Crispin Odey FCA Ban Upheld as Tribunal Reduces Fine to £1.53 Million

The Financial Conduct Authority said on 14 September 2026 that the Upper Tribunal had upheld its ban of Crispin Odey from the financial services industry, finding that the founder and majority owner of Odey Asset Management lacked integrity. The Tribunal dismissed Odey’s reference and upheld the prohibition, while reducing the fine the FCA had proposed from £1.83 million to £1.53 million.

The Upper Tribunal (Tax and Chancery Chamber) published its decision, Robin Crispin Odey v The Financial Conduct Authority, 2026 UKUT 00351 (TCC), on 14 September 2026. The panel of Mr Justice Thompsell, Judge Rupert Jones and Member Catherine Farquharson heard the case on 10-13, 16-20 and 24-26 March 2026 and on 5 and 6 May 2026. According to the published summary, the Tribunal determined whether Odey acted without integrity in twice removing the executive committees of the limited liability partnership he owned that were due to hear a disciplinary hearing into allegations he had breached a Final Written Warning imposed for misconduct and inappropriate behaviour towards female employees; in substituting himself as sole member of the committee in breach of regulatory requirements that at least two managers direct the business; and in making misleading statements to the partnership’s members, to investors and to the FCA. The Tribunal also considered whether the FCA was reasonably entitled to impose a prohibition order under section 56 of the Financial Services and Markets Act 2000, whether there was jurisdiction to impose a financial penalty under section 66, and whether the penalty was correctly calculated. The reference was dismissed.

According to the FCA, its case comprised five allegations and the Tribunal fully upheld all of them, agreeing that each demonstrated Odey’s lack of integrity. Alongside the allegations arising directly from the dismissals of the executive committees, the Tribunal upheld allegations that Odey’s dealings with the firm, its clients, its investors and the FCA lacked candour, including false assertions to and threatening behaviour towards FCA staff. The Tribunal considered Odey’s attempted justifications for removing the committees to be “no more than a smokescreen,” the regulator said, and found that during the trial he demonstrated a lack of insight into why his conduct lacked integrity, expressed no contrition, wrongly considered himself the victim and gave evidence that lacked credibility in multiple respects. The fine was reduced after the Tribunal decided there should be no uplift for the aggravating factors the FCA had applied in its calculation.

“Mr Odey clearly thought he could act with impunity. He twice sacked those tasked with protecting female employees from his inappropriate behaviour when they tried to hold him to account. He felt the rules shouldn’t apply to him and acted to save his own skin,” said Therese Chambers, the FCA’s executive director of enforcement and market oversight. Chambers said Odey’s resulting disregard for proper governance meant he was unfit to work in financial services.

The Disciplinary Process at Odey Asset Management

Odey Asset Management LLP was a London-based investment management and advisory firm established by Odey in 1991 and authorised on 21 November 2002, according to the FCA’s Decision Notice of 3 March 2025. Odey has worked continuously in financial services since 1983. Between September 2020 and January 2021, after two employees alleged sexual harassment, the firm’s executive committee conducted an internal investigation that identified numerous allegations of sexual harassment of female staff between 2003 and 2020, including an allegation of sexual assault in 2005. The committee concluded that Odey had behaved inappropriately towards a number of female staff members and issued a Final Written Warning for Misconduct dated 4 February 2021, which Odey signed on 5 February 2021. The warning required his interactions with all staff to be professional and in line with firm policies, and stated that failure to comply was likely to lead to his removal from the partnership.

The FCA opened an investigation into the alleged non-financial misconduct, and the firm’s handling of the allegations, on 28 September 2021. On 11 October 2021, an agency that supplied temporary staff told the firm it was withdrawing its services over information about Odey’s alleged behaviour towards a temporary staff member, and the firm began a second internal investigation. On 30 November 2021 the firm notified Odey of a disciplinary hearing scheduled for 14 December 2021; on 13 December 2021 he requested a postponement after changing his legal team, and the hearing was moved to 6 January 2022. On 24 December 2021, Odey used his majority shareholding to remove the committee’s members, then comprising an individual who had been the firm’s chief operating officer and chief financial officer since 2001, its head of research since 2005 and a fund manager at the firm since 2009, and appointed himself sole member, assuming the SMF27 (Partner) function under the FCA’s 12-week rule, which allows an individual, without FCA approval, to cover a Senior Management Function holder whose absence is temporary or reasonably unforeseen, provided the appointment lasts less than 12 consecutive weeks in a consecutive 12-month period. In a letter to members that day, Odey said he acted in his capacity as the 74.9% majority owner of the Odey Group and cited what he described as overreaching FCA action; the FCA found the explanations in the letter lacked candour.

