In February 2021, following a settled enforcement proceeding by the SEC against BlueCrest Capital Management Limited (BlueCrest), the U.K. Financial Conduct Authority (FCA) fined BlueCrest’s FCA-supervised U.K. affiliate, BlueCrest Capital Management (UK) LLP (BCMUK), £40,806,700 – more than $55 million at the time. BCMUK allegedly failed to manage or adequately disclose conflicts of interest associated with its side-by-side management of an internal fund open only to select BCMUK personnel (Internal Fund) and another fund open to professional investors (External Fund). BCMUK had transferred portfolio managers from the External Fund to the Internal Fund, replacing them in part with an automated trading system but allegedly failed to manage properly the associated conflicts of interest. After an appeal, the FCA and BCMUK settled the matter, with BCMUK agreeing to return approximately $101 million to affected investors and accepting a censure – but no fine – by the FCA. This article discusses the settlement, with commentary from Matt Hancock, partner at Greenberg Traurig, LLP. See “FCA Fines U.K. Affiliate of U.S. Manager That Replaced Successful Traders With Algorithms” (Feb. 17, 2022). For more on the SEC proceeding, see “Manager Learns $170M Lesson: Replacing Successful Traders With Algorithms May Result in Significant Penalties Unless Properly Disclosed” (Jan. 28, 2021).