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A New Safeguarding Regime: Five Points for Payments and E-money Firms

For any UK fintech business involved with payments of electronic money (e-money) and any (experienced) investor in these businesses, safeguarding client funds is a key regulatory issue....more

ELTIF 2.0 RTS: Second Time Lucky and A Positive Step Forward on Liquidity and Redemptions

In our previous alerts (here and here), we noted critical feedback that the European Commission (Commission) gave to the European Securities and Markets Authority (ESMA) on its December 2023 draft Regulatory Technical...more

A New Sustainable Investment Framework for the EU? ESMA’s Latest Opinion

Those who have had to navigate and consider the EU Sustainable Finance Disclosure Regulation (SFDR) have faced its challenges and noted its deficiencies. Specifically, these have included data gaps, the SFDR’s use as a...more

Paying for Buy-Side Investment Research: Will the FCA’s Third Way Ease the US-UK Divide?

On 10 April 2024, the Financial Conduct Authority (FCA) published a Consultation Paper on payment optionality for investment research (CP24/7). CP24/7 followed the UK Investment Research Review, in which recommendations were...more

Forward to the Past: HNW and Sophisticated Exemptions for UK Investors

On 6 March 2024, following the Chancellor’s budget statement, the Financial Services and Markets Act 2000 (Financial Promotion) (Amendment and Transitional Provision) Order 2024 (SI 2024/301) (the March Amendment) was...more

UK HNW and Sophisticated Investor Exemptions: More Financial Promotion Changes

We wrote on the impact of changes to the financial promotion rules that came into effect earlier this year. On 7 November 2023, the UK Government published the proposed changes to the Financial Promotion Order 2005 (FPO). The...more

Irreconcilable? The EU’s Article 8 and “Anti-ESG” Investor Demands

As the market continues to evolve with the dynamics of sustainable finance legislation, managers are often facing challenges in how to best navigate competing investor demand and sentiment on environmental, social, and...more

First Reminder: Two Months Until New UK Crypto Marketing Rules Take Effect

Starting 8 October 2023, anyone — including a crypto issuer or business based outside the UK — who makes a cryptoasset or service available to an investor or user in the UK will need to consider the UK ‘financial promotion...more

The Remaining New Financial Promotion Rules for UK Private Fund Managers: Less Than a Month Away

In a previous client alert (New Risk Warning Rules for UK Private Fund Managers: Action Required), we discussed the rules governing the main risk warnings for financial promotions of high-risk investments, which came into...more

New Risk Warning Rules For UK Private Fund Managers: Action Required

In our previous client alert, we mentioned the need for managers to review new rules contained in PS22/10, published by the UK Financial Conduct Authority (FCA). The rules governing the main risk warnings for financial...more

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