Burdett & Anor v Financial Conduct Authority (FINANCIAL SERVICES - Pension transfers to a SIPP and investments in offshore property development group - Authority decided to impose financial penalties and prohibition orders on the basis that Applicants lacked integrity) [2026] UKUT 68 (TCC) (12 February 2026)

Executive summary

The Upper Tribunal heard references by Stephen Joseph Burdett and James Paul Goodchild against FCA Decision Notices imposing financial penalties and prohibition orders for conduct connected with pension transfers to a SIPP and investments in an offshore property development group linked to The Resort Group plc. The Tribunal held that both applicants acted without integrity, dismissed the references against the prohibition orders, and determined revised penalties, including £265,071 plus continuing interest for Mr Burdett and £47,600 for Mr Goodchild.

Key points

• Parties: Stephen Joseph Burdett and James Paul Goodchild v Financial Conduct Authority
• Subject matter: pension transfers to a SIPP and high-risk offshore property development investments connected with TRG
• Holding: both applicants acted without integrity; references against prohibition orders dismissed
• Mr Burdett was found to have knowingly performed the CF1 (Director) function without approval and acted without integrity in that role
• Mr Goodchild was found to have acted without integrity in performing his controlled functions managing investments
• Penalty outcome: Mr Burdett £265,071 plus continuing interest; Mr Goodchild £47,600

Why it matters

The decision shows FCA enforcement extending to integrity-based misconduct involving retail pension assets routed into offshore, illiquid investments, which is relevant to financial crime and sanctions-adjacent risk screening even though no sanctions issue is expressly involved. The case also underlines the regulatory exposure of intermediaries and managers where customer funds are steered into opaque cross-border structures.

Implications

For compliance and litigation strategy, the ruling reinforces that lack of integrity findings can support both fines and prohibition even where the underlying activity is framed as investment management rather than direct product mis-selling. Firms handling pension transfers or offshore property-linked products should expect close scrutiny of approval status, governance, and suitability controls, and should not assume that partial self-representation or absence from the hearing will derail enforcement.