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What the FCA’s Business Plan and Strategy really means: a brave new world

The UK Financial Conduct Authority’s (FCA) shift towards consumer protection is intensifying. At the same time, it is gearing up to become a more assertive regulator, intervening more frequently, following the example of its...more

What the FCA’s Business Plan and Strategy really means: financial crime

Financial crime has been a key area of focus for the UK Financial Conduct Authority (FCA) for a number of years, attracting some of the highest financial penalties, and this looks set to continue. With improvements to FCA...more

What the FCA’s Business Plan and Strategy really means: collection and use of data

The requirement for firms to collect and report quality data has never been more important, with the UK Financial Conduct Authority’s (FCA) outcome driven strategy looking to rely on firm data to realise its plans. In this...more

What the FCA’s Business Plan and Strategy really means: digital markets

The UK Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) recently published their Business Plans for 2022/23. The FCA also published a three-year strategy. But what does it really mean for firms? ...more

Preparing for the new Consumer Duty

The UK Financial Conduct Authority’s (FCA) latest consultation and feedback on the proposed Consumer Duty engages with some of the sticking points as well as providing draft rules and guidance. ...more

FCA and PRA Enforcement Action: Trends from 2021 and Predictions for 2022

As the dust looks like it is starting to settle on the Covid-19 pandemic, the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) have been busy resuming their enforcement agendas. Originally...more

Mitigating the risk of facilitating financial crime: the FCA's second enforcement action relating to cum-ex

The UK Financial Conduct Authority (FCA) has finalised two enforcements against brokers in relation to the cum-ex trading scandal; both for failing to mitigate the risk of facilitating financial crime. Further action seems...more

Changes to decision making at the UK FCA: supervisory control

In adopting a new approach to decision making, the Financial Conduct Authority (FCA) aspires to making bolder, more robust and assertive decisions, to prevent and stop harm faster and more effectively. This two-part blog...more

Changes to decision making at the UK FCA: enforcement action

Despite concerns being raised through the consultation process, the Financial Conduct Authority (FCA) has implemented its proposals to shift some decision making from the Regulatory Decisions Committee (RDC) to senior FCA...more

The Senior Managers and Certification Regime

Helping to prepare FMIs, payment and e-money firms for proposed implementation...more

Upper Tribunal upholds FCA’s decision to ban financial adviser convicted of non-financial misconduct

The Financial Conduct Authority (FCA) has imposed a ban on a financial adviser with a criminal conviction for non-financial misconduct, despite the case being contested in the Upper Tribunal. Although the FCA’s policy on...more

The Market Abuse Regulation: the First Five Years

July 2021 marks five years since the Market Abuse Regulation (596/2014/EU) (EU MAR) came into force on 3 July 2016. Since then, a myriad of developments has supplemented practitioners’ understanding and interpretation of EU...more

Sanctions-related reporting and compliance obligations for UK financial institutions

Financial institutions face a myriad of sanctions compliance issues arising out of the multiplicity of legal, regulatory and reporting regimes that they are subject to. For Financial institutions in the United Kingdom, the...more

UK corporate criminal liability reform

The UK Government has asked the Law Commission to review the law on corporate criminal liability and propose options for reform. Supporters of reform will use recent failures of the UK Serious Fraud Office to prosecute large...more

FCA proposes to take enforcement action against an individual relating to "non-financial misconduct"

The UK Financial Conduct Authority (the FCA) is proposing to take enforcement action against an individual, Jon Frensham, relating to "non-financial misconduct". The FCA has made clear its commitment to tackling...more

New operational resilience requirements and guidance for UK financial services firms

Following a year that saw firms’ operational resilience arrangements put to the test, the FCA, the PRA and the Bank of England published their long-awaited final rules and guidance on operational resilience on 29 March 2021,...more

A new perspective on the FCA’s focus on market abuse

The FCA's focus on market abuse is nothing new. Frequent references to the FCA's focus on tackling market abuse have featured in every single one of its Business Plans since 2013/14, with similar references also running...more

FCA takes first enforcement action for breaches of Short Selling Regulation

In October 2020 the FCA issued a Final Notice to Asia Research and Capital Management Ltd (ARCM). The FCA found that between 22 February 2017 and 3 December 2019, ARCM failed to make a number of notifications to the FCA and...more

Fair corporate criminal liability trial despite absence of company’s directing mind

The Court of Appeal has refused to grant a company leave to appeal its conviction for conspiracy to corrupt, notwithstanding that the directors who constituted the company's directing mind were not present at the trial and...more

Australian Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry: Key Themes in the...

The final report (the Report) of the Australian Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry (the Royal Commission) was released on 4 February 2019. The Report provides 76...more

A Comparative Look at Singapore's Proposed Accountability Regime for Senior Managers and Employees in Material Risk Functions

The MAS is proposing to require financial institutions to clearly identify and delineate the responsibilities of senior management and of employees in material risk functions. The proposed "Guidelines on Individual...more

Extending the SMCR to FCA-only authorised firms: Our insights

On 26 July 2017, the FCA published its much-anticipated consultation paper on the extension of the Senior Managers and Certification Regime (SMCR) to FCA-only authorised firms. We have set out below our initial thoughts on...more

Investigations: notes of employee interviews not privileged

Lawyers' notes of interviews with a bank's employees conducted as part of two investigations were not privileged since the employees were not the "client" and the notes were not lawyers' working papers, according to the...more

FCA sanctions bank and its MLRO for anti-money laundering systems failings

In this decision report we review the FCA’s action against Sonali Bank (UK) Ltd (Sonali Bank) and its money laundering reporting officer (MLRO), Steven Smith, in connection with failings identified in relation to Sonali...more

The new market abuse regime: a long road for financial institutions to navigate

On 3 July 2016, the Market Abuse Regulation (596/2014/EU) (MAR) came into force. Even though guidance and clarity from the European Securities and Markets Authority is still awaited in relation to certain key aspects of MAR,...more

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