In a Final Notice issued on 24 February 2015, the FCA fined Aviva Investors £17,607,000 (Stage 1: 30% discount: breaches of principles 3 & 8). The FCA concluded that during the relevant period of 20 August 2005 to 30 June 2013, Aviva Investors failed to exercise adequate and effective control over the inherent conflicts and risks associated with its side-by-side management of funds that paid differing levels of performance fees on the same desk within its fixed income business. This incentive structure created conflicts of interest as side-by-side traders had an incentive to favour funds paying higher performance fees over others. The FCA found that Aviva Investors operated a poor control environment as traders could exploit the weakness in the systems and processes to delay recording the allocation of executed trades for several hours. The delay enabled traders to cherry pick trades to increase incentive payments by allocating trades that benefitted from favourable intraday price movements to some funds and trades that did not to other funds. The Final Notice reinforces the FCA’s focus on the effective management of conflicts of interest by asset managers.