The enforcement process against financial services firms by the UK Financial Conduct Authority and the Swedish Finansinspektionen with a focus on independence, transparency and the calculation basis of financial penalties

November 2025

Abstract

The aim of this paper is to address the separate processes followed by the UK Financial Conduct Authority and the Swedish Finansinspektionen (Swedish Financial Supervisory Authority) on enforcement actions against financial entities operating in their respective market and the calculation methodologies utilised when imposing financial penalties.

Authors

Sofia Skroubi

Head of Legal Europe, Regulatory & Commercial, FNZ Group, Sweden

Sofia Skroubi,MCSI has an LLB,Honors in English &European Laws and Masters(LLM) on International Trade Law&Finance from Essex University.She is admitted as a Solicitor of the Senior Courts of E&W and as an Attorney-at-Law of the Athens BarAssociation. She began her career as an asset finance associate in private practice, providing counsel to leading international banks. She moved in-house in 2006 as a financial services lawyer, initially with J P Morgan and later with the Bank of New York, HSBC Bank and Nasdaq Exchange. She has extensive experience in senior legal leadership roles, having served as Managing Director for many years. Her expertise covers securities services, with a particular focus on liquidity management, global custody&clearing, triparty and derivatives collateral management, securities financing and network management. Throughout the years she was primarily based in London and most recently in Stockholm; however has also supported business activities in New York, Asia and Paris with relevant in-country secondments. She is currently employed by FNZ Group as Head of Legal Europe, Regulatory & Commercial. She is a certified accredited full Member of CISI since 2015.

Andreas Gustafsson

Partner, Stockholm University - Swedish Corporate Governance Institute, Sweden

Andreas Gustafsson has 25 years of experience in the financial market, as General Counsel Europe at Nasdaq and Chairman of Nasdaq Stockholm AB, as well as at the Swedish Financial Supervisory Authority. His team twice won the FT Innovative Lawyers Award in technology (2018) and ESG (2023). He has also been a member of several stakeholder groups such as Swedish self-regulatory bodies, ESMA, EFRAG and CityUK’s Leadership Council as well as International Regulatory Strategy Group. He is currently a Visting Fellow at the Swedish Corporate Governance Institute, Stockholm University, and member of the Swedish Corporate Governance Board.

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The enforcement process against financial services firms by the UK Financial Conduct Authority and the Swedish Finansinspektionen with a focus on independence, transparency and the calculation basis of financial penalties

Abstract

Authors

Companies

FNZ Group

Stockholm University - Swedish Corporate Governance Institute

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