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New UK Requirements for Payment Account Contract Terminations

HM Treasury has published a policy note and a draft statutory instrument—The Payment Services and Payment Accounts (Contract Terminations) (Amendment) Regulations 2024—on strengthening requirements in the Payment Services...more

Draft UK Legislation to Address Push Payment Fraud

HM Treasury has published a policy note and a draft statutory instrument—The Payment Services (Amendment) Regulations 2024—on a risk-based approach to payments to mitigate against authorized push payment fraud. HM Treasury...more

The U.K.’s New Regime for Critical Third Party Supervision

Regulated financial services institutions and financial market infrastructure (FMI) providers often rely on third parties who provide significant services to them behind the scenes, including “cloud” services and IT services...more

UK Regulators Confirm Bonus Cap Being Scrapped

The U.K. Prudential Regulation Authority and Financial Conduct Authority have published a joint policy statement confirming the "bonus cap" will be removed. Banks are subject to compensation requirements for staff who have a...more

Basel Committee Report on 2023 Banking Turmoil

The Basel Committee on Banking Supervision published a press release in early October in which it announced...more

UK Financial Conduct Authority Consults on Securitization Rules

The U.K. Financial Conduct Authority is consulting on its proposed rules for securitization markets, which will replace many of the firm-facing requirements under the existing U.K. Securitization Regulation. The U.K....more

UK Regulator Proposes Framework for a Consolidated Tape

On July 5, 2023, the U.K. Financial Conduct Authority launched a consultation on a proposed U.K. consolidated tape for bonds. MiFID II introduced requirements for a "consolidated tape" for transactions in equity and...more

First Commencement Regulations Under UK Financial Services and Markets Act 2023

The Financial Services and Markets Act 2023 (Commencement No. 1) Regulations 2023 were made on July 10, 2023 and will bring into force provisions under the Financial Services and Markets Act 2023 from either July 11, 2023,...more

UK Investment Research Review Signifies Further EU-UK Divergence on Unbundling Research Rules

The report and recommendations of the UK Investment Research Review were published on July 10, 2023. The recommendations have been accepted by the government and the Financial Conduct Authority has committed to prioritizing...more

UK Financial Conduct Authority Seeks Comment on Draft Rule Review Framework

The U.K. Financial Conduct Authority launched a consultation on July 14, 2023, on its proposed Rule Review Framework. The Financial Services and Markets Act 2023 transfers responsibility for making detailed rules to the...more

UK Financial Services and Markets Act 2023

Following rigorous debate in Parliament, the U.K.'s latest Financial Services and Markets Act (FSM Act) received royal assent on June 29, 2023. The FSM Act significantly changes the U.K.'s regulatory framework for financial...more

UK Government and Regulators Consult on Revised UK Prospectus Regime

HM Treasury has published a near-final draft statutory instrument and related Policy Note setting out its proposed reforms to the U.K. prospectus regime. The U.K. Financial Conduct Authority has also published a series of six...more

EU and UK Sign Memorandum of Understanding on Financial Services Cooperation

On June 27, 2023, the EU and U.K. signed a Memorandum of Understanding on Financial Services Cooperation, a high-level agreement on future cooperation in the regulation of financial services. The MoU provides for - -...more

UK Government Publishes Edinburgh Reforms for Financial Services

The U.K. Government announced on 9 December 2022 a series of initiatives, billed as the Edinburgh Reforms, to reform the laws for the U.K. financial services sector. In this note, we consider these reforms in detail and what...more

UK Government Publishes Brexit Freedoms Bill Setting Deadline for Revocation of EU Law

The U.K. Government has published the Retained EU Law (Revocation and Reform) Bill, known as the Brexit Freedoms Bill, which aims to repeal or assimilate retained EU law and abolish the principle of the supremacy of EU law in...more

Sanctions Round Up: Second Quarter 2022

With the war in Ukraine raging on, the U.S. continued to escalate its sanctions response against Russia. The U.S. announced extensive trade and investment bans that prohibit U.S. persons from making any “new investment” in...more

Access to Cash Designation Measures Confirmed

HM Treasury has published a summary of responses it received to its consultation on protecting access to cash across the U.K. In the response, HM Treasury confirms that it will be proceeding with the proposal to designate...more

European Commission Consults on Potential Digital Euro

The European Commission has launched a targeted consultation on a possible digital euro. The EU is considering introducing a digital euro for retail payments, which would be available alongside cash. A decision has not yet...more

Sanctions Roundup: Third Quarter 2021

The Biden Administration this quarter announced fewer targeted sanctions, but issued several “whole of government” advisories regarding sanctions risks associated with China-related business dealings, as well as virtual...more

Regulatory Challenges For Financial Institutions Operating Across Multiple Jurisdictions

Financial institutions operating across multiple jurisdictions face a myriad of regulatory challenges, including those arising from differences between regulators in: (a) the substance of their laws, regulations and...more

Specific Regulatory and Governance Challenges of European Banks Operating Across Multiple Jurisdictions

European banks operating across multiple jurisdictions face a set of specific regulatory challenges, including...more

COVID-19: FCA Announcement on Key Workers in Financial Services and other issues

The FCA has published a series of measures and regulatory guidance on how financial services firms should deal with the coronavirus (COVID-19) pandemic. In our previous client notes, “Planning in a Time of Pandemic:...more

COVID-19: Bank of England Announces Policy Measures for Financial Market Participants

The Bank of England (BOE) has announced a series of policy measures designed to help U.K. financial market participants deal with the effects of the coronavirus (COVID-19) pandemic. The latest measures, announced on 20 March...more

Planning in a Time of Pandemic: Considerations for Regulated Financial Institutions in the US, EU and UK

The economic and operational stresses caused by the Novel Coronavirus (COVID-19) are highlighting the need for regulated financial institutions to formulate responses to address significant business disruptions (SBDs) and to...more

The UK’s Expanded Senior Managers and Certification Regime: Key Issues and Action Plan for Brokers, Advisers and Asset Managers

The expanded Senior Managers and Certification Regime (SM&CR), which comes into force on December 9, 2019, extends the framework regulating individuals charged with running certain financial institutions. The Banking SM&CR,...more

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