On 6 January 2022, as sole member of the committee, Odey indefinitely postponed his own disciplinary hearing, stating he was unable to conduct it with impartiality. He appointed two new committee members on 12 January 2022 and resigned from the committee the same day. The Decision Notice states that Odey then repeatedly pressed the new members and the FCA to delay the hearing until the regulator’s own investigation concluded. In a 10 January 2022 call with a head of department, he demanded the FCA indemnify prospective committee candidates so they would not need to consider the disciplinary matter unless there was an enforcement outcome, and threatened to go public that day with a letter setting out his view of the FCA. On 11 February 2022 he falsely told a less senior FCA employee that he had reached a verbal agreement on the postponement in a conversation with the head of department a month earlier, and threatened to go to the press.

A further allegation of non-financial misconduct, dating to 17 March 2021 and involving a future employee of the firm, reached the committee on 3 March 2022. When the new committee and the firm’s compliance officer discussed interim safeguarding measures, including that Odey work remotely or be separated from staff, he refused. At a 23 March 2022 meeting he said that if the committee made an adverse finding he would close the firm, litigate personally against its members and remove the insurance cover they could use to finance their defence; at a 28 March 2022 meeting he told the committee that HR law did not matter and directed a profanity at a member who defended the measures, which were not implemented. On 31 March 2022, Odey again removed the committee and made himself sole member, a position he held until he appointed two new members on 4 July 2022; a third member, a non-executive board member, was appointed on 5 October 2022.

The reconvened disciplinary hearing took place on 29 November 2022, nearly one year after it had originally been scheduled. In a 13 December 2022 outcome letter, the firm found Odey had technically breached the Final Written Warning in two instances, by inviting the temporary staff member to lunch without approval and by exchanging non-work phone messages with her while she was still working at the firm, but judged that these were not substantive breaches or inappropriate conduct that could reasonably be considered harassment. The committee required further compulsory training and imposed a one-year management embargo, and the terms of the original warning continued with a 12-month time limit, subject to review.

Regulatory Breaches and the Penalty Calculation

The FCA found that by twice removing the committee Odey caused the firm to breach SYSC 4.2.1R and SYSC 4.2.2R, which require an alternative investment fund manager to be managed by at least two persons of good repute, and FUND 3.7.2R, which requires functional and hierarchical separation between risk management and portfolio management. His actions also prevented the firm from assessing his fitness and propriety under the Certification Regime. According to the Decision Notice, the resulting governance failings lasted a total of 112 days and negatively affected the firm’s ability to meet the FCA’s threshold conditions of effective supervision, appropriate resources and suitability. The firm notified investors of the operational risks, added risk warnings to its prospectus and details of the governance conflicts to its due diligence questionnaire, and in June 2022 ceased marketing its funds to new investors. The FCA closed its investigation into the firm on 11 December 2023.

At the time of the dismissals, the firm held around £2.555 billion of funds under management in December 2021 and £2.836 billion in March 2022, and managed 22, and latterly 20, funds with average assets under management of approximately £2.925 billion. Odey personally managed seven, and latterly six, funds with average assets of £862 million. The firm ceased being authorised on 24 May 2024 and is in wind down, rehousing funds and transferring certain fund management activities to other asset managers.

The FCA’s Regulatory Decisions Committee gave a Warning Notice on 18 September 2024 and issued the Decision Notice on 3 March 2025, deciding to impose a financial penalty of £1,835,200 under section 66 of the Act and an order under section 56 prohibiting Odey from performing any function in relation to any regulated activity carried on by an authorised person, exempt person or exempt professional firm. The notice found he breached Individual Conduct Rule 1, the requirement to act with integrity, during a relevant period from 24 December 2021 to 17 November 2022, when he was a certification employee and at times held Senior Management Functions. Odey challenged the action through the FCA’s expedited reference procedure, which allows a person subject to enforcement action to challenge a warning notice before the Tribunal without engaging the regulator’s internal decision-making process, and waived his right to make representations under section 387(2) of the Act.

Under the FCA’s five-step penalty framework, the regulator identified no financial benefit derived directly from the breach, set Odey’s relevant income at £2,548,957, assessed the seriousness of the breach at level 4 and applied 30% of relevant income to reach £764,687. It increased that figure by 20% for aggravating factors, to £917,624, after finding that Odey proceeded with the second dismissal despite the FCA having communicated its concerns about the first. It then multiplied the figure by two for deterrence, taking into account the firm’s average assets under management during the period of the breach, reaching £1,835,248, and with no settlement discount rounded the penalty down to £1,835,200. The Tribunal decided that no aggravating-factors uplift should apply, reducing the penalty to £1.53 million, the FCA said.