After a record-breaking year of fines, the FCA has had a relatively quiet start to 2025. We analyse the nature of the breaches behind penalties dished out in the first few months of the year.
With nearly half the year behind us, the FCA has issued a total of £13m if we include Odey Asset Management's provisional fine for lack of integrity. Most of the FCA fine amount goes towards a single milestone penalty against a Recognised Investment Exchange (RIE).
With patterns of failures related to financial crime and misconduct emerging, it is more important than ever for staff, including senior management, to engage in FCA compliance training. The consequences of inadequate advice or misleading information in financial services can be detrimental, resulting in heavyweight penalties.
Top FCA fines in 2025
- The London Metal Exchange (LME) - £9.2m fine
- Mako Financial Markets Partnership LLP - £1.6m fine
- Arian Financial LLP - £288k fine
- Infinox Capital Limited - £9k fine
We continuously track the largest Financial Conduct Authority (FCA) fines and identify trends in breaching FCA rules year on year.
The biggest FCA fines 2025 in detail
Here is a breakdown of the most significant penalties of the year and the reasons behind them.
1. The London Metal Exchange (LME) (fined £9.2m)
Breaches of REC 2.5.1 paragraph 3(1), 3(2)(h) and Article 18(3)(a),(4) of MiFID RTS 7
The UK FCA issued a £9.24 million fine to the London Metal Exchange (LME) for serious failings in its systems and controls during a period of extreme market volatility in March 2022. This is the FCA's first enforcement action against an RIE and underscores the importance of robust governance and crisis preparedness in regulated financial markets.
The fine follows the LME's mishandling of unprecedented price surges in nickel futures, which more than tripled in value between 4 and 8 March 2022. The exchange's response was marred by weak escalation processes, inadequate real-time monitoring, and poorly managed price control mechanisms. The LME suspended its nickel market for eight days and cancelled trades from 8 March without sufficient oversight from senior management. Staff lacked the training to recognise market disorder, and communication protocols failed to escalate critical issues appropriately.
The FCA's investigation found the LME in breach of the Recognised Investment Exchanges sourcebook and MiFID RTS 7 standards. While the LME had taken corrective steps since the incident, including commissioning an independent review, its prior provision of inaccurate information aggravated the situation. The penalty was calculated based on the seriousness of the breach, adjusted for mitigation and early settlement.
2. Mako Financial Markets Partnership LLP (fined £1.6m)
Breaches of PRIN 2 and PRIN 3
The FCA has fined Mako Financial Markets Partnership £1.66 million for serious failings in its financial crime controls related to cum-ex trading. This marks the FCA's eighth enforcement action in this area, with total fines now exceeding £30 million.
Between 2013 and 2015, Mako facilitated over £90 billion in equity trades for the Solo Group across Danish and Belgian markets, earning around £1.45 million in commissions. The FCA determined that these trades were circular and appeared designed to enable improper withholding tax (WHT) reclaims. Some individuals involved have already been convicted in Denmark.
Mako failed to detect several warning signs, including purpose-less transactions that caused a €2 million loss for a Solo Group controller while benefiting associates. The firm also accepted payments from a third party in the UAE to settle debts without conducting adequate due diligence, heightening the risk of money laundering.
"Mako failed to spot clear red flags and facilitated highly suspicious trading that made it vulnerable to being used to support financial crime."
By not contesting the FCA's findings and agreeing to settle, Mako received a 30% discount on its fine. The FCA stressed that financial institutions must maintain strong safeguards to prevent being used for financial crime, warning that such failures damage the credibility of UK markets.
3. Arian Financial LLP (fined £288k)
Breaches of PRIN 2 and PRIN 3
The FCA has fined interdealer broker Arian Financial £288,962 for failing to maintain effective anti-financial crime systems and controls, exposing the firm to potential misuse in fraudulent cum-ex trading and money laundering by clients of the Solo Group.
Between 2014 and 2015, Arian executed approximately £52 billion in circular over-the-counter equity trades in Danish and Belgian markets, earning around £547,000 in commissions. These trades facilitated withholding tax (WHT) reclaims by the Solo Group, with over £888 million paid out by Danish and Belgian tax authorities based on the suspicious transactions.
Although Arian admitted to the FCA's findings, it challenged the size of the fine at the Upper Tribunal. The Tribunal upheld the FCA’s conclusions but reduced the penalty from £744,745 to just under £289,000, adjusting for certain fees Arian had paid to Solo and a broker involved in the trades.
This case is the FCA’s seventh enforcement action related to cum-ex and WHT schemes, bringing total fines in this area to more than £22 million. The FCA criticised Arian for missing clear warning signs and failing to provide an adequate defence against financial crime.
"Arian failed to identify red flags which ought to have been obvious. The controls the firms we regulate have in place are an important line of defence against our financial system being abused for criminal ends. Arian’s fell short of what we expect. We are pleased that the Tribunal recognised the seriousness of Arian’s misconduct."
4. Infinox Capital Limited (fined £9k)
Breaches of Article 26(1) of MiFIR
The FCA has fined Infinox Capital Limited £99,200 for failing to report over 46,000 transactions, potentially allowing market abuse to go undetected. Between October 2022 and March 2023, Infinox did not submit required transaction reports for single-stock contracts for difference (CFDs) traded through a corporate brokerage account—this account represented the bulk of its CFD business.
Although a third-party review helped Infinox identify the issue, the firm failed to alert the FCA. Instead, the regulator uncovered the reporting failures through its own monitoring. The case revealed significant weaknesses in Infinox’s systems and controls for handling transaction reporting on high-risk products.
This is the first FCA enforcement action for breach of transaction reporting obligations since the UK implemented the Markets in Financial Instruments Regulation (MiFIR), marking a notable step in reinforcing market transparency and oversight.
"As a data-led regulator, it is vital that firms submit accurate and timely transaction reports, and promptly bring any failures to our attention. Infinox failed to do this, which meant market abuse could have flown under the radar and risked the integrity of the market."
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Written by: Emmeline de Chazal
Emmeline is an experienced digital editor and content marketing executive. She has a demonstrated history of working in both the education management and software industries. Emmeline has a degree in business science and her skillset includes Search Engine Optimisation (SEO) and digital marketing analytics. She is passionate about education and utilising her skills to encourage greater access to e-learning.
