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FPPP post-mortems29 October 2026 · next edition Thursday

Where the procedures failed, and what would have caught it

A casebook, not a news feed. Each entry takes a case where a regulator, a court or the company itself has said that financial position and prospects procedures fell short, and names the criterion in the pack whose evidence test addresses it.

The takeaway

The window was quiet on cases where an authority has stated that a listed or recently-listed company's financial position and prospects procedures failed. Two FCA actions on financial crime and governance controls are included because the regulator stated the failures; neither is an FPPP finding.

  • The FCA stated that six Annex 1 firms had AML policies, controls and procedures that raised concerns during authorisation; restrictions were imposed at the firms' request.
  • The FCA found that a former chief executive acted as a front for a disqualified director at an authorised firm, and banned and fined him.
  • No FCA final notice, FRC sanction, restatement, material weakness disclosure or late-accounts suspension in the fetched items states that a Main Market applicant's FPPP fell short.
  • Profit warnings and trading updates in the window are not evidence of procedural failure and have not been used as such.

Cases published 15 to 29 October 2026 · mapped to the criteria that address them

This edition of the FPPP post-mortems looks for cases where a regulator, a court or the company itself has stated that financial position and prospects procedures, or the controls that feed them, fell short. The window produced almost nothing of that kind. Most of what was fetched is routine: FCA speeches, consultation papers, complaints statistics and trading updates. None of those is evidence that procedures failed, and none is treated here as such.

Searched the FCA news and publications feeds, the FRC news feed and Investegate RNS and PRN announcements for 15 to 27 October 2026. The FRC item fetched was a final settlement notice against an audit firm and an individual, which is an audit enforcement matter and not a statement about a company's FPPP, so it was not used. The trading updates, suspensions on AIM and Aquis, and complaints data did not contain any authority statement that procedures failed. The two entries above are the only ones in the fetched material where a regulator stated that controls fell short; neither concerns a Main Market FPPP confirmation.

1. Anti-money laundering controls that did not meet the threshold for authorisation

The FCA said on 23 October 2026 that it had placed restrictions on six unregulated lenders, described as Annex 1 firms, after raising concerns about their anti-money laundering policies, controls and procedures while assessing their applications. The regulator said the restrictions were imposed at each firm's request and limit their ability to take on new customers or do new business with existing customers, including extending existing arrangements. The FCA attributed the concern to the AML policies, controls and procedures it reviewed during the application process; the firms are not named in the item. This is a financial crime controls finding at authorisation stage, not a finding on FPPP, and it is included only because the FCA stated the controls fell short.

What would have caught it: A named owner for financial crime controls in the procedures pack, with the AML policies, controls and procedures evidenced and dated before the application is submitted, so that gaps are closed rather than discovered by the regulator during assessment.

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2. Senior manager acting as a front for a disqualified director

The FCA said on 21 October 2026 that it had banned Jeffrey Dawkins, former chief executive of Vector Wealth Ltd, and fined him nearly £270,000, after finding that he dishonestly acted as a front for a disqualified director. The FCA said that in 2019 Mr Dawkins sold Vector Wealth to a disqualified director who described himself as chief executive and wanted to use the firm's FCA-authorised status to sell high-risk bonds, and that the misconduct led to £4 million of losses in those investments. The finding is the FCA's own, made in a final notice; the item does not record an appeal.

What would have caught it: A documented change-of-control and approved-persons check in the governance section of the pack, evidencing who actually directs the business and confirming that no disqualified or otherwise prohibited person sits behind an authorised firm.

Touches fb-3, mr-1 — check yours · run the free scan

Sources

It was found in their procedures. Is it open in yours?

Every case above names the criteria it touches. The free scan walks 15 of the 73 across all nine FPPP areas, checks your answers against each other, and tells you where they contradict. It runs entirely in your browser — nothing is sent anywhere, and nothing is stored.

Run the free scan →Read all 73 criteria

Published Thursdays. This is a casebook rather than a news feed: an older case that has not been covered is as welcome as a recent one. Compiled from public regulatory notices, court judgments and companies’ own announcements, and cited to them. It is not legal advice, not investment advice, and not a comment on any company’s prospects or securities.

Earlier editions