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What happens in Vegas...

Non-financial misconduct and the UK Senior Managers and Certification Regimen - The old adage goes that, “What happens in Vegas, stays in Vegas.” But, does this really hold true in the UK financial services sector?...more

Avoiding the Cliff Edge - Immediate Steps for Firms and Groups with Financial Services Businesses in Europe Involving the UK

The UK is due to leave the European Union on March 29, 2019 (“Brexit”). Within the EEA, “passport rights” permit financial services institutions and funds authorised in any EEA Member State to conduct business cross border...more

A Rock or A Hard Place?

Reporting overseas enforcement action against Senior Managers to the Prudential Regulation Authority. On 7 November 2018, the Prudential Regulation Authority (“PRA”) issued two final notices against two individuals who had...more

The FCA’s Heightened Expectations Around Insider Dealing and Market Manipulation Systems and Controls (GC 18/1) – Some Practical...

Firms should consider the implications for their existing anti-market abuse controls and should consider responding to the consultation either directlyor through a relevant industry body. On 5 April 2018, we reported in an...more

UK Court Takes a “Realistic” and “Commercial” Approach to Litigation Privilege in the Context of Internal Investigations

In a judgment handed down at the end of 2017, but only recently released, the High Court in London has determined - in Bilta (UK) Ltd v RBS - that interviews held with employees in preparation of a report intended to deter a...more

The King & Spalding Guide to MiFID II Conduct of Business Requirements

MiFID II, which is a package of measures consisting of a revised Directive (the Markets in Financial Instruments Directive), a new regulation (the Markets in Financial Instruments Regulation) and subsidiary implementing...more

The Senior Managers Regime – should GCs be worried?

In March this year the PRA and the FCA introduced the Senior Managers Regime (‘SMR’) for individuals associated with banks and PRA regulated investment firms (from 2018 the SMR will apply to all UK authorised firms). The...more

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