The Financial Conduct Authority’s decision to seek an injunction against Neil Woodford and his UAE-based platform, W4.0, is a strikingly early and proactive intervention in an area that tests the UK regulatory perimeter.
The action also reflects the regulator's continuing focus on overseas firms whose services are accessible to UK consumers. At one level, the FCA's case is relatively straightforward. It alleges that Woodford and W4.0 are conducting regulated activity (providing investment advice and promoting investments to UK consumers) without authorisation through a subscription-based platform. Rather than waiting for a full enforcement process to run its course, the regulator has moved directly to injunctive relief, an unusual step which underlines the perceived need to act quickly. In reality...
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