One of the most significant fines of 2014 was the fine imposed on Invesco Perpetual in April 2014 of over £18 million for breaches of Principles 3 and 7.

1. The FCA found that it had failed to take reasonable care to ensure that the systems and controls that it put in place around the front office of its fixed income business were sufficient to
   1. record trades on a timely basis and
   2. to enable it to value the funds it managed accurately.
2. This included a failure to invest adequately in the systems and controls around its front office.
3. The case is also significant in that it is an example of FCA taking enforcement action when it identifies a risk rather than actual detriment.
4. As the FCA stressed in a press release when announcing the fine:
   1. “As a forward looking regulator, the FCA takes action where we see risks to consumers, not just after they suffer losses.”

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