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HM Treasury Consults on UK Wholesale Markets Reform

Proposals signal that the UK government is willing to diverge significantly from EU rules. On 1 July 2021, HM Treasury published a consultation on its Wholesale Markets Review....more

Private Bank Briefing – June 2021

The latest edition of our Private Bank Briefing provides a roundup of legal and compliance issues impacting private banks and their clients from Q2 2021. In this edition, we cover sustainable finance developments, the...more

Taskforce Proposes New Approach to Financial Regulation in the UK

A report from the Taskforce on Innovation, Growth and Regulatory Reform provides recommendations for how the UK can “re-imagine” its approach to regulation post-Brexit. On 16 June 2021, the Taskforce on Innovation,...more

FCA Consults on Rule Changes to Accommodate SPACs

Proposed changes to the UK Listing Rules would allow certain SPACs to avoid a listing suspension. Key Points: ..The FCA is proposing to amend its rules so that SPACs meeting certain conditions and disclosure...more

FCA Consults on Changes to UK MiFID Conduct and Organisational Requirements

The consultation proposes changes to rules on research and best execution reporting. On 28 April 2021, the FCA published a Consultation Paper (CP21/9) on proposed changes to UK MiFID relating to research unbundling and...more

Second FCA Consultation on New Prudential Regime for Investment Firms

Latest FCA consultation focuses on remuneration, risk management and governance, and liquidity requirements. Key Points: The consultation: ..Sets out the FCA’s proposals for the new remuneration rules for FCA...more

Private Bank Briefing – March 2021

ESMA reminds firms on rules of reverse solicitation - In a statement published on 13 January 2021, ESMA reminded firms not established or situated in the EU of the MiFID II requirements on the provision of investment...more

PRA Publishes Findings on Its Evaluation of the SMCR

The PRA has released a largely positive report, along with nine follow-up actions and recommendations on the SMCR for PRA-regulated firms. Key Points: ..There is no need for major changes to the SMCR. ..There are...more

Corporate Culture: How to Attain Sustainable Change [Video]

Culture has become a point of focus for regulators and corporate stakeholders. The UK Financial Conduct Authority has taken a particular interest in culture and conduct within the financial services sector following the...more

Private Bank Briefing: Issues Impacting the Private Bank Sector - December 2020

Ahead of the end of the Brexit transition period, on 31 December 2020, regulators in the UK and the EU have issued a number of updates: Share trading obligation - In relation to the potential conflict between the share...more

UK Chancellor Outlines Future for Financial Services Post-Brexit

Equivalence decisions for EEA states, green finance and fintech initiatives are at the forefront of the UK government’s priorities. On 9 November 2020, the UK Chancellor of the Exchequer, Rishi Sunak, delivered a statement...more

ESMA’s STO Guidance Aims to Limit Post-Brexit Disruption

However, ESMA’s proposed changes are less sweeping than required to achieve this aim. Should the Brexit transition period end without a UK equivalence decision, ESMA has issued guidance to limit the impact on the trading...more

HM Treasury Consults on Post-EU Financial Services Regulatory Framework

The UK government signals a diversion from the onshored regime towards a more flexible financial services regulatory framework. HM Treasury has published a consultation paper marking the start of Phase II of its financial...more

UK Firms Granted Extra 15 Months for Brexit Onshoring Preparations

The FCA, Bank of England, and PRA have published updated rules for firms post-Brexit and intend to delay many (but not all) onshoring changes. Key Points: ..The FCA has published an updated version of the FCA Handbook,...more

Private Bank Briefing: Issues Impacting the Private Bank Sector - September 2020

On 22 July 2020, HM Treasury published a policy statement setting out the UK government’s rationale and proposed approach for extending the transitional period for third country benchmarks under the UK Benchmarks Regulation...more

The MAR Review — ESMA’s Final Report

ESMA advises the European Commission to consider some, but not all, of ESMA’s original proposals — and gives guidance on pre-hedging and market soundings along the way. Key Points: ..Pre-hedging / front running: ESMA...more

MAR and Sustainable Investing/ESG

ESG and the reasonable investor test under MAR. Background - Historically, “profit maximisation” has been regarded as the sole (or predominant) objective for investors. Today, however, an ever-increasing proportion of...more

European Commission Proposes Changes to MiFID II Due to COVID-19

Many of the wide-ranging amendments address the perceived barriers MiFID II introduced in capital markets and are likely to be welcomed by industry. Key Points: ..The amendments aim to remove administrative burdens that...more

Private Bank Briefing: Issues Impacting the Private Bank Sector - July 2020

Brexit: Latest Updates - Private banks are currently going through a process of assessing the changes that need to be made to their systems and controls, in addition to client facing documentation, to facilitate the...more

UK Decides Against Implementing Certain Key Areas of EU Financial Services Legislation

The UK government clarifies its legislative plans for financial services regulatory reforms post-Brexit. On 23 June 2020, the House of Commons published a written statement from Rishi Sunak, Chancellor of the Exchequer, on...more

Senior Manager Responsibilities in the Ongoing COVID-19 Situation

Following the large-scale changes and challenges faced by firms during the initial phase of COVID-19, firms are beginning to consider what their operating model will be in the next phase and over the longer-term. For...more

FCA Consults on Post-Brexit Prudential Regime for Investment Firms

Important changes ahead for investment firms as the FCA’s Discussion Paper (DP20/2) indicates that the UK may depart from EU capital rules. Key Points: ..FCA consults on a UK capital regime that in some respects breaks...more

FCA Fails to Find Its Watersheds Moment in Adams v. Options SIPP UK LLP

The English High Court’s findings are likely to have wide implications, not just for SIPP operators but for all regulated firms. Key Points: ..Regulatory obligations are not intended to take precedence over contractual...more

ESMA Draft Guidelines on Outsourcing to Cloud Service Providers

The new guidelines reflect the European Commission’s aim to provide additional certainty for regulated entities outsourcing to cloud services. On 3 June 2020, ESMA published a consultation paper on draft guidelines...more

MiFID’s Transparency Rules: ESMA Confirms Equivalence of Numerous Non-EU Venues

Implications for users of third-country trading venues as ESMA confirms the list of venues who meet the criteria in its updated opinions on transparency and position limits. On 3 June 2020, ESMA published updated versions...more

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