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UK Regulators Proposed Framework for Critical Third Parties

Financial services firms are increasingly reliant upon third-party companies to provide important services, ranging from cloud services and data analytics to machine learning and cash distribution. As these third parties...more

UK Update: ESG Data and Ratings Providers to Come Within Regulatory Perimeter

A key outcome of the UK’s Financial Conduct Authority’s (“FCA”) ESG strategy is the promotion of integrity within the ESG-labelled securities market, supported by the growth of effective service providers. To that end, in...more

AI and Algorithms in Financial Services - Future Areas of Focus

Artificial intelligence (AI) and algorithmic models are used extensively in the financial services sector across a broad range of business areas. Two-thirds of respondents to a survey conducted jointly by the UK’s Prudential...more

Greenwashing - a new regulatory risk

A key plank to the Government’s regulatory ESG agenda is simple: investment in sustainable projects and companies will assist the UK in meeting its environmental targets. Consumer interest appears to be aligned: there is a...more

Alternative Data in ESG: the regulatory risks

Alternative data is big business. Globally, buy-side firms spent $1.71 billion on it during 20201, over half of all hedge funds use it to make investment decisions, and it is increasingly used to validate the sustainability...more

Sanctions Update: Key Global Jurisdictions Continue to Announce New Measures Targeting Russian Elites and Strategic Industries

We wanted to share an update on Russia sanctions developments in the United Kingdom, European Union, and the United States that occurred between March 16 and 24. As summarized below, key global jurisdictions have continued to...more

United States and Allies Sanction Russia for Invading Ukraine

The United States, the European Union (EU), the United Kingdom (UK), and other allies and partners are implementing wide-ranging, novel sanctions and sweeping export controls against Russia in response to its invasion of...more

PRA messaging around firms’ operational resilience to cyber threat

In May the PRA’s Lyndon Nelson gave a speech about the development of the Regulator’s response to cyber risk. In his speech he...more

FCA Discussion Paper - Diversity, inclusion and its future impact on SMCR

During July the FCA made two announcements which demonstrate its continued focus on culture and diversity and their intersection with governance. In a Consultation Paper, it announced proposed changes to Listing Rules which...more

FCA Consultation Paper: Environmental disclosures and scrutiny of ‘Greenwashing’

On 22 June the FCA published two Consultation Papers setting out its proposals for climate-related disclosure obligations on the regulated sector. The first paper proposed extending the application of an existing Listing Rule...more

The risk of market abuse in algorithmic trading

In its May 2021 edition of Market Watch, the FCA described actions it took to address the impact which a firm’s trading algorithm was having in the market. Its concerns had been raised after the Regulator’s own internal...more

UK Government Tackles Greenwashing

Yesterday the UK’s Treasury Department announced the appointment of a Green Technical Advisory Group (GTAG), set up to advise and assist the UK Government in its development and implementation of a Green Taxonomy, aimed at...more

The SMCR, five years on

Five years ago, on 7 March 2016, the Senior Managers and Certification Regime (SMCR) came into force. At first it applied only to dual-regulated banks, those which are regulated both by the FCA and PRA. Originally...more

UK Supreme Court Ruling on Territorial Extent of SFO's Powers Impacts SFO’s Evidence Gathering Capabilities

On February 5, 2021 the Supreme Court handed down judgment in the case of R (on the application of KBR, Inc) v Director of the Serious Fraud Office, finding in favor of the Appellant, KBR, Inc (KBR). This high-profile case...more

UK Supreme Court Rules on Territorial Extent of SFO’s Powers

On February 5, 2021 the Supreme Court handed down judgment in the case of R (on the application of KBR, Inc) v Director of the Serious Fraud Office, finding in favor of the Appellant, KBR, Inc (KBR). This high-profile case...more

Can Kicking and Buck Passing: Reform of Corporate Criminal Liability

In January 2017, the UK Government issued a consultation paper calling for evidence on reforming corporate criminal liability for economic crime. Nearly four years later, on 3 November 2020, the Government’s response was...more

FCA’s statement on cannabis related businesses POCA application

On Friday 18 September the FCA issued a statement, setting out its approach to assessing applications for listing made by cannabis-related businesses. The statement is short and will be followed in due course by a...more

A powerful lesson in UK Data Protection law restrictions

The protections afforded by the GDPR and the UK’s 2019 Data Protection Act (‘DPA’) are not naturally associated with efforts to frustrate and restrict the use of the death penalty internationally. However, the recent Supreme...more

Cyber issues on the FCA’s radar

On 11 March 2020 the FCA published new research on cyber security. The research is the product of its Cyber Coordination Groups (CCGs) which were created through an FCA initiative in 2017. The CCGs bring together over 185...more

High Court Ruling May Impede Unexplained Wealth Order Use

On 8 April 2020 the NCA suffered its first setback in using Unexplained Wealth Orders (‘UWOs’). The Respondents in NCA v Baker successfully applied to discharge UWOs relating to three properties in London, all held by...more

State of the Markets – Speech by Mark Steward

On 6 February 2020, Mark Steward, Executive Director of Enforcement and Market Oversight at the Financial Conduct Authority (“FCA”), spoke at the 19th Annual Institute on Securities Regulation in Europe. His speech,...more

SFO - First 100 Days With the New Director

Reviewing the first 100 days of an administration is an American pastime, typically used as a yardstick against which to measure the initial impact of a new presidency. The practice started in Franklin D Roosevelt’s first...more

Blurred Vision – Cannabis and Reporting

On 17 October, Canada legalised the recreational use of marijuana, following the passing of The Cannabis Act 2018 this summer. This marks a further step in the drug's deregulation in Canada, where its medical use has been...more

Final Notice in Tesco Personal Finance Plc - Cyber Attacks and the Need for Dress Rehearsals

In a Final Notice dated 1 October 2018, the FCA sanctioned Tesco Personal Finance Plc for failings connected with a cyber attack it suffered in November 2016. The attack originated from Brazil and attackers managed to...more

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