LIBOR/EURIBOR-related bans

The regulator confirmed it will take no further action against them on this matter. This follows similar moves last year for Tom Hayes and Carlo Palombo after their convictions were quashed. For compliance teams, this is a reminder that enforcement outcomes can be unwound when underlying criminal convictions fall.

Firms should audit legacy records, screening databases, reference materials and due diligence files for references to the revoked final notices or bans. Any internal disciplinary, employment, or third-party risk assessments that relied on those convictions should be reviewed and corrected. Training and escalation policies should reflect that FCA enforcement is not immutable.

Although the direct market impact is limited, the reputational and legal implications of retaining outdated adverse information can be material. No new regulatory obligations arise, but proactive record remediation will reduce the risk of inaccurate disclosures or unfair treatment. Compliance leaders should confirm that no business area continues to rely on the quashed convictions, and that relevant teams understand the change.

Given the FCA's statement, no immediate filing or notification is required, but firms should document their review for audit purposes.