Happy Holidays. Have some fines.

It isn't just you.  The FCA and PRA enforcement teams have been unusually busy this December.  The busiest they've been at any time of year in the last five years, with Final Notices imposing 6 fines totalling £182m.  (Though it's true that it's becoming a habit of theirs disproportionately to take action in December.)

And that doesn't even include December's five FCA Decision Notices to individuals totalling £952,700 which those individuals have referred to the Upper Tribunal.

Here I was thinking that Christmas shoppers were the only ones whose hip pockets feel lighter at this time of year.

These charts tell the story.

Surely there won't be any more enforcement actions between Christmas and New Year.  So: now the dust is, presumably, settling - what are the key takeaways from this December's fining frenzy?

• Expect the FCA to use its enforcement powers alongside its other supervisory interventions power to address systemic issues e.g. its December pensions transfer advice fine - the first in connection with the British Steel Pension Scheme in respect of which it's also established a redress scheme, imposed asset retention rules and made OIREQs.
• Caveat your market disclosures especially when they're based on regulatory reporting requirements.  And a bonus from this one: expect the FCA ever more creatively to interpret and apply its penalty policy.
• AML systems and controls are an ongoing area of focus.  Foster first-line ownership of AML risk management, de-silo your AML teams (and attend to their resourcing requirements), and review your ongoing monitoring including automated transaction monitoring.
• Exercise close oversight (extending even to a technical level) of outsourced IT service provision in particular during systems migrations.  (Presumably enforcement risk rises with impact on retail.)
• Market abuse automatic surveillance should cover the breadth of your traded product types, ingest substantial voice-brokered order volume, use meaningful sample size in sample-based monitoring strategies, and when it comes to oversight and challenge - document, document, document!