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02 Oct 2026

Is the FCA’s five-step penalty policy fit for purpose? Priya Dave writes for FT Adviser

With FCA penalties increasingly being reduced on appeal, scrutiny is growing over whether the regulator’s five-step penalty framework remains fit for purpose.

In her latest article for FT Adviser, Priya Dave, Of Counsel at Corker Binning and a former contentious regulatory lawyer at the FCA, explores how the regulator applies its penalty policy and discretion, and whether the framework is achieving its original aims.

Priya argues that the FCA’s latest proposals in CP26/19 “tinker around the edges”, failing to address more fundamental concerns around the operation of the five-step penalty framework.

Read the full article here.

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