The regulator said Adrian Douglas, Liam Martin, Frank Oxberry and Alec Cuthbert were responsible for a pension transfer advice model that put people’s guaranteed retirement benefits at risk.

Between October 2015 and July 2016, the FCA claims St Martin’s Partners’ advice model put 547 customers at “significant risk” of transferring out of guaranteed defined benefit pensions into investments which were unlikely to be suitable for them, including investing in hotel developments in Cape Verde offered by The Resort Group.

The FCA said the firm’s advice model did not take into account the information required to assess the suitability of a pension transfer or how the benefits of the customer’s existing scheme compared to the new investment.

Douglas and Martin, both qualified pension advisers, played a role in designing and operating the transfer advice model used at the Essex-based firm, according to the regulator.

Customers were brought to St Martin’s Partners through ‘introducer’ firms, including First Review Pension Services, a subsidiary of The Resort Group.

The FCA believes the firm had a “clear indication” of the link between The Resort Group and First Review Pension Services.

The firm’s two partners, Oxberry and Cuthbert, had oversight of the firm and its advisers and according to the regulator did not ensure due diligence was carried out on the introducer firms involved in the model.

A requirement was agreed in November 2016 that stopped the firm from using the advice model, the FCA said.

Therese Chambers, joint executive director of enforcement and market oversight, said: “People need to be able to trust the advice they receive about their pensions. But these four individuals put SMP’s customers in danger of giving up guaranteed retirement income for high-risk investments, like overseas hotel developments. They received significant financial benefit in doing so, at the expense of their customers.

“There was a reckless disregard for customers’ financial situation, their needs through retirement and how their existing benefits compared to the proposed alternative. It is right the FCA takes steps to prevent these people from working in the financial industry and impose penalties.”

The regulator fined Oxberry £241,869, Martin £128,356 and Douglas £128,356 as well as banning them from working in financial services.

While Cuthbert has been fined £91,963 and also banned from working in the sector.

Oxberry, Martin and Douglas have referred the FCA’s decisions to the Upper Tribunal which will determine in the case of the decision to impose a financial penalty, what (if any) the appropriate action is for the FCA to take.

According to the FCA, Cuthbert agreed to settle the FCA’s case against him and therefore did not make a reference to the Tribunal.

St Martin’s Partners is now in liquidation, the FCA confirmed with the FSCS paying out more than £13.4mn in compensation to the firm’s clients as a result of losses suffered following advice they received.

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