Neil Woodford and Woodford Investment Management have referred the Decision Notices to the Upper Tribunal where each will present their case. Any findings in the Decision Notices are therefore provisional and reflect the FCA’s belief as to what occurred and how it considers their behaviour should be characterised.
The FCA has decided to fine Mr Woodford £5,888,800 and ban him from holding senior manager roles and managing funds for retail investors.
The FCA has also decided to fine WIM £40,000,000.
WEIF was an investment fund managed by Mr Woodford and WIM. They were responsible for managing the liquidity of the fund, so that investors could redeem their investments and be repaid.
The fund was suspended in June 2019, leaving investors – a significant majority of whom were ordinary retail customers – unable to access their money. The value of the WEIF had fallen from a high of over £10.1bn in May 2017 to just £3.6bn in the run-up to its suspension.
The FCA has concluded that between July 2018 and June 2019 WIM and Mr Woodford made unreasonable and inappropriate investment decisions. They disproportionately sold more liquid investments (those that are easier to sell) and bought less liquid ones over this period. This meant that at the time of suspension only 8% of the investments held by WEIF could be sold within 7 days.
Under rules in place at the time, investors should have been able to access their funds within 4 days.
WIM and Mr Woodford did not react appropriately as the fund’s value declined, its liquidity worsened and more investors withdrew their money. This disadvantaged investors who remained in the fund, compared to those who had withdrawn their investment before the fund was suspended.
The FCA has concluded that Mr Woodford held a defective and unreasonably narrow understanding of his responsibilities. Despite his senior role, he did not accept that he had a responsibility to oversee the management of the fund’s liquidity, including in interviews conducted by the FCA. He also failed to provide proper oversight of WIM’s relationship with Link Fund Solutions (Link), the WEIF’s authorised corporate director, including after Link raised concerns about the fund’s liquidity.
The FCA considers Mr Woodford’s and WIM’s failings led to a significantly increased risk of the fund being suspended.
Steve Smart, joint executive director of enforcement and market oversight at the FCA, said: "Being a leader in financial services comes with responsibilities as well as profile. Mr Woodford simply doesn’t accept he had any role in managing the liquidity of the fund. The very minimum investors should expect is those managing their money make sensible decisions and take their senior role seriously. Neither Neil Woodford nor Woodford Investment Management did so, putting at risk the money people had entrusted them with."
The FCA previously set out its findings against Link for its role in the suspension of the WEIF. This included securing a £230m redress scheme for those investors stuck in the fund when it was suspended.
1. Decision Notice 2025: Neil Woodford (PDF)
2. Decision Notice 2025: Woodford Investment Management Limited (PDF)
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