Sam Millar

Sam Millar

DLA Piper

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FCA thematic review finds failures in oversight of authorised representatives in insurance industry

On 22 July 2016, the Financial Conduct Authority (FCA) published the results of a thematic review in which the FCA found significant shortcomings in the control and oversight of appointed representatives (ARs) by their...more

8/4/2016 - Financial Conduct Authority (FCA) Insurance Industry Risk-Based Approaches UK

No more passporting post-Brexit?

UK authorised financial institutions (banks, investment firms, fund managers, insurers, insurance intermediaries payment institutions and e-money issuers) can carry out their activities across the EEA without setting up a...more

7/27/2016 - AIFMD CRD IV Directive EEA EU Financial Services Industry MiFID Passporting Payment Services Directive Third Country Entities UK UK Brexit

Market Abuse Regime: Overview for AIM companies

INTRODUCTION The Market Abuse Regulation ("MAR") introduces a new market abuse regime from 3 July 2016. MAR is designed to introduce a common regulatory framework on market abuse across the EU and generally will extend the...more

5/9/2016 - AIM Disclosure Requirements EU EU Market Abuse Regulation (EU MAR) Financial Conduct Authority (FCA) FSMA London Stock Exchange UK

Market Abuse Regime: Overview for Offical List Companies

- INTRODUCTION The Market Abuse Regulation ("MAR") will replace the existing market abuse regime from 3 July 2016. MAR is designed to introduce a common regulatory framework on market abuse across the EU and generally...more

5/9/2016 - EU EU Market Abuse Regulation (EU MAR) European Securities and Markets Authority (ESMA) Listing Rules UK

David Cameron announces acceleration of new corporate offence of failing to prevent "associated persons" from facilitating tax...

The UK Government has announced the proposed introduction of a new corporate offence of failing to prevent the facilitation of tax evasion. The new offence is likely to build on draft legislation produced in...more

4/15/2016 - Corporate Counsel Offshore Companies Serious Fraud Office Tax Evasion UK UK Bribery Act

Financial Services Regulation - Exchange International Newsletter - Issue 28 - January 2016

DLA Piper’s Financial Services International Regulatory team welcomes you to the twenty-eighth edition of ‘Exchange – International’ – an international newsletter designed to keep you informed of regulatory developments in...more

2/8/2016 - BRRD Data Outsourcing Enforcement Actions EU Financial Conduct Authority (FCA) Interest Rate Swaps Market Abuse MiFID Payment Processors Securities Financing Transactions (SFTs) Senior Managers Insurers Regime (SMIR) Singapore SMEs UCITS UK

Serious Fraud Office - first conclusion of a case under Section 7 of the Bribery Act 2010 - first deferred prosecution agreement

In 2012 the Government of Tanzania began the process of raising USD $600 million by way of a sovereign note private placement. The Tanzanian subsidiary of Standard Bank Group Ltd (SBG), Stanbic Bank Tanzania Ltd (Stanbic),...more

12/4/2015 - Deferred Prosecution Agreements Foreign Investment Private Placements Serious Fraud Office UK UK Bribery Act

FCA consults on UK implementation of the Market Abuse Regulation

On 5 November 2015, the Financial Conduct Authority (FCA) published a consultation paper CP15/35: Policy proposals and Handbook changes related to the implementation of the Market Abuse Regulation (2014/596/EU) (Consultation...more

12/1/2015 - Consultation EU Financial Conduct Authority (FCA) Market Abuse UK

Proposed Guidance for Firms Outsourcing to the "Cloud" and Other Third-Party IT Services: FCA Guidance Consultation 15/6 -...

