FCA revokes LIBOR bans: enforcement credibility and the cost of relying on criminal convictions

The Financial Conduct Authority has closed one of the most high-profile enforcement chapters of the past decade. On 16 October 2026 it revoked the bans imposed on Colin Bermingham, Philippe Moryoussef, Jonathan Mathew and Christian Bittar, and removed their Final Notices from FCA channels, after the Court of Appeal overturned the criminal convictions on which those bans rested (FCA). The regulator confirmed it will take no further action against the four.

Key Executive Takeaways

• The FCA has withdrawn industry bans against four traders linked to the LIBOR and EURIBOR cases after their convictions were quashed, and will pursue no further action against them.
• The reversal follows last year's discontinuation of proceedings against Tom Hayes and the revocation of Carlo Palombo's ban after the Supreme Court quashed their convictions, signalling a systemic unwinding rather than a one-off correction.
• Boards and heads of compliance should reassess how far their internal conduct findings, dismissals and references depend on parallel criminal outcomes that may not survive appeal.

The immediate significance is reputational, both for the individuals and for the regulator. The FCA's action follows its decision last year to discontinue proceedings against Tom Hayes and revoke Carlo Palombo's ban after the Supreme Court quashed their criminal convictions (FCA). Taken together, these reversals represent an orderly dismantling of the enforcement architecture built around the benchmark-rigging prosecutions. The regulator is not conceding error in its original judgement, but it is accepting that where the criminal foundation falls away, the regulatory consequence cannot stand alone.

For general counsel and chief compliance officers, the practical lesson is about dependency risk in enforcement strategy. The FCA's bans in these cases were anchored to convictions secured by the Serious Fraud Office. When those convictions were overturned, the regulatory sanction had no independent evidential spine to fall back on. Firms that structured internal findings, dismissals, clawbacks or regulatory references around the same criminal outcomes now face their own cleanup. Any employee who was exited on the strength of a conviction later quashed has a stronger platform to challenge references issued under the Senior Managers and Certification Regime, and potentially to seek redress for lost earnings and reputational harm.

There is also a wider signal about how the FCA frames individual accountability going forward. The benchmark cases were, for years, the showcase for the proposition that misconduct in wholesale markets would be met with personal consequences. Their unwinding does not reverse that policy ambition, but it raises the evidential bar the regulator will want to clear before pinning career-ending action on contested interpretations of market practice. Expect enforcement teams to invest more heavily in standalone regulatory cases built on their own record, rather than riding on prosecutorial coat-tails. That shift tends to mean longer investigations, narrower charges and more negotiated outcomes.

For boards, the episode is a reminder that enforcement outcomes are not static. Risk committees that treat a Final Notice as the end of a matter should recognise that the perimeter of regulatory truth can move, sometimes years later. Succession decisions, remuneration adjustments and public statements made in the heat of an enforcement cycle can age poorly. The firms that handle the next benchmark-style controversy best will be those that distinguish, in their own governance records, between what a court found and what the firm itself concluded on the evidence.

The LIBOR enforcement era is now effectively closed. What replaces it will be shaped less by prosecutorial momentum and more by the quality of the regulator's own casework.