The Bank of England (BoE) has announced it has renewed its statement of commitment to the FX Global Code, based on the revised code dated December 2024. The FX Global Code outlines principles of good practice in the foreign...more
The Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA) and Bank of England are consulting on proposals to require firms to report operational incidents and material third party arrangements. In the face...more
The FCA, PRA, and Bank of England have published their finalised critical third party (CTP) rules (and accompanying guidance) in PS24/16 Operational resilience: Critical third parties to the UK financial sector....more
Our UK Financial Services Group examine the UK’s new mandatory reimbursement rules that will require payment service providers (PSPs) to reimburse victims of scam transactions....more
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
The announcement in 2021 of the intention to implement new rules directly targeting the types of tech service provider relied on by most financial institutions may be a necessary corrective given the heavy market...more
Goldman Sachs is reportedly in negotiations with federal prosecutors to resolve claims about its role in the Malaysian 1MDB scandal for upwards of $2 billion. A settlement—which “could include a guilty plea from Goldman’s...more
According to the U.S. Sentencing Guidelines for Organizations—and similar provisions found in other guidelines worldwide—an organization’s governing body is responsible to “exercise reasonable oversight with respect to the...more
New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more