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Global Jurisdictions Adopt New Price Cap on Russian Petroleum Products - New Guidance Creates Additional Compliance Expectations

Effective February 5, 2023, the Price Cap Coalition (the Coalition), consisting of the G7 nations, the European Union (EU) and Australia, set a price cap of $45 per barrel for “Discount to Crude” petroleum products of Russian...more

Global Jurisdictions Implement Russian Oil Ban and Price Cap Policy

A ban on services related to the maritime transport of Russian-origin crude oil sold above a pre-determined price cap of $60 per barrel began on December 5, 2022, with a similar price cap ban related to other Russian-origin...more

UK Regulators Proposed Framework for Critical Third Parties

Financial services firms are increasingly reliant upon third-party companies to provide important services, ranging from cloud services and data analytics to machine learning and cash distribution. As these third parties...more

UK Update: ESG Data and Ratings Providers to Come Within Regulatory Perimeter

A key outcome of the UK’s Financial Conduct Authority’s (“FCA”) ESG strategy is the promotion of integrity within the ESG-labelled securities market, supported by the growth of effective service providers. To that end, in...more

AI and Algorithms in Financial Services - Future Areas of Focus

Artificial intelligence (AI) and algorithmic models are used extensively in the financial services sector across a broad range of business areas. Two-thirds of respondents to a survey conducted jointly by the UK’s Prudential...more

Greenwashing - a new regulatory risk

A key plank to the Government’s regulatory ESG agenda is simple: investment in sustainable projects and companies will assist the UK in meeting its environmental targets. Consumer interest appears to be aligned: there is a...more

Sanctions Update: Global Jurisdictions Announce a Series of Wide-Ranging Russia Sanctions

We wanted to share an update on Russia sanctions developments in the United States, United Kingdom, and European Union that occurred between March 24 and April 8, 2022. Following new reports of atrocities committed by the...more

Alternative Data in ESG: the regulatory risks

Alternative data is big business. Globally, buy-side firms spent $1.71 billion on it during 20201, over half of all hedge funds use it to make investment decisions, and it is increasingly used to validate the sustainability...more

Sanctions Update: Key Global Jurisdictions Continue to Announce New Measures Targeting Russian Elites and Strategic Industries

We wanted to share an update on Russia sanctions developments in the United Kingdom, European Union, and the United States that occurred between March 16 and 24. As summarized below, key global jurisdictions have continued to...more

United States and Allies Sanction Russia for Invading Ukraine

The United States, the European Union (EU), the United Kingdom (UK), and other allies and partners are implementing wide-ranging, novel sanctions and sweeping export controls against Russia in response to its invasion of...more

PRA messaging around firms’ operational resilience to cyber threat

In May the PRA’s Lyndon Nelson gave a speech about the development of the Regulator’s response to cyber risk. In his speech he...more

FCA Discussion Paper - Diversity, inclusion and its future impact on SMCR

During July the FCA made two announcements which demonstrate its continued focus on culture and diversity and their intersection with governance. In a Consultation Paper, it announced proposed changes to Listing Rules which...more

FCA Consultation Paper: Environmental disclosures and scrutiny of ‘Greenwashing’

On 22 June the FCA published two Consultation Papers setting out its proposals for climate-related disclosure obligations on the regulated sector. The first paper proposed extending the application of an existing Listing Rule...more

The risk of market abuse in algorithmic trading

In its May 2021 edition of Market Watch, the FCA described actions it took to address the impact which a firm’s trading algorithm was having in the market. Its concerns had been raised after the Regulator’s own internal...more

UK Government Tackles Greenwashing

Yesterday the UK’s Treasury Department announced the appointment of a Green Technical Advisory Group (GTAG), set up to advise and assist the UK Government in its development and implementation of a Green Taxonomy, aimed at...more

The SMCR, five years on

Five years ago, on 7 March 2016, the Senior Managers and Certification Regime (SMCR) came into force. At first it applied only to dual-regulated banks, those which are regulated both by the FCA and PRA. Originally...more

UK Supreme Court Ruling on Territorial Extent of SFO's Powers Impacts SFO’s Evidence Gathering Capabilities

On February 5, 2021 the Supreme Court handed down judgment in the case of R (on the application of KBR, Inc) v Director of the Serious Fraud Office, finding in favor of the Appellant, KBR, Inc (KBR). This high-profile case...more

UK Supreme Court Rules on Territorial Extent of SFO’s Powers

On February 5, 2021 the Supreme Court handed down judgment in the case of R (on the application of KBR, Inc) v Director of the Serious Fraud Office, finding in favor of the Appellant, KBR, Inc (KBR). This high-profile case...more

Can Kicking and Buck Passing: Reform of Corporate Criminal Liability

In January 2017, the UK Government issued a consultation paper calling for evidence on reforming corporate criminal liability for economic crime. Nearly four years later, on 3 November 2020, the Government’s response was...more

FCA’s statement on cannabis related businesses POCA application

On Friday 18 September the FCA issued a statement, setting out its approach to assessing applications for listing made by cannabis-related businesses. The statement is short and will be followed in due course by a...more

A powerful lesson in UK Data Protection law restrictions

The protections afforded by the GDPR and the UK’s 2019 Data Protection Act (‘DPA’) are not naturally associated with efforts to frustrate and restrict the use of the death penalty internationally. However, the recent Supreme...more

Cyber issues on the FCA’s radar

On 11 March 2020 the FCA published new research on cyber security. The research is the product of its Cyber Coordination Groups (CCGs) which were created through an FCA initiative in 2017. The CCGs bring together over 185...more

High Court Ruling May Impede Unexplained Wealth Order Use

On 8 April 2020 the NCA suffered its first setback in using Unexplained Wealth Orders (‘UWOs’). The Respondents in NCA v Baker successfully applied to discharge UWOs relating to three properties in London, all held by...more

Money laundering: Buyer secrecy in the London art market

The introduction of the Fifth Money Laundering Directive on the 10th January 2020 brought the art market into the fold of regulated sectors for anti-money laundering purposes. The new law, which amends the existing...more

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