The individuals, who remain anonymous, undertook the scam between January 2015 and November 2017. In total, they generated approximately £5.9 million in payments to the individuals and others involved in the scheme, according to the regulator.

The three individuals have the right to make representations to the Regulatory Decisions Committee (RDC) after receiving the FCA’s warning notice. The committee will then decide on the appropriate action and whether to issue a decision notice, which they also have a right to appeal.

The regulator said each of the individuals “played an integral role in a pension scam and colluded together to ensure that customers were recommended to switch/transfer their existing pension funds into a self-invested personal pension (SIPP), which would be invested into certain high-risk and mainly illiquid investments in investment companies seeking to raise funds.“The FCA considers the decisions made by the individual working at the retail advisory stockbroker and the advice provided by the independent financial advisers were driven by profit, were inevitably unsuitable and exposed all customers to a very significant risk of detriment and, in many cases, actual loss.”

The individuals deliberately concealed their receipt of marketing commissions and other payments from customers, it added.  

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