The Boardroom · 5-Minute Read
The First 72 Hours of an FCA Investigation
Anjali MehtaCounsel, Financial RegulationJuly 2025
The first 72 hours after a firm receives notice of an FCA investigation shape the regulator's view of that firm for the rest of the process. Three priorities for that window.
01 — Preserve, don't explainSecure relevant records and communications before responding substantively. An early, incomplete explanation is harder to correct later than a short delay for a considered one.
02 — Decide the cooperation posture at board levelNot every fact needs to be contested. Deciding, early and deliberately, where the firm will cooperate and where it will contest sets the tone for the entire investigation.
03 — Separate the internal investigation from the regulatory responseRun in parallel with clear coordination, not as a single undifferentiated workstream — conflating the two is one of the most common and costly mistakes we see.
Firms that treat these first three days as a discrete, board-level decision point — rather than delegating the initial response entirely to compliance — tend to reach better outcomes across the life of the investigation.