Sam Millar

Sam Millar

DLA Piper

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Latest Publications


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 ESMA EU EURIBOR European Commission 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/CFT Australia Banks Basel III Capital Markets Crowdfunding Deutsche Bank ESMA EU EU Directive 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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