FCA v Bright Management Solution Ltd

When directing distribution under section 382(3) FSMA 2000 of sums recovered from unauthorised activity, the court applies a set of guiding principles focused on compensating those adversely affected (not punishment), proceeding on a rough-and-ready basis where facts are incomplete, balancing simplicity and fairness, requiring the FCA to take all reasonable steps to identify qualifying persons, prioritising out-of-pocket over expectation losses, and providing finality.