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The UK’s Lighter-Touch, Post-Brexit, Short Selling Regime

The U.K. is currently engaged in a wide-ranging review of the inherited package of EU financial services law. The rules on short selling, which impose disclosure obligations and restrictions on persons seeking an economic...more

Draft Legislation Published for Implementing UK's Retained EU Law (Revocation and Reform) Act 2023

The draft Retained EU Law (Revocation and Reform) Act 2023 (Consequential Amendment) Regulations 2023, laid before Parliament on October 16, 2023, will implement certain aspects of the Retained EU Law (Revocation and Reform)...more

UK Regulator Issues Statement on New Growth and International Competitiveness Objective

The U.K. Financial Conduct Authority has published a statement setting out how its work to support the 'key drivers' of productivity will facilitate delivery of its new secondary objective and how it intends to report on...more

UK Regulator Proposes Framework for a Consolidated Tape

On July 5, 2023, the U.K. Financial Conduct Authority launched a consultation on a proposed U.K. consolidated tape for bonds. MiFID II introduced requirements for a "consolidated tape" for transactions in equity and...more

First Commencement Regulations Under UK Financial Services and Markets Act 2023

The Financial Services and Markets Act 2023 (Commencement No. 1) Regulations 2023 were made on July 10, 2023 and will bring into force provisions under the Financial Services and Markets Act 2023 from either July 11, 2023,...more

UK Government Sets Out Plan for Revoking EU Financial Services Laws

Following finalization of the Financial Services and Markets Act 2023, HM Treasury published a Delivery Plan for the Building a Smarter Financial Services Regulatory Framework for the UK. The Delivery Plan compliments the...more

UK Prudential Regulation Authority Consults on Approach to Reviewing Rules

The U.K. Prudential Regulation Authority opened a consultation on June 30, 2023, on its proposed approach to reviewing its rules, including a proposed statement of policy. The Financial Services and Markets Act 2023 transfers...more

UK Financial Conduct Authority Seeks Comment on Draft Rule Review Framework

The U.K. Financial Conduct Authority launched a consultation on July 14, 2023, on its proposed Rule Review Framework. The Financial Services and Markets Act 2023 transfers responsibility for making detailed rules to the...more

UK Government Publishes Edinburgh Reforms for Financial Services

The U.K. Government announced on 9 December 2022 a series of initiatives, billed as the Edinburgh Reforms, to reform the laws for the U.K. financial services sector. In this note, we consider these reforms in detail and what...more

The Brexit Freedoms Bill and the MiFID Override for Financial Services Regulation

U.K. financial regulation includes a small and unusual provision, the so-called “MiFID override,” which prioritises the EU’s MiFID II regime over the U.K.’s own regulatory framework when determining questions of what is...more

UK Regulators Propose Changes to Margin Requirements for Non-Centrally Cleared Derivatives

The U.K. Prudential Regulation Authority and Financial Conduct Authority have issued a joint consultation paper on proposals to amend the U.K. Binding Technical Standards on margin requirements for non-centrally cleared...more

Final UK Policy on Regulation of Central Counterparties and Central Securities Depositories Post-Brexit

HM Treasury has published its final policy approach to the regulation of central counterparties and central securities depositories under the Financial Services Future Regulatory Framework Review. The response is published on...more

HM Treasury Publishes Final Policy Following Financial Services Future Regulatory Framework Review

HM Treasury has published its final response to the Financial Services Future Regulatory Framework Review in which it sets out the government's policy approach to reforming the U.K.’s regulatory architecture post-Brexit. The...more

UK Financial Services and Markets Bill 2022

The recently published Financial Services and Markets Bill (FSM Bill) is intended to recast the U.K.’s regulatory architecture post-Brexit. It was introduced to Parliament on 20 July 2022. The Bill implements the outcomes of...more

UK Government Publishes Financial Services and Markets Bill

The U.K. government has published the much anticipated Financial Services and Markets Bill. Following its exit from the EU, the U.K. has undertaken a fundamental review of how financial regulation policy and rules should be...more

Government Details Proposed Financial Services and Markets Bill

Following the Queen's speech yesterday, the government has published a briefing pack setting out details of the bills that it intends to introduce, including the so-called Brexit Freedoms Bill as well as key legislation...more

Queen’s Speech Confirms Government Will Proceed with Brexit Freedoms Bill

Prince Charles, Prince of Wales, delivered the Queen’s speech in which he announced that the government will be introducing the so-called Brexit Freedoms Bill, which was first announced by Prime Minister Boris Johnson on...more

UK Conduct Regulator Commits to Three-year Strategy of Improving Outcomes of Regulation

The U.K. Financial Conduct Authority has published a three-year Strategy on improving outcomes of regulation and its 2022/23 Business Plan. In the 2022-2025 Strategy, the FCA outlines its expectations of financial services...more

EU Grants Further Time-Limited Equivalence for UK CCPs

An EU Commission Implementing Decision extending the equivalence of U.K. CCPs to June 2025 has been published in the Official Journal of the European Union. The equivalence decision applies to U.K. CCPs already established...more

UK Government Announces "Brexit Freedoms Bill"

U.K. Prime Minister Boris Johnson has announced that a "Brexit Freedoms Bill" will be put before Parliament. Upon Brexit taking effect, all then in force EU Regulations were "on-shored" automatically into U.K. laws, pursuant...more

ESMA’s Post-Brexit Regime for UK Investment Firms Revisited—‘Equivalence’ or Direct Regulation?

The European Union’s financial regulatory regime for third-country access in many sectors relies on a framework of “equivalence,” whereby institutions based in approved non-EU countries with similar standards may have varying...more

ESMA’s Post-Brexit Regime for UK Investment Firms—‘Equivalence’ or Direct Regulation?

The European Union’s financial regulatory regime for third-country access in many sectors relies on a framework of “equivalence,” whereby institutions based in approved non-EU countries with similar standards may have varying...more

The EU-UK Future Relationship: EU Announces Its Timetable For Cross-Border Equivalence In Financial Services

The U.K. House of Commons has approved the Withdrawal Agreement. Assuming this is ratified by the EU, and Royal Assent is achieved in time, the U.K. will leave the EU on January 31, 2020, entering into a “transition” or...more

Emir Refit: Impact of the Reclassification of Funds

The EU proposals to amend technical aspects of the European Market Infrastructure Regulation (EMIR), known colloquially as ‘EMIR 2.1’ or ‘EMIR Refit’, have been politically agreed. The final text is likely to be published in...more

The New EU Law on Intermediate Holding Companies for Third-Country Banking Groups

Non-EU banking groups (“non-EU groups”) with large EU operations will be required to establish an EU intermediate parent undertaking (“IPU”) according to the final changes to the Capital Requirements Directive (“CRD 5”)...more

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