On 1 August 2025, the Financial Conduct Authority (FCA) announced in its Final Notice that it had fined Sigma Broking Limited a total of £1,087,300 for significant and prolonged failures in transaction reporting under the UK’s Markets in Financial Instruments Regulation (MiFIR).
Regulatory Breaches
The FCA’s surveillance systems identified discrepancies in Sigma’s reporting as early as May 2023. At that time, Sigma reported approximately 984,000 incorrect reports. However, an independent review completed in February 2025 revised the figure to 924,584 inaccurate reports, accounting for nearly 100% of the firm’s transaction data between 1 December 2018 and 1 December 2023.
The root cause was traced to an incorrect system configuration. This error persisted due to weaknesses in Sigma’s internal controls and oversight processes, which failed to detect and address the issue in a timely manner.
Regulatory Standards Breached
Sigma’s conduct was found to have breached:
- Article 26 of MiFIR: which requires the accurate and timely reporting of transaction data to competent authorities.
- Principle 3 of the FCA’s Principles for Businesses: which obliges firms to “take reasonable care to organise and control their affairs responsibly and effectively” (FCA Handbook, PRIN 2.1.1R).
These breaches highlight both operational failings and a lack of effective governance in maintaining regulatory compliance.
Enforcement History
This is not the first time the FCA has taken enforcement action against Sigma. In October 2022, the Firm was fined £531,600 for previous reporting failures, including the omission of around 56,000 transaction reports and the failure to report 97 suspicious trades between December 2014 and August 2016. That earlier case also led to fines and prohibitions for three former directors.
Mitigation and Penalty
Sigma qualified for a 30% early settlement discount, reducing the fine from a potential £1,553,300 to £1,087,300. By 5 February 2025, the Firm had corrected and resubmitted all incomplete and inaccurate transaction reports, completing the required “back-reporting” process. The FCA emphasised that accurate transaction reporting is essential for detecting market abuse, supervising firms and maintaining the integrity of the financial markets. Failures of this scale significantly impair the regulator’s ability to carry out its statutory functions.
Conclusion
This case serves as a strong reminder to all regulated firms of the importance of robust systems and controls for transaction reporting. Sigma’s persistent failures breached fundamental regulatory obligations and undermined market oversight.
The FCA’s approach, combining improved enforcement efficiency with significant financial penalties, underscores its commitment to data integrity and regulatory compliance across the UK financial sector.
How Can Complyport Help?
Complyport can support your firm meet its transaction reporting obligations in the following way:
- Transaction Reporting Health Checks: We conduct comprehensive reviews of your reporting framework to identify any gaps or inaccuracies and provide practical recommendations.
- Regulatory Technology Solutions: We offer technology-enabled compliance solutions to automate and improve the accuracy of transaction reporting processes.
- Remediation Support: In the event of a reporting failure, our team can assist with back-reporting, internal investigations, and liaising with the FCA.
- Ongoing Compliance Monitoring: We provide outsourced or co-sourced compliance support to ensure your systems and controls remain fit for purpose over time.
Book a meeting with one of our Subject Matter Experts to ensure you remain compliant and well-positioned in the evolving UK regulatory landscape.
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