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The FCA, PRA, and Bank of England have published their finalised critical third party (CTP) rules (and accompanying guidance) in PS24/16 Operational resilience: Critical third parties to the UK financial sector....more
The new regime will take effect on 1 January 2025, but will not diminish the responsibilities of financial services firms relying on the services of critical third parties....more
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
The announcement in 2021 of the intention to implement new rules directly targeting the types of tech service provider relied on by most financial institutions may be a necessary corrective given the heavy market...more
New High Court case considers nature and scope of the Quincecare duty - In June, the Court of Appeal expanded the scope of a bank’s duty of care to protect its customers from fraud to encompass instructions by those other...more
On 5 December 2019 the Bank of England (Bank), UK Prudential Regulation Authority (PRA) and UK Financial Conduct Authority (FCA) published coordinated consultation papers and policy on new requirements to strengthen...more