The Financial Conduct Authority (FCA) has introduced a new “Enforcement Investigations” page on its website providing a centralised list of investigations that the regulator has chosen to announce publicly. The list can be accessed via the FCA’s ‘News’ webpage by selecting the new filter “Enforcement investigations” (see here).
This development follows the FCA’s decision to abandon its controversial proposals for an enhanced “naming and shaming” regime and forms part of its broader transparency initiative under Policy Statement PS25/5 and the revised Enforcement Guide (ENFG). As outlined in our June briefing, the FCA ultimately dropped its proposal to adopt a “public interest” test for naming firms under investigation. Instead, it retained its existing policy of announcing investigations only in “exceptional circumstances” and added three new scenarios where announcements may be made:
- Suspected unauthorised or criminal activity – to warn or alert consumers/investors or assist investigations by encouraging witnesses to come forward.
- Reactive confirmations – where the investigation has already been made public by the firm, an affiliate, or another UK or overseas authority, the FCA will confirm it is investigating.
- Anonymised announcements – for educational purposes for the public or to promote compliance amongst regulated firms.
The FCA is now putting this new policy into practice and seeking to make announcements where possible. We have recently covered the judicial review proceedings brought by an as yet unnamed firm challenging the FCA’s decision to publicly announce that it was under investigation on the basis of exceptional circumstances. Although the firm was successful in obtaining permission for judicial review, its substantive High Court challenge failed on the basis that there was no material misinterpretation of the guidance on announcements in the FCA’s Enforcement Guide and the FCA’s reasoning for justifying a naming announcement was not unreasonable in terms of process or outcome.
Current Listings
The new page currently lists three investigations giving the names of the relevant firms, the first two of which are reactive confirmations which appear to relate to market disclosures (potentially giving rise to Market Abuse Regulation and Listing Rule compliance issues) and a third which may be related to unauthorised activity:
- John Wood Group plc – On 27 June 2025, the company announced it was under FCA investigation in relation to its market disclosures over the period 1 January 2023 to 7 November 2024. This followed an independent review first announced by the company in November 2024 (and updated in March 2025), examining contract reporting and accounting practices, governance, and controls, and assessing whether prior-year financial statements needed to be restated. It seems that the company discovered some accounting issues and commissioned a review by Deloitte which identified “material weaknesses and failures in the Group’s financial culture” in relation to its Projects business, including management pressure to maintain previously reported positions through “unsupported dispensations and over-optimism and/or lack of evidence in respect of accounting judgements”, which appear to have led to information being withheld from auditors or the provision of unreliable information to them.
- Drax Group plc – On 28 August 2025, Drax announced via RNS that the FCA had commenced an investigation covering the period from January 2022 to March 2024 concerning its statements to the market on biomass sourcing and compliance of its 2021, 2022 and 2023 Annual Reports with the Listing Rules and Disclosure Guidance and Transparency Rules. The FCA confirmed the investigation the same day. It has been reported that the investigation follows claims by a whistleblower that the company had misled the market about the sourcing of wood for its biomass pellets. Drax was previously investigated by Ofgem which concluded that an absence of adequate data governance and controls in place had contributed to Drax misreporting data to Ofgem and being unable to satisfy Ofgem regarding supporting evidence for certain profiling data under the Renewable Obligations scheme.
- Moneda Capital Group – On 15 October 2025 the FCA announced it was investigating entities within this Group and a number of people associated with those entities. The FCA has invited anyone who invested with any of the Group companies to contact the FCA. The Moneda Capital website confirms the FCA investigation and that an asset restraint order took effect on 2 September 2025 but states that “the FCA does not wish for us to provide any details beyond confirming that an investigation is ongoing” and anyone seeking further information should contact the FCA directly.
Implications for Firms
- Heightened transparency and reputational risk: Firms named on the FCA’s new page will face immediate visibility among customers, investors, competitors and the media and may be the subject of speculation regarding the matters under investigation. This underscores the need for proactive reputation management and clear communication strategies.
- Regulatory priorities: The FCA’s move signals a continued focus on transparency, governance, accuracy of disclosures and compliance culture including in respect of ESG matters. Firms should expect greater scrutiny of internal controls including disclosure verification and reporting processes.
Practical Steps
- Monitor the FCA investigations page: Set up regular alerts to stay informed about competitor investigations and sector trends. Consider the extent to which these indicate any lessons learned for your own business or areas in which an internal review may be useful to get ahead of the regulatory agenda and evidence proactive senior management engagement.
- Prepare for potential publicity and crisis management: Consider developments/enhancements to internal and external communication plans in the event of receipt of a Notice of Appointment of Investigators. Is potential publicity factored into your crisis management and investigation plans and do internal stakeholders require any training or other support to prepare for dealing with a potential crisis scenario?
- Engage early with the FCA: Early engagement with the regulator can help manage regulatory expectations, influence the narrative and mitigate reputational impact.
