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Broker-Dealer Research: MiFID-Related "Hard Dollar" SEC Investment Adviser Status Relief to End in July 2023

The EU Markets in Financial Instruments Directive II (“MiFID II”), which came into effect on January 3, 2018, raised concerns that U.S. broker-dealers that would receive “hard dollars” for research from firms subject to MiFID...more

Managing Global Risks in Light of the Pandora Papers Leak

On October 3, the International Consortium of Investigative Journalists began reporting on millions of confidential documents relating to the financial activities of heads of state, international business leaders, and other...more

Anti-Money Laundering Implications for the Art Market in the UK

Introduction - The art market is characterised by high-value, portable items that can be bought and exchanged quickly and often confidentially. These features, which make the market inherently vulnerable to many types of...more

Employees Working Abroad

What are the legal issues for employers to consider? During the pandemic, many employers have been dealing with requests from employees to work abroad. With the move to remote working, employees have asked to work from...more

And So it Begins: What Recent Announcements Mean for the Future of LIBOR

On March 5, 2021, the ICE Benchmark Administration (the “IBA”) issued feedback that it had completed the consultation with LIBOR panel banks that it began in December 2020, and stated that it will be unable to publish certain...more

Operational Resilience and the Old Regulatory Two-Step

The UK financial services regulators speak loudly and often about their forward-looking approach to supervision, which – rather than looking back – seeks to focus on future risks to firms and consumers. Yet, you only have to...more

FCA Comments on UK Regulatory Expectations

On 17 March 2020, the UK Financial Conduct Authority (FCA) released information for regulated firms setting out its expectations of their responses to the COVID-19 pandemic. In broad terms, the FCA recognises that COVID-19...more

What happens in Vegas...

Non-financial misconduct and the UK Senior Managers and Certification Regimen - The old adage goes that, “What happens in Vegas, stays in Vegas.” But, does this really hold true in the UK financial services sector?...more

Financial Services: UK Regulators Shine a Spotlight on Cybersecurity and Technology Resilience

In a paper published last month,[i] the UK’s Financial Conduct Authority (“FCA”) set out various cybersecurity insights gleaned from the work of cyber coordination groups (“CCGs”) the regulator established in 2017. The...more

Avoiding the Cliff Edge - Immediate Steps for Firms and Groups with Financial Services Businesses in Europe Involving the UK

The UK is due to leave the European Union on March 29, 2019 (“Brexit”). Within the EEA, “passport rights” permit financial services institutions and funds authorised in any EEA Member State to conduct business cross border...more

A Rock or A Hard Place?

Reporting overseas enforcement action against Senior Managers to the Prudential Regulation Authority. On 7 November 2018, the Prudential Regulation Authority (“PRA”) issued two final notices against two individuals who had...more

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