THE GRC NAVIGATOR
Your Bi-Weekly GRC Intelligence Briefing
Issue 7 | 15 August 2025
Executive Summary
This fortnight marks a watershed moment for UK financial regulation, with the FCA’s announcement of a potential £9-18 billion motor finance compensation scheme following the Supreme Court’s landmark ruling. The Bank of England cut interest rates to 4% on August 7—the fifth consecutive reduction—signaling a cautious approach to stimulating a sluggish economy despite persistent inflation concerns. Meanwhile, the FCA’s imposition of a substantial £46 million fine against former fund manager Neil Woodford and his firm for critical management failures closes a significant chapter in UK fund management history, sending a strong message about accountability. In the private markets, fundraising momentum continues despite macroeconomic headwinds, with a notable “flight to quality” as capital flows toward large, established funds, while smaller players face a more challenging environment. Taken together, these developments underscore a clear strategic evolution in UK regulation: a pivot toward proactive, systemic enforcement aimed at market-wide remediation and consumer protection.
Top Story: FCA Proposes £9-18 Billion Motor Finance Compensation Scheme
Regulatory Updates
FCA Tightens Payment Safeguarding Rules
The FCA finalised new rules on August 7 to strengthen consumer protection in the event of payment firm insolvency, with the new “supplementary regime” set to take effect on May 7, 2026. These rules, introduced to address weaknesses identified in previous firm failures, establish a significantly higher compliance bar.
KEY REQUIREMENTS:
• Annual audits by qualified auditors – Moving beyond self-certification to independent verification
• Monthly reporting obligations – Real-time supervisory monitoring replacing quarterly retrospective reviews
• Daily reconciliation checks – Ensuring precise safeguarding of customer money
• Resolution planning requirements – Mandatory contingency frameworks for rapid customer fund return
• Enhanced segregation standards – Stricter operational boundaries between firm and client assets
The daily reconciliation requirement will be the most challenging operationally. Firms should invest now in automated reconciliation systems and real-time monitoring dashboards.
Divergence on Sustainability Reporting Framework
Woodford Fine Sets New Accountability Precedent
The FCA’s £46 million fine against Neil Woodford and Woodford Investment Management on August 5, 2025, for “unreasonable and inappropriate investment decisions” establishes critical precedents for fund management accountability. The personal penalty of £5.89 million for Woodford, alongside his ban from senior management roles, sends a clear message about individual responsibility.
GOVERNANCE IMPLICATIONS:
• Personal liability for liquidity management failures now clearly established
• Questions raised about regulatory perimeter as Woodford continues operating W4.0 platform outside FCA oversight
• WIM’s defense citing Link Fund Solutions’ approved framework highlights the complex liability chain in delegated fund administration
• Upper Tribunal referral means final precedent remains pending, creating continued uncertainty
Data Integrity Becomes Priority
Crypto ETN Retail Access Approved
The FCA announced on August 1 that firms will soon be able to offer crypto exchange-traded notes (ETNs) to retail consumers, marking a significant shift in the UK’s approach to digital asset accessibility. This follows extensive consultation on appropriate consumer protections.
Insights: The real opportunity lies in tokenising traditional assets—from fund interests to insurance policies. Boards should establish digital asset strategies now, focusing on operational efficiency rather than speculation.
PRA Developments
Fifth Consecutive Rate Cut Signals Policy Pivot
The Bank of England’s decision to cut the Bank Rate by 25 basis points to 4% on August 7, 2025, marks the fifth consecutive reduction since August 2024. The split MPC vote highlights the delicate balance between supporting economic growth (Q2 2025 growth of just 0.3%) and managing persistent inflation concerns.
KEY IMPLICATIONS:
• Inflation trajectory revised: BoE now expects peak at 4% in September before returning to 2% target by Q2 2027
• O-SII buffer increases: PRA reissued 2024 buffer rates with 27% increase for systemically important institutions
• Net interest margin compression: Banks must recalibrate revenue models amid declining rate environment
• ALM challenges: Institutions face complex hedging decisions with uncertain rate trajectory
UK EMIR Reporting Requirements Updated
The Bank of England and FCA’s joint policy statement on UK EMIR amendments, with changes effective January 26, 2026, demonstrates continued technical refinement of the derivatives reporting framework. The addition of ‘execution agent’ as an optional field and clarifications on FX swap reporting reflect lessons learned from implementation challenges.
