The FCA seeks a declaration that the Defendants have contravened, or been knowingly concerned in, contraventions of sections 19 and 21 of the Financial Services and Markets Act 2000 (FSMA). The FCA also seeks a restitution order against the Defendants under s. 382 FSMA enabling the orderly return of consumer funds and holding the Defendants liable to pay any shortfall in those funds, together with an injunction under s. 380 FSMA restraining the Defendants from future contraventions.

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