FSA’s themed programme looking at sales of geared traded endowment policies has led to two enforcement decisions. It fined one firm £35,000 and the other £10,500. It also banned individuals at one firm from performing controlled functions (one individual could no longer act as compliance officer or MLRO, but kept his other functions). The firms did not:

  • gather enough information about customers; 
  • make sure their advisers and customers properly understood the products and risks; and in one case 
  • properly review sales.

The levels of the fines reflected the costs of review exercises and the firms’ likely ability to pay redress to any customers their actions had disadvantaged.