Lessons from the Crispin Odey case part 3: What should happen after a misconduct complaint is made?

The Odey case shows what can happen when people struggle to raise concerns about the most powerful person in a business. 

On 14 September 2026, the Upper Tribunal upheld the FCA’s decision to ban Crispin Odey from financial services after finding that he lacked integrity. It upheld all five of the FCA’s allegations against him and imposed a £1.53 million fine, reduced from the £1.83 million proposed by the FCA.

For more information on the case, read part 1 and part 2.

Huge consequences and a lengthy legal process

One former employee raised her complaint through solicitors. Another employee filed a formal grievance. The firm notified the FCA. Years later, further allegations reached the Financial Times and Tortoise. Soon afterwards, Odey was dismissed, counterparties withdrew services and Odey Asset Management began transferring funds before closing.

For Risk and Compliance leaders, the lesson starts much earlier in that sequence: give people a credible way to speak up, then protect the process once they do.

One complainant said there was no mechanism to report him

The Upper Tribunal judgment records that a former employee raised a sexual harassment complaint against Odey through solicitors on 27 August 2020.

Her complaint included a particularly important point. She said there was no mechanism through which she could formally report Odey. GOV.UK

On 17 September, a current employee who had been interviewed during that investigation raised her own formal grievance. OAM told its FCA supervisory contact about both allegations on 24 September. GOV.UK

For us, that sequence gets to the purpose of an anonymous whistleblowing channel.

When something is seriously wrong inside your organisation, your people often know before leadership does. The question is - do they feel safe enough to report it?

A balanced reporting framework and a secure independent whistleblowing channel, built by a third party, gives your employees, contractors and other stakeholders a confidential route to raise concerns outside normal management lines. 

Someone reporting a founder or CEO faces a different risk from someone reporting a peer. The normal management route may lead directly back to the person concerned. HR may report into them. The employee may fear exposure or career consequences.

Your reporting route needs to account for that power imbalance.

Anonymity still needs two-way communication

Anonymous reporting can create another problem if the investigator cannot ask questions afterwards.

That is why our whistleblowing software allows a reporter to remain anonymous while authorised case handlers continue communicating with them through an encrypted system.

This matters for Risk and Compliance because serious concerns rarely arrive with every fact neatly documented.

You may need dates, documents or clarification. Secure two-way communication allows you to request them without requiring the reporter to identify themselves. We explain the approach in more detail in our guide to two-way anonymous reporting. Veremark

An anonymous whistleblowing channel gives you an opportunity to receive that information earlier and manage it inside a controlled process.

Concerns can move outside the business

OAM's internal process did eventually reach the regulator. In September 2020, senior people at the firm informed the FCA about the two internal allegations, and the FCA's involvement developed from there. GOV.UK

A much wider public reckoning followed in June 2023, when the Financial Times and Tortoise published an investigation containing allegations from 13 women who accused Odey of abuse or harassment. Odey disputed the allegations. Financial Times

The Upper Tribunal did not determine the truth of those later allegations and expressly excluded them from its findings because they were subject to separate court proceedings. GOV.UK

The commercial consequences that followed are documented.

The tribunal said the FT articles may have contributed to large withdrawals from OAM funds. Prime brokers and other counterparties withdrew services and liquidity began to leave the business. OAM started transferring fund activities to other managers. Odey was dismissed shortly afterwards. GOV.UK

By October 2023, OAM announced that it was closing, with funds and managers moved elsewhere. That is more accurate than saying the firm “went bust”. The Guardian

Protect the case after somebody reports

A reporting channel cannot compensate for a process that can be interfered with after the report arrives.

The tribunal found that Odey twice removed executive committees that were meant to consider disciplinary allegations against him. It also found that he repeatedly threatened to close the firm if the committees sought to dismiss him. GOV.UK

For Compliance, that means your controls should cover case access and escalation as carefully as initial reporting.

Who can see a senior misconduct report? Who can reassign it? Is there a record of actions and decisions? Can the case bypass implicated executives? Who receives an escalation if the concern involves the CEO or board?

Our guidance on supporting whistleblowers after they report looks at why the relationship with the reporter also needs to continue after intake.

Give people a credible internal route

Employees will sometimes need to speak to regulators, advisers or journalists. Those external routes perform an important function when internal systems fail.

The FCA itself reviewed 1,375 whistleblowing reports in 2025/26, 22% more than the previous year. Whistleblower information contributed to 523 instances of direct FCA action. FCA

Your opportunity is to give people a credible route inside your organisation as well.

A well-designed anonymous whistleblowing channel lets somebody raise a difficult concern without first instructing a solicitor or identifying themselves to people within the normal reporting line. It gives Compliance a structured record and a way to follow up while the reporter stays protected.

The Odey case shows how expensive unresolved conduct risk can become once confidence in internal accountability breaks down.

Find out how Veremark’s whistleblowing software can give your employees a secure anonymous reporting route and give your Risk and Compliance team better control of what happens next.