Therese Chambers, joint executive director of enforcement and market oversight at the FCA, was the keynote speaker at the Market Abuse and Market Manipulation Summit 2025 in London last week.

In her speech, she discussed three key factors that, in her words, underpinned the FCA’s overall strategy to combat market abuse and market manipulation. The UK’s senior regulator also spoke how about the FCA was streamlining transaction reporting requirements to reduce burdens on firms, and insisted that collaboration between the industry and the regulator was crucial “to complete the market integrity “jigsaw”.”

Part of her speech also focused on how organized crime groups (OCGs) posed the most serious threat to markets, and how the regulator was “prioritizing efforts to disrupt their operations.”

She opened by reminding the audience that a lot had changed since February 2024 (when she last spoke at the Summit), the most obvious change being a new government, and a greater emphasis on economic growth.

But she also insisted that a lot of good work and improvement had taken place as a result of the collective efforts of the industry, the regulators and other stakeholders.

“Bit by bit, day by day, week by week, large groups of people, all playing their small but impactful part, to help solve the whole puzzle, to see the big picture at the end,” she said.

Fighting financial crime

The FCA’s recently announced five-year strategy was also mentioned, with a commitment to fight financial crime being a core pillar of the overall programme.

The FCA boss specifically touched upon the work the regulator was doing to prevent market abuse and market manipulation.

“Cleaner markets instil confidence, which encourages investment into our markets, which encourages growth and innovation. It’s a virtuous cycle,” she added.

The direct co-relation between market cleanliness and economic growth was also mentioned. She insisted that the two go hand in hand in order to achieve a desired outcome.

She also mentioned the FCA’s top three objectives going forward, which included:

• “to understand more across more markets;
• “to work with you to stop market abuse before it happens;
• “to punish and deter offenders.”

Predictable

Predictability meant being transparent and consistent, and explaining to the industry what the regulator was doing, and why it was doing it, so that the industry understands what to expect.

The subject of reporting requirements and information sharing also came up, with a promise that the regulator was trying to reduce the burden on the industry in regards to the information it had to submit. FCA publications such as the MarketWatch newsletter and Primary Market Bulletins (PMBs) were praised for being very useful to the industry, both for flagging unsatisfactory behaviour and as training material.

The publications, she said, had helped the regulator and the industry identify areas which posed the greatest risk, so that priorities can be focused in that direction. These areas include:

• “the scale of organized crime group (OCG) insider trading, and how firms must be alert to client behaviors which suggest membership of OCG;

• “identifying and managing the risk of inadvertently facilitating insider dealing by actors who mask their identities through overseas brokers; and
• “the importance of good governance around market abuse surveillance and data in safeguarding market integrity.”

Sponsor roundtables and policy forums were also highlighted and praised for providing a good opportunity to the regulator to engage face to face with industry representatives.

Proportionate

Chambers explained that removing or reducing reporting requirements in some areas meant that the information the regulator did collect was of even greater value. She insisted on maintaining a healthy balance between reducing burden on firms around information sharing, and ensuring ensuring market integrity and trust.

“We will be proportionate where the value of data does not justify its cost, and consult on removing fields which are not regularly used, such as some of the indicator fields,” she promised.

Chambers also stressed the importance of transaction reports in the regulator’s work to identify and act against market abuse and market manipulation, since they provided a unique view into the markets during volatile times.

There was also an acceptance that the regulator was now increasing its risk appetite in a calculated way to support the government’s economic growth agenda. It was referred to as another example of the regulator’s proportionate approach.

“An example of how we’re willing to innovate and take more risks is our plan for a ‘Private Intermittent Securities and Capital Exchange System’, or PISCES,” she added.

Purposeful

Being purposeful meant that the regulator’s work and decisions needed to be “deliberate, targeted, and focused on outcomes that truly matter.” There was also a clear warning that the regulator will “intervene where firms persistently discharge their responsibilities poorly.”

The onus was put on firms that provided trading services to have adequate systems and controls to identify and report market abuse.

“This isn’t just a nice-to-have – it’s a fundamental responsibility, and one that supports the virtuous cycle I mentioned earlier.” Chambers clarified.

There was also a useful piece of advice for firms in the end, that they should not be afraid of abandoning a corporate relationship if it didn’t fit their risk profile and could cause harm down the line. And a warning for so-called bad actors, that the regulator will using its full tool kit to detect misconduct and disrupt bad actors before they could cause any major harm.

“The challenges in prosecuting insider dealing are significant: sophisticated communications, international culprits, and outdated legislation. But our appetite for tackling difficult cases remains strong,” she said in conclusion.