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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

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

UK Government Publishes Draft UK-EU Free Trade Agreement With Financial Services Chapter

The government sets out a bold and ambitious arrangement for financial services, including free market access and a new Financial Services Committee. On 19 May 2020, the UK government published draft legal texts of 12...more

UK Firms Should Share Customer Information Cross-Border Intra-Group to Fight Money Laundering and Terrorist Financing

UK government encourages regulated firms to share customer information within corporate groups, highlighting interaction with firms’ obligations under the Proceeds of Crime Act 2002 and GDPR. The UK government has...more

COVID-19: FCA Delays Implementation of SCA Under PSRs 2017

On 30 April 2020, the FCA released a statement announcing a six-month extension to the deadline for firms’ implementation of strong customer authentication (SCA) for e-commerce under the Payment Services Regulations 2017...more

FCA Announces Additional Primary Market Measures to Support Listed Companies

The package combines temporary policy interventions and existing options to help companies raise new share capital during the COVID-19 crisis. On 8 April 2020, the FCA published a Statement of Policy and related technical...more

FCA and PSR Support CMA’s Guidance on Business Cooperation Under Competition Law

The CMA recognises that businesses may need to cooperate to ensure supply of essential products and services during the COVID-19 outbreak. On 27 March 2020, the FCA and Payment Systems Regulator (PSR) announced their...more

COVID-19: PRA Welcomes Suspension of Dividends, Share Buybacks, and Cash Bonuses

Seven of the largest systemically important UK deposit-takers to suspend dividends and share buybacks and to cancel payments of any outstanding 2019 dividends. On 31 March 2020, the PRA published a statement on deposit...more

FCA and PRA Statement on SM&CR and COVID-19: Expectations of Dual-Regulated Firms

UK Regulators announce new measures after acknowledging firms affected by COVID-19 will need to keep their governance arrangements under review. On 3 April 2020, the FCA and the PRA released a statement announcing several...more

COVID-19: FCA Dear CEO Letter to Firms Providing Services to Retail Investors

The FCA sets out its approach on client identity verification, supervisory flexibility over best execution obligations and 10% depreciation notifications, and financial resilience. On 31 March 2020, the FCA published...more

COVID-19 Bank Lending Relief Measures

Several countries have announced or have already implemented extensive debt relief measures for consumers and companies. In some instances these measures also include debt moratoria. The following provides a brief overview of...more

Preliminary Financial Accounts - the FCA’s Moratorium “Request”

The FCA asks issuers to delay publishing their preliminary financial results due to COVID-19. Key Points: ..The FCA is asking issuers to delay the publication of their preliminary financial accounts by at least two...more

Changes to Reporting Requirements for Issuers in Light of COVID-19

UK regulators announce a further package of measures to ease the burden on issuers. In response to the COVID-19 pandemic, UK regulators have published further measures affecting issuers, to try to preserve the flow of...more

FCA Issues Guidance on Key Workers in Financial Services

The FCA has clarified which people working in regulated financial services firms will meet the definition of a “key worker”. On 19 March 2020, the UK government published guidance setting out which “key workers” will be...more

Bank of England Announces Measures to Address Challenges of COVID-19

The regulator is taking immediate supervisory and policy measures to help support banks, insurers, and financial market infrastructures. The Bank of England and the Prudential Regulation Authority (PRA) have announced a...more

HM Treasury Responds to the Call for Evidence on Regulatory Coordination

Financial Services Regulatory Initiatives Forum and the Regulatory Initiatives Grid to be introduced this summer. On 11 March 2020, HM Treasury published its response to the Call for Evidence on Regulatory Coordination....more

FCA Sets Out Its Expectations of Firms’ Response to COVID-19

The FCA expects firms to use flexibility to support consumers, has delayed new publications, and extended deadline for responses to published consultations to 1 October 2020. The Financial Conduct Authority (FCA) has...more

FCA Breaks Ranks in Its Approach to Using Wholesale Data

A Call for Input reveals that the FCA is planning for a post-EU future and examining ethics with regard to MAR. On 9 March 2020, the Financial Conduct Authority (FCA) issued a Call for Input on the way that wholesale...more

FCA Proposes New Rules on Climate-Related Disclosures by Listed Issuers

The FCA is moving towards formalising issuers’ compliance with the TCFD recommendations. Key Points: ..The FCA is proposing that premium listed commercial companies will need to disclose how they have implemented the...more

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