HM Treasury (HMT) published a policy statement on the appointed representatives regime, setting out how it proposes to adjust the appointed representative (AR) legislative framework to provide further needed protection for...more
The appointed representatives regime has been around longer than many of us might realise, having been introduced in 1986, and so predating our beloved Financial Services and Markets Act 2000 (FSMA) by some years. No doubt,...more
HM Treasury (HMT) has announced an extension to the consultation deadlines set out in its policy update on applying the Financial Services and Markets Act 2000 (FSMA) model of regulation to the Capital Requirements Regulation...more
From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was...more
HM Treasury (HMT) has published an update to its policy note on applying the Financial Services and Markets Act 2000 model of regulation to the UK Capital Requirements Regulation (UK CRR). An earlier version of the policy...more
The Financial Conduct Authority (“FCA”) published a consultation paper (“CP 25/19”) on the ancillary activities exemption (the “AAE”) on 3 July 2025. The AAE enables commercial users and producers of commodities to undertake...more
On June 26, 2025, the UK government brought into force the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 (the “2025 Amendment”), marking a notable development in the UK government’s sanctions...more
Following the publication by HM Treasury of the draft legislation establishing a financial services regulatory regime for cryptoassets in the UK, on 28 May 2025 the UK Financial Conduct Authority (FCA) published Consultation...more
I. U.S. Sanctions - President Trump Threatens Sanctions on Russia Following Drone Attack on Ukraine: On May 28, Bloomberg reported that President Trump said he was “‘absolutely’ considering new sanctions against Russia as...more
The Bank Resolution (Recapitalisation) Act 2025 (Act) received Royal asset on 15 May 2025. Although deceptively short and dependant on the passing of further regulations in order to come into effect, it introduces significant...more
In October 2024, HM Treasury (HMT) published a consultation paper amid perceived concerns related to the “buy now, pay later” (BNPL) sector, including uninformed consumer decisions, affordability checks and levels of...more
HM Treasury published on 15 May 2025 the legal framework which will govern the establishment and operation of the Private Intermittent Securities and Capital Exchange System (PISCES), a new type of intermittent private...more
In an exciting week for consumer credit lawyers, in addition to the consultation paper on the reform of the Consumer Credit Act 1974 (CCA), we also have HM Treasury’s response to the feedback it received from the 61...more
On 19 May 2025, HM Treasury published its consultation response on the regulation of certain buy-now-pay-later (BNPL) products, setting out its final position, and laid a draft statutory instrument before Parliament to effect...more
The Ninth Commencement Regulations–the Financial Services and Markets Act 2023 (Commencement No. 9) Regulations 2025–under the Financial Services and Markets Act 2023 (FSMA 2023) were made and have been published. The Ninth...more
Ahead of the commencement of the UK Carbon Border Adjustment Mechanism (CBAM), key building blocks for its regulatory framework are moving into place. Following consultations in 2023 and 2024, draft legislation and a policy...more
The UK Payment Systems Regulator (PSR) has published its annual plan and budget for 2025/26. The foreword by Aidene Walsh, Chair of the PSR, references the government's announcement to incorporate the PSR into the FCA and...more
The UK government has published long-awaited draft legislation setting out how the regulatory perimeter will be expanded to include cryptoassets, with the introduction of new regulated activities relating to cryptoassets,...more
On 29 April 2025, HM Treasury published near-final draft legislation establishing a financial services regulatory regime for cryptoassets in the UK, along with a policy note explaining the intended policy outcomes of the...more
Welcome to your weekly update from the A&O Shearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions....more
The Money Laundering and Terrorist Financing (Amendment) Regulations 2023, which amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (known as the MLRs), come into...more
On 6 October 2023, the Court of Appeal handed down judgment in the case of Mints & ors v PJSC National Bank Trust & anor [2023] EWCA 1332. The judgment confirmed that the UK’s sanctions do not preclude the English courts...more
On 7 June 2023, the U.K. government published a statutory instrument (the Financial Services and Markets Act 2000 (Financial Promotion) (Amendment) Order 2023 (FP (Amendment) Order) and related explanatory memorandum)...more
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
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