The UK Financial Services Authority has hardened its enforcement strategy over the last two years, but when a few record cases are set aside the average fine imposed by the regulator against firms has actually fallen, according to a new analysis.

The total fines issued by the FSA rose to £98.6 million in the 2010/2011 fiscal year, a near three-fold increase over the previous 12 months, according to an analysis by NERA Economic Consulting. And the number of fines issued in the period nearly doubled compared to the previous year.

The increase was even more marked for individuals: the number of fines assessed here in the last fiscal year was more than 10 times the average of the six years to 2008/09, when the FSA adopted a tougher enforcement policy.

But excluding the 10 biggest fines against firms and individuals reveals a nuanced underlying trend: the size of the average fine against individuals increased by 37% last year compared to the previous 12 months, while the average for firms fell by 16%.

The analysis also shows that, while the FSA is imposing more fines than ever before, this has not happened across the board. Its enforcement activity has targeted certain forms of behavior, such as investments mis-selling; punishment for market abuse, for example, remains rare.