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The FCA’s Approach to Non-Financial Misconduct - A Further Twist

The FCA stated that the perpetrator’s character is key to non-financial misconduct investigations, which suggests a mismatch with recent case law. In last year’s Frensham case, the Upper Tribunal considered how relevant...more

The FCA’s Approach to Non-Financial Misconduct - Latest Cases and Observations

The FCA has long since regarded non-financial misconduct as potentially relevant to the integrity and reputation elements of a regulated individual’s fitness and propriety. While not formally defined, non-financial misconduct...more

HM Treasury Initiates Post-Brexit Review of the UK’s AML and CTF Regime

Recent publications come in light of UK’s “greater autonomy” in setting AML and CTF regulations following Brexit. Background to the review - On 22 July 2021, HM Treasury published both a Call for Evidence on a review...more

FCA Proposes New Consumer Duty

The FCA is proposing to set higher expectations for firms operating in retail markets. On 14 May 2021, the FCA published a Consultation Paper (CP21/13) on introducing a new Consumer Duty....more

High Court Clarifies Consequences of Late Part 36 Offer Acceptance

The decision highlights a potential tactical advantage of late acceptance in certain circumstances. In Roxanne Pallett v. MGN Limited, the High Court held that the usual costs consequences of accepting a Part 36 offer do not...more

Landmark Judgment Rules in Favour of Rothesay Life Plc

Court of Appeal sets out correct approach to transfer of long-term Insurance. Latham & Watkins has won an appeal on behalf of Rothesay Life Plc (Rothesay) in an unprecedented challenge to the High Court’s refusal to...more

UK Scores Highly on Anti-Money Laundering Review

FATF has published its highly anticipated report on the effectiveness of the UK’s anti-money laundering and counter-terrorist financing measures. On 7 December 2018, the Financial Action Task Force (FATF) published its...more

Internal Investigations Protected By Privilege Once More?

English Court of Appeal Reaffirms Privilege Over Internal Investigation Documents Prepared in Contemplation of Litigation - In a much anticipated decision, the Court of Appeal has reaffirmed legal privilege protection for...more

EU Responds to the Snap-Back of US Sanctions Against Iran: Between a Rock and a Hard Place

In light of the EU’s recent amendments to its long-standing blocking measure, EU operators will need to weigh the consequences of failing to comply with their contradicting obligations under US and EU law. How has the EU...more

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