FCA announces new senior role, Enforcement Guide update

The Financial Conduct Authority (FCA) has appointed Sarah Pritchard to the newly established role of deputy chief executive, as the regulator intensifies its efforts to modernise enforcement procedures and manage an expanded regulatory perimeter.

The move comes amid a period of heightened reform across the UK’s financial oversight regime. It coincides with a major revision of the FCA’s Enforcement Guide and follows the recent absorption of new responsibilities related to crypto assets, stablecoins and payments regulation.

Leadership Restructuring Reflects Broader Strategic Agenda

Pritchard’s appointment marks the first time the FCA has had a formal deputy chief executive role. She will hold the post in conjunction with her existing responsibilities leading the supervision, policy and competition division, as well as the regulator’s international strategy.

Since joining the FCA in 2021, Pritchard has been involved in capital markets reform, pension oversight and regulatory engagement with global standard-setters, including the G20 and Financial Stability Board. Her appointment is understood to be designed to support the FCA’s growing list of functions, including its oversight of buy now, pay later (BNPL) lenders and non-bank financial institutions.

Prior to her time at the FCA, Pritchard served as director of the National Economic Crime Centre, general counsel at the National Crime Agency and held senior compliance roles at HSBC. She also began her career in private legal practice.

FCA chair Ashley Alder said the regulator's board supported the appointment in light of rising external demands. Chief executive Nikhil Rathi noted that Pritchard had played a key role in major projects and the integration of the FCA’s operational divisions. He described the new strategy as a “collective endeavour.”

Enforcement Framework Overhauled

Separately, the FCA has implemented a comprehensive update of its Enforcement Guide—now referred to as the ENFG—applicable to all new investigations opened from 3 June 2025. The previous version, in place since 2007, has been substantially revised following a two-stage consultation process.

The updated guide removes more than 250 pages of content deemed duplicative or outdated. Among the most notable adjustments is a shift in the regulator’s stance on publicity: plans to publicly identify regulated firms under investigation, based on a discretionary ‘public interest’ test, have been abandoned. Instead, the FCA has retained the narrower 'exceptional circumstances' approach while allowing for new, specific cases in which publicity may be justified.

These include suspected criminal activity in unregulated financial services, cases where the investigation is already public knowledge, and anonymised announcements intended to improve compliance awareness.

The regulator has also clarified its position on legal representation at compelled interviews, signalling that legal advisers with potential conflicts—such as those representing multiple parties—may be excluded from attending. Firms have been advised to ensure employees have access to independent counsel where necessary.

Implications for Regulated Firms

The revised ENFG also formalises existing practice regarding the submission of privileged reports. The FCA will continue to accept such material on a limited waiver basis but without accepting constraints on how it may be used. Additionally, references to enforcement tools such as private warnings and preliminary findings letters have been removed, reflecting changes in how the FCA communicates with firms under investigation.

Further adjustments include widening the pool of FCA officials authorised to initiate enforcement proceedings and moving certain regulatory guidance to other sections of the FCA Handbook. These include powers of intervention and supervision, now relocated to the Supervision Manual, and decision-making processes, now under the Decision Procedure and Penalties Manual.

The reforms come against the backdrop of the FCA’s 2025–30 strategy, which emphasises faster, more focused enforcement. According to the regulator, the number of open investigations has dropped by more than a third since April 2023, and none of the cases initiated since then have closed without resulting action.

Relevance for the Mortgage Sector

While primarily operational in nature, the changes to the FCA’s leadership and enforcement framework are expected to influence how mortgage lenders and intermediaries engage with the regulator. Pritchard’s continued oversight of competition and consumer matters, as well as the FCA’s growing role in digital lending and payments, may also shape future interventions in the mortgage markets.