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Widening the sanctions net in uncertain times: latest developments in the U.S., EU, and U.K.'s sanctions targeting Russia

In the context of the third anniversary of Russia’s invasion of Ukraine, the U.S., EU, and U.K. continue to implement new measures to stifle Russia’s war efforts. The Biden administration continued to escalate sanctions...more

The UK’s new lighter-touch short selling regime

The U.K. Short Selling Regulations 2025 (“SSR 2025”) have been made. This paves the way for the U.K. to repeal and replace the regime implemented while the U.K. was in the European Union and then onshored into U.K. domestic...more

Eurozone banks: get ready for the new IPR obligations!

The new Regulation (EU) 2024/886 on instant credit transfers in euros (IPR), amending the so-called SEPA Regulation, is here, and it’s time to gear up! Effective from April 8, 2024, the first set of obligations kicks in on...more

Instant Payments Regulation - January 2025

In order to increase the use of instant credit transfers in euros at Union level, the EU legislators have amended Regulation (EU) No 260/2012 establishing technical and business requirements for credit transfers and direct...more

UK allows bundled payments for third-party research and trading commissions

From 1 August 2024, the UK changed its rules on how payments are made for investment research. UK firms may now use bundled payments for third-party research and trading commissions, subject to certain requirements being...more

On the existence of a pan-European reverse solicitation regime under MIFID II, and importance on a 'Hard' BREXIT

This client memorandum concerns a highly technical point of considerable practical importance. It challenges aspects of the received wisdom that, for post-Brexit cross-border investment business conducted from the U.K....more

UK Proposes Design of the Future Entity for UK Open Banking

On April 19, 2024, the U.K.'s Joint Regulatory Oversight Committee published proposals on the design of the future entity for UK Open Banking. The JROC is composed of the Financial Conduct Authority, the Payment Systems...more

UK Prudential Regulator Granted Power to Disapply Rules

On April 18, 2024, the Financial Services and Markets Act 2000 (Disapplication or Modification of Financial Regulator Rules in Individual Cases) Regulations 2024 were made. The Financial Services and Markets Act of 2023...more

UK Approach to Critical Third-Party Supplier Designation Published

The Financial Services and Markets Act 2023 established a framework for the regulation of third parties who provide significant services to financial institutions, giving HM Treasury power to designate an entity as a...more

UK Regulators Consult on Digital Securities Sandbox

On April 3, 2024, the Bank of England and U.K. Financial Conduct Authority published a joint consultation paper on proposed rules for the incoming digital securities sandbox. The Financial Services and Markets Act 2023...more

Bank of England Consults on Revisions to Statement of Policy on Enforcement

On March 28, 2024, the Bank of England published a consultation paper on revisions to its Statement of Policy and Procedure on its approach to enforcement, published in January 2024, to reflect enhancements to the BoE's...more

HM Treasury Publishes Policy Statement on Next Phase of Smarter Financial Services Regulatory Framework

On March 21, 2024, HM Treasury published a paper on the next phase of its Smarter Financial Services Regulatory Framework, the U.K.'s program of post-Brexit regulatory reforms for financial services. The original policy...more

UK Conduct Authority Consults on New Approach to Enforcement and Publication of Enforcement Investigations

On February 27, 2024, the U.K. Financial Conduct Authority published a consultation on revisions to its Enforcement Guide, setting out proposals which aim to simplify the guidance and increase transparency around the FCA's...more

UK Conduct Regulator Proposes Payment Optionality for Investment Research

The U.K. Financial Conduct Authority has opened a consultation setting out proposals for allowing firms to use joint (bundled) payments for third-party research and execution services, subject to certain requirements being...more

UK To Move to T+1 Settlement by Latest End 2027

The recently published Accelerated Settlement Taskforce report makes several recommendations to the U.K. government for moving to faster settlement of securities trades in the U.K. The main recommendation is that the U.K....more

Court of Justice of the European Union Annuls Sanctions Measures

The Court of Justice of the European Union has decided that the reasons for the EU sanctions measures designating Mr Fridman and Mr Aven (two of the shareholders of LetterOne) were not sufficiently substantiated and their...more

4/11/2024  /  AML/CFT , EU , Insider Trading , Sanctions , UK

Law Commission Publishes Consultation on Digital Assets as Personal Property

The Law Commission, a U.K. body which makes suggestions for legislative reform, is consulting on wording for a possible draft piece of legislation establishing a third category of personal property that would encompass...more

Law Commission Publishes Call for Evidence on Digital Assets and Electronic Trade Documents in Private International Law

The Law Commission, a U.K. body which makes suggestions for legislative reform, has published a call for evidence on the operation of English private international law (conflicts of law rules) in relation to digital assets...more

UK Public Offers and Admissions to Trading Regulations Published

On January 29, 2024, the Public Offers and Admissions to Trading Regulations 2024 (SI 2024/105) were published. The Regulations implement the new Public Offers and Admission to Trading Regime, part of the new designated...more

UK Fifth Commencement Regulations Under the Financial Services and Markets Act 2023 Published

The Fifth Commencement Regulations - the Financial Services and Markets Act 2023 (Commencement No. 5) Regulations 2024 (SI 2024/250)- under the Financial Services and Markets Act 2023 were made on February 29, 2024. One of...more

UK Securitisation Regulations Published

The Securitisation Regulations 2024 (SI 2024/102) were made on January 29, 2024, and will come into force for the most part when the Securitisation Regulation 2017 is revoked. This is part of HM Treasury's Smarter Regulatory...more

EMIR 3 and Clearing in the EU

Of the many aims of the EU’s latest revisions to the European Market Infrastructure Regulation (EMIR), the most controversial and intensely debated is mandating clearing at EU CCPs. Since Brexit, the EU has been concerned...more

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