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Legal implications of the FCA’s new non-financial misconduct rule

A woman being distracted from her spinning, early 14th century. A man is putting an arm around her shoulder and reaching out to touch her bottom. From decretals of Pope of Gregory IX. Creator: Unknown.
Photo: Heritage Art/Heritage Images via Getty Images

David Berman | Covington, Emily Lemaire | Covington

4 min read
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New rule, COCON 1.1.7FR, expands the scope of COCON for non-banks in the context of NFM and comes into force on September 1, 2026.

On July 2, 2025, the FCA published a further consultation paper (CP25/18) on tackling non-financial misconduct (NFM) in financial services, containing a Policy Statement with finalized rules on NFM to come into force and proposals for new Handbook guidance on the application of the new rule.

The FCA initially consulted on its

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