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EU Kicks Off MAR Review

The European Commission has set out the elements of MAR that it wishes to consider as part of a planned review. Key Points: ..The formal review of MAR will consider not only the topics mandated for review by the...more

FCA Fires Warning Shot to Brokers in Wholesale Markets

Latest Dear CEO letter from the regulator includes strong criticism and warns that firms need to improve to meet regulatory expectations. Key Points: ..FCA supervisory work during the next two years will focus on four...more

Private Bank Briefing: Issues Impacting the Private Bank Sector

On 23 January 2019, the FCA published a Consultation Paper (CP19/4) concerning further amendments to the Senior Managers and Certification Regime (SMCR). For private banks which are already subject to the SMCR, the...more

MiFID II Costs and Charges - Room For Improvement

The FCA has issued feedback from its review of firms’ costs and charges disclosures under MiFID II. Key Points: ..The FCA found that, despite firms being aware of the rules and taking compliance seriously, firms are not...more

Brexit and Financial Services - FCA Issues Further Guidance For Firms

The FCA outlines how it intends to use its temporary transitional powers in a no-deal scenario. Key Points: ..The FCA has highlighted areas in which transitional relief will not be granted in a no-deal...more

Regulating Crypto-assets and ICOs? ESMA and EBA Consider the Benefits

ESMA and the EBA publish documents considering the application of the EU regulatory regime to crypto-assets and ICOs. Key Points: ..ESMA highlights the importance of taking a technology-neutral approach to regulation,...more

FCA Consults on Further Amendments to the SMCR

The FCA seeks to clarify the position of the Head of Legal and the scope of the Client Dealing Function. Key Points: ..The FCA is proposing to exclude the Head of Legal from the scope of the Senior Managers...more

Brexit and Financial Services — UK Equivalence Decisions

HM Treasury has published draft legislation that will allow the UK to make timely equivalence decisions in relation to the EU. Key Points: ..Post-Brexit, HM Treasury will take on the role of making equivalence decisions...more

European Commission Report on the Operation of the AIFMD

Report concludes that the AIFMD has been helpful in building a market for AIFs, but is not free from issues. Key Points: ..The report concludes that the AIFMD has played a significant role in helping to create an...more

Brexit and Financial Services - Temporary Permissions

The UK’s temporary permissions regime appears to be a helpful concession for inbound firms, but there are some hidden challenges. Key Points: ..The UK regulators have set out further details of the rules they propose...more

FCA Finalises Changes to its Financial Crime Guide

The FCA has finalised a new chapter on insider dealing and market manipulation. Key Points: ..Firms should take note of the new guidance, which applies immediately. ..Helpfully, the FCA has clarified that firms do...more

FCA Proposes Permanent Product Intervention Measures for Retail CFDs and Binary Options

The rules will echo ESMA’s temporary measures, however the FCA will extend the CFD restriction to capture closely substitutable products (such as turbo certificates). The FCA has launched two consultations on: ..Banning...more

FCA to Clarify Scope of the Client Dealing Function

The FCA has announced that it plans to consult further on the scope of the Client Dealing Function under the SMCR. Key Points: ..The FCA acknowledges that the scope of the Client Dealing Function needs to be clarified,...more

FCA CP18/36 — The Second Brexit Onshoring Consultation

The FCA has published a second consultation on the Brexit onshoring project. Like the first, and many other Brexit onshoring documents, it is both long and very technical. However, a number of important policy points are...more

Brexit and Financial Services — Onshoring MiFID II

Latham & Watkins demystifies the process for onshoring the MiFID II regime, and outlines the key changes for firms operating in the UK. Key Points: ..The onshoring process is designed to preserve the status quo as much...more

UK Cryptoassets Taskforce Publishes its Final Report

The Taskforce’s final report outlines the UK’s policy and regulatory approach to crypto-assets and distributed ledger technology in financial services. Key Points: ..The Report provides an overview of crypto-assets and...more

Findings from FCA Thematic Review on AML and CTF Systems and Controls Provide Timely Reminder for Firms

Examples of good and poor practices provide helpful guidance, and a reminder of supervisory expectations. The FCA has published TR18/3, setting out the findings from its thematic review of the anti-money laundering (AML)...more

A New Sheriff in Town? UK MPs Call for Regulation of “Wild West” Crypto-assets

The House of Commons Treasury Committee has published its recommendations for the regulation of crypto-assets in the UK. Key Points: ..The House of Commons Treasury Committee has proposed that the UK government should...more

Private Bank Briefing: Issues Impacting the Private Bank Sector

The FCA published a Discussion Paper on a duty of care and potential alternative approaches (DP18/5) on 17 July 2018. The FCA is exploring whether there should be a duty of care in the financial services sector. It is...more

European Banking Authority’s Draft Guidelines on Outsourcing: Discussion of Key Themes

The EBA’s draft guidelines on outsourcing will impact cloud outsourcing and institutions’ deployment of FinTech. On 4 September 2018, a wide audience of interested individuals gathered at Canary Wharf for a public hearing...more

FCA Sets Out Stance on Cross-Border Booking Arrangements

The “Dear CEO” letter underlines the FCA’s open and pragmatic approach in the context of Brexit. The FCA has published a “Dear CEO” letter to firms, advising them of its position in relation to the use of cross-border...more

FCA to Create Global Financial Innovation Network

FCA teams up with other regulators to advance its idea of creating a global regulatory sandbox. The FCA, along with several other financial services regulators, has launched a consultation on the operating framework for a...more

First Details of Brexit Temporary Permissions Regime Published — Key Questions Answered

UK regulators expand on plans to smooth the transition for inbound passporting firms in the event of a “no deal” Brexit. Overview - HM Treasury published draft legislation on 24 July 2018 to establish a temporary...more

Regulators Publish Final Rules on SMCR Extension

The FCA and the PRA have published their Policy Statements, setting out final rules on the SMCR regimes for insurers and FCA solo-regulated firms. Key Points: ..The FCA has announced that the extended SMCR will apply to...more

FCA Supports Guidelines on the Open Banking Fall-Back Provisions Exemption

The FCA has outlined its approach to implementing key standards under the revised Payment Services Directive. The FCA has published a statement on its website relating to the European Banking Authority’s (EBA’s) Opinion...more

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