The FCA Guidance Consultation 15/6 consults on proposed guidance to clarify various requirements imposed on firms, when outsourcing to the 'cloud.' The proposed guidance is the FCA's response to uncertainty on how the FCA...more

11/18/2015 - Banking Sector Cloud Computing Financial Conduct Authority (FCA) FSMA Information Technology Outsourcing UK

UK Government Plans to Extend New Senior Managers and Certificate Regimes to all UK Regulated Firms

The initial reception to the new senior managers and certification regime (SM & CR) for banks building societies and PRA-designated investment firms was that the government had gone too far. There was concerns that...more

10/19/2015 - Banking Sector Fair and Effective Markets Review (FEMR) Financial Institutions Investment Firms Presumption of Reliance Prudential Regulation Authority Regulatory Agenda Senior Managers

FCA and PRA Set Out New Rules on Whistleblowing.

The FCA has published new rules designed to encourage a culture in which individuals raise concerns and challenge poor practice and behaviour. The new regime represent a significant expansion on the scope of the previous...more

10/12/2015 - Banking Sector Best Management Practices Chief Compliance Officers Financial Conduct Authority (FCA) Financial Institutions Investment Funds New Guidance Prudential Regulation Authority UK Whistleblower Protection Policies Whistleblowers

Resolution Ready? New Controls For IT Supplies to Distressed Banks

A current "hot topic" for banking technology contracts is termination rights. 1 October brings new statutory controls, potentially affecting termination rights in many IT contracts. For banks in particular, regulatory led...more

10/8/2015 - Bank of England Banks Contract Termination IP License Prudential Regulation Authority Regulatory Agenda Ring-Fencing Service Contracts UK UK Insolvency Act

The New EU Benchmark Regulation

There has been increased pressure on the EU to restore confidence in the integrity and accuracy of benchmarks following the LIBOR and EURIBOR market-rigging scandals. Multi-million Euro fines have already been levied against...more

9/30/2015 - Benchmarks Code of Conduct EU EURIBOR European Commission European Securities and Markets Authority (ESMA) Financial Institutions Financial Instruments Financial Regulatory Reform Libor

Financial Services Regulation: Exchange – International Newsletter - Issue 26 – May 2015

DLA Piper’s Financial Services International Regulatory team welcomes you to the twenty-sixth edition of ‘Exchange – International’ – an international newsletter designed to keep you informed of regulatory developments in the...more

6/2/2015 - AIFMD AML-CTF Australia Banks Basel III Capital Markets Crowdfunding Deutsche Bank EU EU Directive European Securities and Markets Authority (ESMA) Financial Institutions Financial Regulatory Reform Foreign Banks Libor Middle East MiFID Netherlands Securities Shadow Banking Spain UK United States

Letter From America: Internal investigations – a stark reminder of the dangers of failing to implement strict protocols from the...

A recent ruling in long-running civil litigation against the Bank of China (“BOC”) in the United States District Court for the Southern District of New York provides a stark reminder of the dangers of failing to develop and...more

3/13/2015 - Attorney-Client Privilege Chief Compliance Officers Demand Letter Disclosure Discovery Functional Equivalent Internal Investigations International Litigation Legal Advice Privilege People's Bank of China Work Product Privilege

Exchange – International Newsletter: Issue 24 – October 2014

WELCOME - DLA Piper’s Financial Services International Regulatory team welcomes you to the twenty-fourth edition of ‘Exchange – International’ – an international newsletter designed to keep you informed of regulatory...more

11/5/2014 - Banks Compliance Enforcement Enforcement Actions EU Financial Conduct Authority (FCA) Financial Regulatory Reform Foreign Banks Leverage Ratio Liquidity Coverage Ratio Payday Loans Prudential Regulation Authority SEC UK

Ian Hannam - Much Needed Clarity On Market Abuse?

Last month the Upper Tribunal (the "Tribunal") rejected an appeal by Ian Hannam ("Hannam") against the Financial Services Authority's ("FSA") (predecessor to the Financial Conduct Authority) controversial 2012 decision that...more

7/2/2014 - Banks Enforcement Equity Markets Financial Markets FSA Insider Trading JPMorgan Chase UK

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