FSA Conflicts of Interest Safeguards

The UK Financial Services Authority has recently published an important report that builds upon a series of late 2011 and early 2012 “thematic reviews” of FSA-authorised investment managers (the “Report”). The Report, which focuses (at length and with specific examples) on numerous failures to identify, monitor and mitigate conflicts of interest in ways that meet the FSA’s expectations, is more direct in its tone and in its content than has been seen in such circulars previously and may presage a new era of vigorous FSA enforcement.