The regulator has issued a warning notice to the trio that it will take action, including potential fines, over the scam.

The individuals include 2 IFAs who worked at the same advisory firm as approved persons and a stockbroker also working as an approved person.

The three have not yet been named yet by the watchdog and the FCA says the warning notice is not the final decision of the FCA as the three have the right to appeal.

The warning notices were issued to the three in mid-August but have only been made public by the FCA now.

The FCA believes that the three individuals played an “integral role” in a pension scam by colluding together to ensure that customers were recommended to transfer their existing pension funds into a SIPP. The SIPP would then be invested into “high-risk and mainly illiquid investments” in investment companies seeking to raise funds.

In return for transferring the pensions the investment companies were asked to make marketing and other payments to the three individuals. In total, the scam generated approximately £5.9m, the FCA says.

The FCA says it believes the individuals and the advice they gave were driven by profit. The regulator says the advice recommendations made by the trio were were “inevitably unsuitable” and exposed customers to a very significant risk of detriment and, in many cases, financial loss.

The three are also accused of deliberately concealing their receipt of marketing commissions and other payments 

The FCA considers that the trio failed to “act with integrity” in carrying out their controlled functions in breach of Statement of Principle 1 in the FCA’s Statements of Principle and Code of Practice for Approved Persons (APER).

The conduct scam took place between January 2015 and November 2017.

Financial Planning Today has asked the FCA for the identity of the individuals.