with our team at ESG@avyse.com 

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