FCA Accountability in Action: What the Staley Case Means for Your Firm

The FCA Conduct Rules have always been more than a tick-box exercise, and yesterday's Upper Tribunal decision in the Jes Staley case is a sharp reminder.

What Happened

The FCA fined Jes Staley £1.8 million and banned him from holding senior roles in financial services after he was found to have recklessly approved misleading letters to the FCA regarding his relationship with Jeffrey Epstein.

The Upper Tribunal agreed. Staley breached key FCA Conduct Rules, including:

• COCON 1 – Failing to act with integrity

• COCON 3 – Failing to be open and cooperative with the FCA

The FCA's message is clear:

Seniority doesn’t shield anyone from accountability.

This isn’t just a story about a high-profile CEO. It’s a wake-up call for every regulated firm, and the Conduct Rules apply at every level of the business, and when breached, they have teeth.

Why This Matters to Your Firm (and Your Staff)

✔️ All staff (except ancillary roles) are subject to the Conduct Rules.

✔️ The FCA expects honesty, integrity, and openness from all Conduct Rules staff.

✔️ Senior Managers carry heightened responsibility, and face personal accountability for failings.

✔️ Poor communication with the FCA (even by omission) can lead to career-ending outcomes.

✔️ Non-compliance can mean financial penalties, reputational damage, and even regulatory intervention.

✔️ The FCA is actively using enforcement powers to drive home cultural change.

How We Can Help

Whether you're reviewing your SM&CR framework or preparing for regulatory scrutiny, we provide practical, proportionate support to help you meet your obligations.

✅ Responsibility Mapping: Clear documentation of senior management responsibilities, aligned with regulatory expectations.

✅ Certification Process Reviews: Support with implementing or improving your annual certification procedures and fitness and propriety assessments.

✅ Conduct Rules Training: Tailored training for Conduct Rules staff and Senior Managers, with practical examples and role-relevant guidance.

✅ Breach Identification & Escalation: Tools and advice to help you identify, assess, and report Conduct Rule breaches appropriately.

✅ Ongoing Advisory Support: A trusted second line of defence for your firm, offering guidance on challenges and regulatory change.

Ready to make compliance less stressful?

Contact us and schedule a free consultation to find out how Compliance Angle can help you stay on track and ahead of the game.

Call us on 07427792594 or send us an email at info@complianceangle.co.uk