CONSULTATIONS:
• Pillar 2A review – Extended to September 30, 2025, aligning with Basel 3.1 implementation
• IRB mortgage approach – Simplification for mid-sized firms through PRA-prescribed LGD values (closes October 31, 2025)
• RT2 and CHAPS hours extension – Proposed 1:30 am opening for settlement (comments due October 21, 2025)
Asset Purchase Facility Q2 Report
Market Participants Survey Results
Fund Launches & Capital Raises
Flight to Quality Defines Private Markets
The private markets in August 2025 demonstrate clear bifurcation: while general fundraising momentum slows, established managers are closing oversubscribed vehicles, indicating a pronounced “flight to quality” among institutional allocators.
FUND CLOSINGS:
• TPG Growth VI: $4.8 billion close, exceeding $4 billion target – Middle Eastern and Asian LP expansion
• JMI Equity Fund XII: $3.1 billion raised in just four months – software focus resonating with LPs
• Pacific Avenue Fund II: $1.65 billion including €100 million European sidecar – sub-4 month fundraise demonstrates LP confidence
• TPG Twin Brook Credit Continuation: $3 billion vehicle led by Coller Capital – largest private credit secondaries transaction to date
• Sound Point Strategic Capital III: $1.1 billion first close – doubling predecessor fund size
STRATEGIC M&A ACTIVITY:
• Advent/Sapiens: $2.5 billion take-private of insurance software provider
• Centerbridge/MeridianLink: $2 billion acquisition just four years post-IPO
• PHP/Assura: £1.9 billion healthcare REIT consolidation defeating KKR
• J.P. Morgan/Chestnut Carbon: $210 million ESG-focused afforestation financing
The compression of fundraising timelines for established managers versus extended periods for emerging managers reflects LP portfolio concentration. Boards of emerging managers must now demonstrate truly differentiated value propositions, not incremental improvements
Enforcement Watch
Sigma Broking Fined £1.08 Million for Transaction Reporting Failures
CAPITAL MARKETS, BROKERS
Criminal Conviction for £1.3 Million Ponzi Scheme
Daniel Pugh was convicted of fraud on August 7 following an FCA prosecution for operating a £1.3 million Ponzi scheme. The successful prosecution demonstrates the regulator’s commitment to pursuing criminal sanctions for serious misconduct.
ENFORCEMENT TRENDS:
• Regulatory technology enabling pattern recognition across millions of transactions
• Personal accountability extending beyond conduct to competence failures
Market Developments
UK Investment Management Industry Reaches Record £10 Trillion AUM
China ETF Market Set to Overtake Japan
China’s ETF market is on track to become Asia Pacific’s largest, overtaking Japan by year-end. This shift has significant implications for UK asset managers seeking Asian market exposure and distribution partnerships.
KEY MARKET INDICATORS:
• Global M&A surge: $2.6 trillion YTD, highest since 2021, AI-driven consolidation accelerating
• InsurTech funding decline: 16.7% QoQ drop despite AI adoption acceleration
• Home insurance complacency: 25% of UK homeowners auto-renewing without comparison shopping
Regulatory Calendar
- 1 September: Economic Crime and Corporate Transparency Act - failure to prevent fraud offence comes into force.
- 12 September: Joint BoE/FCA consultation closes on derivative reporting Q&As
- 30 September: Extended deadline for PRA Pillar 2A review comments
- Early October: FCA motor finance compensation scheme consultation publication
- 21 October: BoE consultation closes on RT2/CHAPS hours extension
- 31 October: PRA consultation closes on IRB mortgage approach
- 19 Jan 2026: UK: UK POATR (Public Offers and Admission to Trading Regime) starts (FCA PS25/9; debt prospectus rules).
- 26 Jan 2026 : UK: UK EMIR trade repository reporting amendments take effect.
- 7 May: FCA “Supplementary Regime” for safeguarding (payments/e‑money firms) takes effect (PS25/12).
- 2 Jul 2026: EU: ESG Ratings Regulation begins to apply (cross‑border restrictions and third‑country regime in force).
Question of the Week
How should boards reset their 2025–26 planning assumptions when macro–market correlations have broken down—against (i) potential £18bn motor-finance redress, (ii) a fifth straight rate cut squeezing margins, and (iii) record £10tn AUM alongside 0.3% GDP growth?
We welcome your perspectives on this challenge.
Insights:
• The motor finance compensation scheme means the era of “industry practice” as a defense has ended; boards must now evaluate every intermediated distribution channel for retrospective liability.
• The bifurcation in private markets—where quality trumps quantity mirrors what occurred in Asian markets post-2015: consolidation is inevitable, differentiation is survival.
• The record AUM amid economic stagnation suggests we’re witnessing a structural shift where global capital flows override domestic fundamentals.
Firms should leverage compliance into an offensive weapon—using robust governance to access cheaper capital, attract institutional allocators, and pre-empt regulatory intervention.