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Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more
Key developments in May 2024: ESG: The Financial Conduct Authority (“FCA”) updated its webpage on the sustainability disclosure requirements (“SDR”) and investments labelling regime. Among other things, the webpage has been...more
In our previous alert “Acquiring or Investing in EU Crypto-Asset Businesses: MiCA’s Impact,” we discussed the impact of the European Union (EU) Markets in Crypto-Assets Regulation (MiCA) on the acquisition or investment in EU...more
Welcome to the UK Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation....more
Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
In our recent article (available here) we reported that the Guernsey Financial Services Commission (the "GFSC") had been granted leave to appeal to the Court of Appeal. The GFSC obtained leave to appeal on the basis of a...more
Bank mergers and acquisitions are becoming a regular part of life in the banking industry, especially for smaller and medium-sized organizations. They provide significant opportunities for institutions to expand their...more
This latest edition of the regulatory initiatives paper sets out at a high level the core regulatory issues that are likely to impact private fund managers in the coming months, including an overview of the key actions needed...more
The advance of the regulation of crypto-assets and crypto-related service providers has been piecemeal in the U.K. The latest round of changes took place in the Money Laundering Regulations 2017 (MLR) on 1 September...more
Pension scheme (and other) trustees must register certain trusts with HMRC by 1 September 2022, following the implementation in the UK of the Fifth Money Laundering Directive (5MLD). While the new requirements do not apply to...more
In the early hours of 15 March 2022, following a wait of almost five years, the UK Parliament introduced into law the Economic Crime (Transparency and Enforcement) Act (the "Act"). The Act was fast-tracked at an...more
The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more
Regulators propose new regulations for virtual asset exchanges and enhanced customer identity verification requirements, and launch an innovative commercial data interchange. This blog post summarises key regulatory...more
The first cryptocurrency, Bitcoin, is still the most well-known application of blockchain. However, this technology has since rapidly evolved and expanded in many other areas. The initial hope with Bitcoin was to make both...more
On October 8, 2020, Attorney General William Barr announced the release of a Cryptocurrency Enforcement Framework produced by the Department of Justice (DOJ) Cyber-Digital Task Force. The 83-page framework is intended to help...more
Last week, the House Financial Services Committee Subcommittee on National Security, International Development and Monetary Policy held a hearing on transnational trafficking networks and illicit finances. Titled “The...more
On 10 January 2020 the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (the “2019 Regulations”) came into force in the UK, implementing the EU’s fifth Money Laundering Directive (“MLD5”) and amending the...more
The Financial Conduct Authority (FCA) has released final guidance on cryptoassets in a policy statement that includes feedback from their January consultation paper. It is important to note that the policy statement is of a...more
In June 2018, the Abu Dhabi Global Market (ADGM) Financial Services Regulatory Authority (FSRA) unveiled a dedicated cryptoasset regulatory framework by way of various amendments to the FSRA’s core regulations – the Financial...more
What do people see when they look at a piece of fine art—such as a painting by Cezanne, a sculpture by Giacometti, or a three-dimensional combine by Rauschenberg? To a great extent, it depends on who’s doing the looking. An...more
The Abu Dhabi Global Market’s Guidance clarifies and expands FSRA expectations for OCAB Framework license holders. In June 2018, the Abu Dhabi Global Market (ADGM) Financial Services Regulatory Authority (FSRA) unveiled a...more
These topics are attracting particular attention because they are either at a key stage in the regulatory change or implementation cycle, or because uncertainty and inconsistency in their recent implementation means that they...more
Last month, the Financial Crimes Enforcement Network (FinCEN) released new guidance to clarify when the Bank Secrecy Act (BSA) will apply to businesses that involve cryptocurrencies (what FinCEN refers to as convertible...more
The Monday afternoon keynote speech by Hui Chen at Compliance Week 2019 was one of the most significant speeches I have heard recently. I thought Chen’s keynote speech summed up where compliance has been and where it is going...more