Woodford Investment Management Limited

FCA action

actions

2

most recent

August 2025

• Decision notice issued on 5 August 2025, under appeal

  The FCA has given Woodford Investment Management Limited (WIML) a Decision Notice to impose a financial penalty of £40,000,000. WIML has referred the Decision Notice to the Upper Tribunal. Any findings in the Decision Notice are therefore provisional and reflect the FCA's belief as to what occured and how it considers the behaviour of WIML should be characterised. The proposed action outlined in the Decision Notice will have no effect pending the determination of the case by the Tribunal. The Tribunal's decision will be made public on its website. The Decision Notice has been issued by the FCA deciding that WIML breached Principle 2 of the Principles for Businesses.

• Fined on 19 February 2024

  IMPORTANT: A warning notice is not the final decision of the FCA. The firm and the individual have the right to make representations to the Regulatory Decisions Committee (“RDC”) which, in the light of those representations, will decide on the appropriate action and whether to issue decision notices. The RDC is a committee of the FCA board which decides whether the FCA should give certain statutory notices described as within its scope by the FCA’s Handbook. If decision notices are issued, the firm and the individual have the right to refer the matter to the Upper Tribunal which would reach an independent decision on the appropriate action for the FCA to take, if any. If either the RDC or the Upper Tribunal decides that no further action should be taken, the FCA will publish a notice of discontinuance provided it has the firm and/or the individual’s consent. On 19 February 2024, the Financial Conduct Authority (“the FCA”) gave Woodford Investment Management Limited (“WIM”, FRN: 745433) a warning notice proposing to take action, for the following reasons:  The FCA considers that during the period from 31 July 2018 to 3 June 2019 (“the Relevant Period”) WIM breached Principle 2 (due skill, care and diligence) of the FCA’s Principles for Businesses by failing to act with due skill, care and diligence in the conduct of its business. WIM acted as the investment manager of the LF Woodford Equity Income Fund (the “WEIF”). The WEIF was ultimately suspended on 3 June 2019 due to liquidity issues. The FCA considers that during the Relevant Period WIM failed: • to maintain an appropriate liquidity profile for the WEIF and made unreasonable and inappropriate investment decisions in the face of ongoing redemptions and net outflows from the WEIF; • to implement the applicable liquidity risk framework effectively and applied unreasonable and inappropriate metrics and methodologies to measure liquidity for the WEIF; • to respond appropriately to the ongoing deterioration in the WEIF’s liquidity; and • to pay due regard to warning signs about the WEIF’s liquidity, including concerns raised by Link Fund Solutions Limited (“Link”), the WEIF’s authorised corporate director. The FCA considers that the above failings by WIM materially increased the risk of and/or resulted in the WEIF’s liquidity profile and its associated liquidity framework becoming unreasonable and inappropriate. They also materially increased the risk that the WEIF would need to be suspended and thereby place those investors who did not redeem prior to the point of suspension at a disadvantage.

Customer compensation schemes

The FCA has ordered this firm to review past sales and pay back customers who lost out.

• September 2016 The firm is required to abide by the Deed Poll and Declaration in relation to the past business of the firm or by the past business of Woodford Investment Management LLP for which the firm has accepted responsibility as…