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FCA guidance on non-financial misconduct: Top 12 takeaways from CP25/18

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Photo: A. Snyder/Getty Images

Lorraine Johnston | Ashurst, Jake Green | Ashurst, Nathan Willmott | Ashurst, Ruth Buchanan | Ashurst, Crowley Woodford | Ashurst+3

5 min read
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Ashurst set out the key takeaways from the paper, which is clearly important – but not for the reasons the FCA has given.

On July 2, 2025, the FCA published CP 25/18, announcing major changes to its conduct rules. 

The paper was eagerly awaited by industry, which had sought greater clarity around how non-financial misconduct (NFM) in firms should be treated under existing Conduct Rules (COCON) and fitness and propriety assessments. (The FCA’s mantra that

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