Mark Kelly traded under PCD Wealth and Pensions Management to provide customers financial services, while Patrick Gray was one of his advisers.
However, the FCA cannot fine either of the men because they were not approved persons during the time period in question.
The FCA claims that, between August 2008 and July 2010, PCD poured nearly £24m of customers' funds – an average of over £68,000 per customer – in potentially unsuitable investments, while also failing to tell customers about the fees it was receiving from a number of these investments.
The FCA also claims that the process used by Kelly was designed to prevent customers from easily discovering where their money had been invested.
Meanwhile, Gray is accused of advising at least five customers while knowing that he had neither the suitable qualifications or training to do so, "recklessly" providing customers with misleading information on costs and charges, and supplying pension reports which contained false and misleading assurances.
"These two individuals misused pension funds, endangering the retirement incomes of hundreds of people," said Mark Steward, director of enforcement and market oversight at the FCA. "While further investigations continue, the FCA considers it necessary to prohibit them to help protect consumers."
During the time period in question, PCD advised over 350 customers.