Nov 2025 : How the FCA Handles Failure: The JNFX Special Administration
Zakir Karim
On 24 November 2025, JNFX Ltd – an FCA-authorised payment institution providing FX and payment services to corporate clients – was placed into special administration under the Payment and Electronic Money Institution Insolvency Regulations 2021. Just a few days earlier, on 20 November, the firm had agreed to a voluntary undertaking that restricted the activities it could carry out, signalling rising financial and regulatory pressure. The High Court ultimately found JNFX to be insolvent after it failed to satisfy a judgment of around £3.4 million owed to a major creditor, confirming that the statutory grounds for a special administration order had been met. Loss of managing customer claims and returning funds where possible.
FCA response:
On the day of the appointment, the FCA published a news update confirming that JNFX had entered special administration and explaining what this meant for customers. The regulator made clear that JNFX remains an authorised firm and that it would work closely with the special administrators to seek the best possible outcome for affected clients. It directed customers to contact the administrators directly, provided contact details and FAQs, and reminded them that payment institutions are not covered by the Financial Services Compensation Scheme, relying instead on safeguarding rules that require customer money to be held separately from the firm’s own funds. In its messaging, the FCA emphasised that the purpose of the special administration regime is to prioritise the orderly and timely return of safeguarded funds, illustrating how the post-2021 framework for failed payment institutions now operates in practice.
Fintech Risk & Compliance Hiring Grows as Overall Vacancies Cool
November’s labour-market data paints a two-speed picture. Overall vacancies in the UK continue to ease from their post-pandemic highs, and many firms remain cautious about permanent headcount growth. At the same time, fintechs are steadily increasing their share of risk and compliance hiring, with specialist roles in governance, regulatory change, financial crime and conduct risk proving more resilient than the broader jobs market.
The City of London continues to add financial and professional services roles, even as national vacancy numbers soften, and recruitment surveys point to a gradual shift towards more flexible and temporary hiring in areas outside core control functions. Taken together, the trend suggests that while the volume of generic roles may be flattening, demand for people who can sit at the intersection of regulation, data and fintech innovation remains structurally strong.
Open Finance TechSprints Move from Design to Delivery
In November, Open Finance shifted from concept to testing as the FCA’s Smart Data Accelerator kicked off TechSprints on SME finance and mortgages. Over the coming months, mixed teams from fintechs, banks and data providers will prototype real Open Finance journeys, giving firms an early, practical view of how consent, data-sharing and governance expectations are likely to evolve.
Rebalancing Risk for Growth: FCA Puts CROs Centre Stage
In a November speech launching the Chief Risk Officer Network, the FCA stressed that the goal is not to eliminate risk, but to rebalance it so firms can support sustainable growth with eyes wide open. Chief Risk Officers were positioned as strategic partners, expected to sit alongside CEOs and CFOs in shaping business plans rather than simply policing them after the fact. The regulator urged firms to move away from “paper compliance” towards outcomes-focused risk management, where good data, clear ownership and timely escalation drive better decisions. For fast-growing fintechs and payment firms, the message was that strong risk functions are now a precondition for ambitious growth, not a drag on it.
Our Thoughts
- Risk as a growth tool – CROs are being pulled into strategy, not just oversight. Boards are increasingly expected to use risk insight to shape product, pricing and growth plans rather than treat it as a post-hoc challenge function.
- Innovation in the sandbox – Open Finance is being shaped through live TechSprints, not just discussion papers. That means questions about consent, data use and customer understanding are being tested on real journeys, with regulators watching closely.
- Control skills in demand – Fintechs continue to hire into risk and compliance even as broader vacancies cool. Strong governance, safeguarding and financial crime capabilities are becoming part of the core infrastructure investors and regulators expect to see.
- Failure as a live test – The JNFX special administration shows how quickly the regime now moves when a firm gets into trouble. It’s a reminder that weak liquidity, governance or safeguarding can translate rapidly into court action and intensive FCA scrutiny.
