Total fines issued by the Financial Conduct Authority have fallen in the first half of 2014 compared with the same period of 2013.
The FCA imposed £136m of fines in the first six months of this year compared with £150m a year earlier. The number of fines also fell to 18 from 21.
The financial watchdog issued a record £474m in fines last year, including three totalling £330m as it clamped down on Libor rigging and JP Morgan's "London Whale" trading activity.
But Rachel Couter, a partner at the law firm King & Wood Mallesons SJ Berwin, said that beneath the headline numbers the FCA was getting tougher with financial firms.
"I don't think they are letting up. They are probably being more aggressive than previously. Last year was pretty exceptional."
The £87.5m Libor fine for Royal Bank of Scotland in the first half of 2013 was far greater than the biggest so far this year: £30.6m imposed on HomeServe, the emergencies and repairs group.
But the number of fines of more than £10m increased to five from three a year earlier, while £5m-plus penalties rose to seven from five.
They included the £26m imposed on Barclays for failing to prevent manipulation of the London gold price and £18.6m for Invesco Perpetual's failures that left small investors exposed to big losses.
Couter said fines were going up because more came under the FCA's harsher penalty regime. Barclays' fine and a £2.4m penalty against Credit Suisse were both increased because of previous wrongdoing. "There has been more of that this year. The regulator decides what number it is seeking to achieve," Couter said.
The FCA replaced the Financial Services Authority last year. Its chief executive, Martin Wheatley, is unpopular in the City for clamping down on firms.
The FCA releases its first annual report this week and will disclose Wheatley's pay along with details of its annual budget. The regulator is being investigated by the law firm Clifford Chance over the botched announcement of an insurance inquiry last year.
The FCA takes over responsibility for promoting competition in the financial industry next spring. Bovill, a financial consultancy, said the regulator had hired extra staff in the last year in preparation.
Ashley Kovas, head of funds at Bovill, said: "Thirty new hires in the space of a year is the equivalent of a whole department in FCA terms. The new enforcement powers will mean it has the ability to investigate and punish businesses that fall foul of competition law, which could have an unnerving effect across the City."
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