Compliance & Ethics

A bank could raise its fees by as much as 200% after a slight increase in inflation. Another could introduce charges for services that had previously been free. A third reserved the right to alter credit card agreements when it improved its products or expanded its offerings. These were among the contractual provisions challenged by Poland’s Office of Competition and Consumer Protection (UOKiK), which announced penalties totaling approximately $37.7 million (PLN 147.09 million) against four banks on October 15.

The European Securities and Markets Authority (ESMA) published its third consolidated sanctions report on October 15, recording more than 950 administrative sanctions and measures imposed by national authorities during the year. The combined value of administrative fines reached almost €82 million, while the number of sanctions and measures remained broadly unchanged from the preceding two years.

A countdown timer on Wayfair’s website told shoppers that a deal was about to disappear. The furniture retailer advertised products through “Daily Deals” and 24-hour “Flash Deals,” sometimes accompanied by the warning “Here Today, Gone Tomorrow.” Customers who wanted the advertised price were given reason to believe they had little time to decide.

The Norway Financial Supervisory Authority (Finanstilsynet) has published a warning about "gfo-xx (Clone)," a suspected clone of a UK FCA-authorized firm, based on a UK FCA warning. Compliance teams should treat this as a fraud and impersonation alert and update screening, client-protection, and monitoring controls accordingly.

Norway's Financial Supervisory Authority (Finanstilsynet) has published a warning about a clone of an FCA-registered firm, "hanbury_financial_p1lanning (Clone)," which links to a corresponding UK Financial Conduct Authority (FCA) warning. Clone firms use the identity of authorized firms to defraud consumers, so compliance teams should strengthen counterparty verification and fraud-monitoring controls.

De Nederlandsche Bank (DNB) announced that roughly 55 pension funds and APF circles plan to transfer to the new pension system after January 1, 2027, and that it will accelerate its assessments to meet the statutory deadline of January 1, 2028. DNB aims to issue decisions at least six months before each intended transfer date. Funds must submit high-quality notifications at least twelve months before transfer to avoid time pressure and a higher risk of unresolved findings.

The Norway Financial Supervisory Authority (Finanstilsynet) published a warning about WealthW-Group, which links to a UK Financial Conduct Authority (FCA) notice identifying it as a suspected clone of an FCA-authorized firm. Compliance teams should treat this as a fraud and impersonation alert, since the entity is not a legitimate authorized firm. It calls for updates to screening, onboarding, and customer-protection controls.