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EU Reaches Provisional Agreement on AIFMD II

On July 20, 2023, the Council of the European Union (EU) announced1 a provisional agreement had been reached with the EU Parliament on the amendments to the Alternative Investment Fund Managers Directive (AIFMD) – commonly...more

Beginning of the End of EU Law in the UK?

The Financial Services and Markets Act 2023 (“FSMA 2023”) marks a watershed moment in British legislative history. FSMA 2023 introduces sweeping changes to the financial services regulatory infrastructure and will have a...more

ISSB Sustainability Disclosure Standards

The International Sustainability Standards Board (ISSB) published its first sustainability disclosure standards, IFRS S1 and IFRS S2 (Standards), on 26 June 2023 with the aim of improving the disclosure and transparency of...more

New Rules on Marketing Cryptoassets

The UK Financial Conduct Authority has published near final rules setting out its approach to regulating the financial promotion of ‘qualifying cryptoassets’. The new rules mean financial promotions on cryptoassets are only...more

European Commission publishes further guidance on interpreting SFDR

On 14 April 2023, the European Commission published its responses1to the questions2raised by the European Supervisory Authorities (ESAs) on a number of areas of uncertainty in the Sustainable Finance Disclosure Regulation...more

European Union Mandates IT and Cybersecurity Resilience Requirements for Investment Managers and Firms with Enactment of DORA

The European Union (EU) adopted Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (the “DORA Regulation”) in January 2023. The DORA Regulation seeks to establish a harmonised digital...more

FCA Contemplates Revising Asset Management Regulatory Framework

The UK Financial Conduct Authority (FCA) is seeking industry feedback in a discussion paper (DP)1 on potential regulatory reform of the asset management sector. If enacted, the UK Government’s Future Regulatory Framework...more

The SEC’s 2023 Exam Priorities in Context: Private Fund Arrangements

On Tuesday, February 7, the Division of Examinations of the U.S. Securities and Exchange Commission released its 2023 Examination Priorities. Private fund sponsors and managers should pay attention to the Priorities for two...more

EU Commission Report on the Functioning of the EU Securitisation Regulation – Considerations for the CLO Market

Key Points - The European Commission (“EU Commission”) has published its report on the functioning of the EU Securitisation Regulation which contains the EU Commission’s assessment of a number of key aspects of the...more

Proposal for U.K. Sustainability Disclosure Rules Will Apply to Investment Managers

The United Kingdom’s Financial Conduct Authority (FCA) has issued proposed rules to establish a U.K. sustainability disclosure regime (SDR) providing a U.K. take on a topic many investment managers have been dealing with in...more

EU Close to Introducing Groundbreaking Law to Regulate Crypto

In October 2022 the European Council approved the Markets in Crypto-Assets (MiCA) Regulation, one of the first attempts globally at comprehensive regulation of cryptocurrency markets. The regulation extends to money...more

New FCA Principle 12: Consumer Duty

Key Point - The FCA is introducing a new Principle for Businesses, namely Principle 12: “A firm must act to deliver good outcomes for retail customers.” Firms will need to assess and evidence how they are acting to...more

EU’s Sustainable Investing Taxonomy to Include Gas and Nuclear Sector Products – EU Parliament Vote

The European Parliament has rejected a motion to remove gas and nuclear investment products from the EU’s sustainable investment taxonomy, surprising many who consider their inclusion to be greenwashing. This article...more

The FCA and SEC Annual Reports – 2022 Comparison

Key Points - The SEC and the FCA each publish annual reports, which can offer a useful insight into their enforcement actions. The data in the reports only represents a snapshot of the regulators’ activities, but is...more

FCA Clarifies Its Position on 'Significant SYSC Firm' Dilemma

The FCA announced earlier yesterday that it will consult on amending the definition of 'Significant SYSC Firm' to ensure that no firms will be subject to the enhanced rules of the Senior Managers and Certification Regime...more

More FCA-Authorized Firms to Be Considered Enhanced SMCR Firms

A number of asset managers currently categorized as core firms under the U.K. Senior Managers and Certification Regime (SMCR) may be recategorized as falling within the enhanced firms SMCR regime. ...more

FCA Rules on Diversity and Inclusion for Listed Company Boards and Executive Management

The Financial Conduct Authority (FCA) has announced that in-scope issuers for financial years starting on or after April 1, 2022, will be required to provide disclosures with respect to the diversity of their boards and...more

Diversity and Inclusion on Company Boards and Excusive Management Policy

In April 2022, the Financial Conduct Authority (the FCA) issued its final policy statement on diversity and inclusion (D&I) requirements for premium and standard listed issuers with the object of increasing transparency for...more

FCA Has Extended the Rule on Listed Companies’ Climate-Related Financial Disclosure Standards

Who is Now Subject to Climate-Related Financial Disclosures? Issuers of standard listed equity shares and Global Depositary Receipts (GDRs) will now be required to satisfy certain previously issued climate-related...more

FCA Releases Three-Year Strategy and Business Plan

On 7 April 2022 the Financial Conduct Authority (FCA) released a three-year strategy for 2022-2025(the “Strategy”), setting out how the FCA aims to improve outcomes for UK consumers and markets. This was released alongside...more

Issues Affecting Sustainable Finance in 2022

If, as they say, past is prologue, then boards of directors in the United States should follow closely lessons learned by their European and British counterparts when it comes to the potential role sustainable finance plays...more

EU New Net Short Position Disclosure Threshold at 0.1%—ESMA Confirms Disclosure of Existing Positions Required

As previously notified, the European Commission has revised rules to permanently lower the initial net short position reporting threshold from 0.2 per cent to 0.1 per cent under the EU Short Selling Regulation (EU SSR) and...more

In Principle: Key Things Authorised Firms Need to Know for 2022

The SFDR and the Taxonomy Regulation: Key Developments and What Firms Can Expect in the Coming Year - Almost a year on from the date on which the European Union’s Sustainable Finance Disclosure Regulation (SFDR) came into...more

EU Net Short Position Disclosure Threshold Lowered to 0.1% from 31 January 2022

The European Commission has published rules to permanently lower the initial net short position reporting threshold from 0.2 per cent to 0.1 per cent under the EU Short Selling Regulation (EU SSR). The lower disclosure...more

Proposed UK Sustainable Disclosure Requirements

The Financial Conduct Authority (FCA) has issued a Discussion Paper (DP21/4) (the “DP”) seeking industry participants’ views on the proposed new Sustainability Disclosure Requirements (SDR) and an accompanying sustainability...more

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