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FCA Updates – ‘Assertive’ Supervision, and About Turns

We are now starting to see a real shift in the UK Financial Conduct Authority’s (FCA) Enforcement strategy following a changing of the guard in 2023, which brought in Therese Chambers and Steve Smart to be Joint Executive...more

Preparing Organisations for the New UK Failure to Prevent Fraud Offence

Fraud is the most common offence in the UK, amounting to 41% of all crime.  On 26 October 2023, the UK’s long-awaited Economic Crime and Corporate Transparency Act 20232  (the Act) received Royal Assent, setting out...more

FCA Consults on Publishing Information about the Opening and Progress of Investigations

The U.K. Financial Conduct Authority has published its proposed approach to publishing information about the opening and progress of investigations.1  The proposals represent a marked departure from the FCA’s current practice...more

FCA and PRA Publish Consultation on New Rules relating to Non-Financial Misconduct

Key Points - Following a joint Discussion Paper in 2021 issued by the FCA and the PRA, both regulators have now issued Consultation Papers proposing new rules and guidance in relation to diversity and inclusion in the...more

FCA and PRA Publish Consultation on New Rules Relating to Diversity and Inclusion

Key Points - -Following a joint Discussion Paper in 2021 issued by the UK Financial Conduct Authority (FCA) and the UK Prudential Regulation Authority (PRA), both regulators have now issued Consultation Papers proposing new...more

The FCA Pledges to Improve Its Whistleblowing Framework

Overview - A survey conducted by the United Kingdom Financial Conduct Authority (FCA) in early 2022, but published only in 2023, has revealed the stark reality that the regulator is not doing enough for whistleblowers. 15...more

The SEC and FCA: A Pond, 362 Investigations and $4 Billion in Penalties Apart

No financial services firm or professional welcomes an investigation by a regulator, let alone enforcement action. Each investigation proceeds differently depending on the target of the investigation, the subject matter and...more

The Bank of England and Prudential Regulation Authority Consult on Approach to Enforcement

Key Points - The UK’s prudential and banking regulator has published a Consultation Paper proposing changes to its enforcement policies and procedures. The consultation runs until 4 August 2023. ...more

EU Reaches Provisional Agreement on AIFMD II

On July 20, 2023, the Council of the European Union (EU) announced1 a provisional agreement had been reached with the EU Parliament on the amendments to the Alternative Investment Fund Managers Directive (AIFMD) – commonly...more

Beginning of the End of EU Law in the UK?

The Financial Services and Markets Act 2023 (“FSMA 2023”) marks a watershed moment in British legislative history. FSMA 2023 introduces sweeping changes to the financial services regulatory infrastructure and will have a...more

The UK regulator awakens from its COVID-19 slumber – A review of FCA enforcement in 2022 and a look ahead to 2023

In September 2021, following the London Capital & Finance ‘mini-bonds’ scandal, the Treasury Select Committee of the UK House of Commons asked for a more “proactive” Financial Conduct Authority (FCA) that is “decisive” in its...more

New FCA Principle 12: Consumer Duty

Key Point - The FCA is introducing a new Principle for Businesses, namely Principle 12: “A firm must act to deliver good outcomes for retail customers.” Firms will need to assess and evidence how they are acting to...more

In Principle: Key Things Authorised Firms Need to Know for 2022

The SFDR and the Taxonomy Regulation: Key Developments and What Firms Can Expect in the Coming Year - Almost a year on from the date on which the European Union’s Sustainable Finance Disclosure Regulation (SFDR) came into...more

UK Financial Conduct Authority Consults on Amending Decision-Making Process

Key Points - The FCA is consulting on changing its internal decision-making process. If the FCA’s proposals are made into final rules, certain decisions which are currently taken by the quasi-independent RDC will...more

Upper Tribunal Clarifies FCA’s Powers Regarding Non-Financial Misconduct by Regulated Individuals

Key Points - The Upper Tribunal has issued the first ruling in relation to the FCA’s decision to sanction an individual following a conviction for a criminal offence which did not involve dishonesty. The FCA had sought...more

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