Final Notice

On , the Financial Conduct Authority issued a Final Notice to ODA Exclusive Ltd


Dated: 8 March 2018


For the reasons set out in this Final Notice, the Authority hereby takes the
following action against ODA.

The Authority issued to ODA the Decision Notice which notified it that for the
reasons given below and pursuant to section 55J of the Act, the Authority had
decided to cancel ODA’s permission.

ODA has not referred the matter to the Tribunal within 28 days of the date on
which the Decision Notice was issued to it.

Accordingly, the Authority has today cancelled ODA’s permission.


The definitions below are used in this Final Notice:

“the Act” means the Financial Services and Markets Act 2000;

“the Authority” means the Financial Conduct Authority;

“the Decision Notice” means the Decision Notice issued to ODA dated 30 January

“ODA” means ODA Exclusive Ltd;

“ODA’s permission” means the permission granted by the Authority to ODA
pursuant to Part 4A of the Act;

“the Return” means the CCR007 return for the period ended 31 March 2017,
which was due to be submitted by 17 May 2017;

“the suitability Threshold Condition” means the threshold condition stated at
parapgraph 2E of Schedule 6 to the Act;

“the Threshold Conditions” means the threshold conditions set out in Schedule 6
to the Act;

“the Tribunal” means the Upper Tribunal (Tax and Chancery Chamber); and

“the Warning Notice” means the Warning Notice issued to ODA dated 3 January



On the basis of the facts and matters and conclusions described in the Warning
Notice issued to ODA and in the Decision Notice, it appears to the Authority that
ODA is failing to satisfy the suitability Threshold Condition, in that the Authority is
not satisfied that ODA is a fit and proper person having regard to all the
circumstances, including whether ODA managed its business in such a way as to
ensure that its affairs were conducted in a sound and prudent manner.

This is because ODA has failed to comply with the regulatory requirement to
submit the Return. ODA has not been open and co-operative in all ODA’s dealings
with the Authority, in that it has failed to respond adequately to the Authority's
repeated requests for it to submit the Return, and has thereby failed to comply
with Principle 11 of the Authority's Principles for Businesses and to satisfy the
Authority that it is ready, willing and organised to comply with the requirements
and standards under the regulatory system.

These failures, which are significant in the context of ODA’s suitability, lead the
Authority to conclude that ODA has failed to manage its business in such a way
as to ensure that its affairs are conducted in a sound and prudent manner, that it
is not a fit and proper person, and that it is therefore failing to satisfy the
Threshold Conditions in relation to the regulated activities for which ODA has had
a permission.


The decision which gave rise to the obligation to give this Final Notice was made
by the Regulatory Decisions Committee.


This Final Notice is given to ODA in accordance with section 390(1) of the Act.


The Authority must publish such information about the matter to which this Final
Notice relates as the Authority considers appropriate. The information may be
published in such manner as the Authority considers appropriate. However, the
Authority may not publish information if such publication would, in the opinion of
the Authority, be unfair to ODA or prejudicial to the interest of consumers.

The Authority intends to publish such information about the matter to which this
Final Notice relates as it considers appropriate.

Authority Contact

For more information concerning this matter generally, please contact Prea Deans
at the Authority (direct line: 020 7066 2272).

Anna Couzens
Enforcement and Market Oversight Division


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