The regulatory clamp-down on mid-market firms

While tier one banks have historically drawn the most attention from global financial regulators, smaller mid-market firms are now increasingly finding themselves on the receiving end of enforcement action for infringements related to market abuse.

Findings from our 2025 Global trends in market abuse and trade surveillance report corroborate this fact. In the past six years, 2022 saw the highest total value of enforcement actions at $1.90 billion in total fines. However, this number was spread across a relatively low number of high value fines, with just over 40 individual sanctions issued. By contrast, 2024 saw a comparable $1.84 billion in total value of fines issued, but across 163 fines - roughly 4x as many as the previous highest annual figures.

This shows a significant decrease in average fine value, clearly indicating that smaller, tier two and tier three firms are now also drawing regulatory ire. Firms of all sizes are now expected to have robust compliance functions in place - a failure to do so is likely to result in regulatory enforcement action being pursued.