Less than one month into 2025, the financial services sector is already abuzz with discussions and analyses concerning the diverse compliance and regulatory challenges anticipated this year.

 

These topics were at the forefront of our recent TCC compliance forums, hosted by our in-house regulatory specialists. In this summary, we delve into the critical areas highlighted during the forums that we facilitated over the course of 2024 in a handy overview of the key issues that we expect for financial service compliance in 2025.

The current regulatory landscape

  1. The FCA has concerns over the financial resilience of firms, the accuracy of resilience testing, the likelihood of insufficient wind-down plans and the potential impact on clients where the above can create poor behaviours and decision making. ​
  2. UK consumers continue to rely on short-term credit, often on a repeat basis. This dependency indicates the probability of arrears and vulnerability, which (based on significant and costly FCA censure in 2024) firms still do not consistently and fairly assess or address.​
  3. The FCA continues to focus on the financial vulnerability of customers, compounded by some firm’s lack of appropriate consideration of individual circumstances regarding actual and potential future vulnerability.​
  4. The Consumer Duty outcomes – in particular, product price and fair value – continue to be under scrutiny. Key areas include Discretionary Commission Arrangements (DCAs), ongoing service advice and self-invested personal pensions (SIPPs). The regulator is also aware that fees and commissions are not consistently aligned with the Consumer Duty and monitored.​
  5. The recent fines issued to large UK companies demonstrate that firms are preoccupied with business as usual and fail to ensure appropriate controls and/or control testing are in place. This specifically applies to the areas of fair value in closed books, arrears and customer vulnerability.​
  6. The FCA is expected to increasingly challenge senior management and boards to demonstrate a more in-depth understanding of how they discharge duties, such as why/how the situation went wrong on their watch.​
  7. Areas of training and competence are currently mostly treated as a tick-box exercise that lacks depth. Firms will be expected to take proactive steps to address this challenge, which can be limited by the firms’ ability and/or appetite for change.

Key risks and next steps

“Be proactive. Don’t wait for us to intervene, we expect our firms to lead from the front.”​ FCA

Risk 

Next step

Cumulative 

Censure demonstrates that the longer a weakness exists, the more likely customers will feel its impact.  

 

We urge firms to thoroughly review their systems and controls, particularly regarding known risk areas such as price, value, DCA, and ongoing services. TCC’s experienced team can advise on risk-based provisioning and planning for worst-case scenarios, including resource availability and cost. You can utilise our experts and experienced teams to address your immediate resource needs for business continuity.

Perception

The regulator is increasingly questioning the reasons and methods by which senior management may have permitted risks to materialise, resulting in negative consequences on both a collective and individual level. Regulatory intrusion is costly, stressful and distracting. It can affect the firm and individual careers.

 

TCC can benchmark your firm against your wider peer group, highlighting your strengths and comparative weaknesses, and the possibility of being an outlier.​ Perception can affect your stakeholder relationships and reputational risk. We can help review your past operations and introduce you to sophisticated AI to ensure business-as-usual processes are compliant and evidence outcomes.

Culture

Culture is explicitly reflected in both the actions a firm takes and those it chooses not to, even when it is reasonably expected. Equally important is how well colleagues comprehend and embody company culture. The most detrimental behaviours often stem from overpowering personalities and, conversely, the risks associated with ‘groupthink.’ Neglecting to address these issues can be perceived as intentional misconduct.

 

The FCA is emphasising the behavioural role that senior management should fulfil. TCC is equipped to assess your firm’s evidence of cultural and conduct metrics, alignment with risk appetite, comprehension of regulatory risks, conduct risk and cultural maturity to provide insightful analysis to help drive any necessary improvements.

Systems and controls

Evaluating systems and controls is intrinsically linked to assessing organisational culture. Companies should establish necessary controls based on complexity and proportionality rather than fitting them to align with predetermined budgets. The guiding principle should be ‘show me, don’t tell me,’ with SMFs expected to demonstrate their delivery methods.

 

Regulatory fines often highlight concerns that companies may not adequately scrutinise their controls, pointing to potential competence or organisational culture issues. We offer a comprehensive review of your key systems and controls, including monitoring and audit plans, to help you benchmark your performance and enhance control effectiveness with our recommended solutions for future success. Utilising reliable, established AI technology, we can help inform your decision making with accurate comprehensive data and MI.

Corporate governance

The organisational structure, encompassing committees and the three lines roles, should be clearly defined and widely understood. There should be a unified risk appetite and consistent metrics. Oversight should narrate a compelling story of challenge, debate, and transparency. Conflicts of interest must be explicitly identified, with quantifiable controls, and SMFs should be able to articulate and demonstrate the execution of their responsibilities clearly.

 

Senior management is not meant to be a comfortable space. We can help you benchmark and evaluate your corporate governance strategies, ensuring that your behaviours and controls effectively demonstrate best practice at the board level and within the SMCR framework. You can rely on our interim regulatory experts to introduce strategies and help you set up operations for a long-term compliant future.

Tackle compliance challenges with ease

For over two decades, TCC’s experts have assisted financial service firms in navigating their compliance challenges and successfully meeting regulatory outcomes. Our specialised teams offer a one-stop compliance solution:

  • An unbiased review and strategic advice to help you achieve your compliance objectives in 2025.
  • Comprehensive outsourcing solutions to address your compliance needs, providing a pragmatic and value-driven service across a wide array of products.
  • Access to a team or individual experts tailored to your specific resource requirements. TCC’s Specialist Resourcing connects you with a vast network of over 5,000 pre-vetted subject matter experts, covering the entire spectrum of financial services specialisation.
  • Where suitable, we combine our smart people with smart tech from our sister company, Recordsure, to help firms drive operational efficiencies and evidence outcomes to satisfy the regulator. With Recordsure AI firms have unique oversight of client interactions, ensure processes and compliance, and have access to actionable data and MI.

No matter the expertise your projects require, we have the compliance solution to support you.

Contact us