In the second part of our mini-series on regulatory enforcement, we explain how the PRA’s Early Account Scheme works, and the factors firms should consider when deciding whether or not to participate.

Welcome to episode two in our mini-series exploring new approaches from financial services regulators in the UK. In this episode, we unpack details of the Early Account Scheme (EAS), which was introduced by the Prudential Regulatory Authority (PRA) in January 2024.

Together, Ashurst colleagues Nathan Willmott, Adam Jamieson and Laura Bell explain how the voluntary scheme enables firms to provide a narrative factual account of issues when a suspected breach is flagged for investigation. Having provided this, firms may later receive a 50% discount on their financial penalty.

Laura highlights some circumstances where the EAS won’t be available and Adam explains that individuals are unlikely to opt for the EAS. On the other hand, he says firms might follow the EAS path because it provides the opportunity to take control of the narrative and present the facts in a way that they think is fair and justified. The trio also point out some of the challenges that firms may encounter during the EAS process.

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