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Financial Conduct Authority (FCA) Internal Controls United Kingdom

Thomas Fox - Compliance Evangelist

Internal Controls and Humans in the Loop: Lessons from Citigroup’s $126 Million Mistake

In the world of compliance and ethics, the Citigroup internal control debacle serves as a glaring reminder of the critical importance of robust, well-designed, functioning and effective internal controls. The U.K. Financial...more

WilmerHale

FCA - Financial Crime Focus Areas for 2024

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“Stopping financial crime requires a collective effort...we will be more proactive in our supervision. Where we detect harm or UK-wide financial crime vulnerabilities, we will continue to share intelligence with our partners...more

BCLP

UK Corporate Briefing - March 2024

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Welcome to the Corporate Briefing, where we review the latest developments in UK corporate law that you need to know about. In this month’s issue, we discuss...more

Latham & Watkins LLP

In Practice: Preparing for a New UK Securitisation Framework

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The start of 2024 heralds the rollout of a new suite of rules for securitisation in the UK, which once adopted, will replace the existing on-shored UK Securitisation Regulation (the “UKSR”). Originally published in...more

BCLP

Personal Matters - How will the risks to firms from individuals’ behaviour increase in 2024?

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Financial regulators in the UK have been interested for some years in the question of how personal behaviour can affect the risk profile of a financial institution. A recent SEC case suggests that US regulators may now be...more

A&O Shearman

New UK Corporate Governance Code: carefully choreographed

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Today saw the publication by the Financial Reporting Council (FRC) of its revised corporate governance code (the Code). Whilst the updated Code contains a limited set of targeted changes, as opposed to a broader wholesale...more

Latham & Watkins LLP

Recent Developments for UK PLCs - May Edition

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This edition covers the FCA’s priorities for the next 12 months, the ICGN statement on post-pandemic AGM practices, Takeover Code changes affecting competitive bids, and a proposed new corporate “failure to prevent fraud”...more

Goodwin

The FCA’s 2023/24 Priorities for UK Payments: Firms and Investors, Take Note

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On March 16, 2003, the UK Financial Conduct Authority (FCA) published its letter Portfolio Letter: FCA priorities for payments firms to the CEOs of UK Payment Institutions (PIs), Electronic Money Institutions (EMIs), and...more

BCLP

FCA publishes Primary Market Bulletin No. 42 and Market Watch 71

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The FCA has published Primary Market Bulletin No.42 which, amongst other things: (i) discusses themes from the FCA’s enquiries into unlawful disclosure of inside information (ii) highlights the relationship between the...more

Latham & Watkins LLP

FCA Issues Final Notice to Former Banking CEO Over Anti-Money Laundering Failures

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The case provides instructive practical examples of the “reasonable steps” companies can take according to the FCA and a reminder of the FCA’s cultural expectations of CEOs. On 16 November 2022, the FCA issued a final...more

BCLP

Banking Bites - July 2022

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Welcome to Banking Bites! This is our short summary flagging key developments in the UK that we hope will inform your activities in your market. This edition covers...more

BCLP

Government proposals to reform corporate reporting and governance

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The Government has published its long-awaited White Paper on the reform of the UK’s audit, corporate reporting and corporate governance system including a package of measures aimed at improving the UK’s audit, corporate...more

Mitratech Holdings, Inc

With Great Power Comes Great Responsibility – How to Deal With the Growth in Accountability and Responsibility Regulations

With potential large fines and prohibitions, managers will have ever-greater pressures upon them to ensure their teams meet required compliance standards and show that effective controls have been put in place to prevent...more

Proskauer Rose LLP

UK Financial Conduct Authority Identifies Significant Shortcomings in Firms Operating Appointed Representative Platforms

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On 20 May 2019, the UK Financial Conduct Authority ("FCA") published its findings of its multi-firm review into the supervision by principal firms of their appointed representatives ("ARs") operating in the investment...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

BCLP

FCA Enforcement Focus: Transaction Reporting

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In what is a key FCA enforcement risk area, we study the common pitfalls firms encounter and the lessons firms can draw from the recent enforcement cases. Why is transaction reporting a key FCA priority? The transaction...more

A&O Shearman

UK Regulator Sets Out Strategy to Manage Risk of Harm from Wholesale Brokers

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The Financial Conduct Authority has published a "Dear CEO" letter addressed to wholesale market broking firms highlighting its view of the key risks of harm that such brokerage firms pose for their clients and markets and the...more

Latham & Watkins LLP

FCA Fires Warning Shot to Brokers in Wholesale Markets

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Latest Dear CEO letter from the regulator includes strong criticism and warns that firms need to improve to meet regulatory expectations. Key Points: ..FCA supervisory work during the next two years will focus on four...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on NFA Compliance Updates for CPOs and Swaps, and Brexit and No-Deal...

BROKER-DEALER - FINRA Issues Report on Examination Findings - This month, the Financial Industry Regulatory Authority (FINRA) issued a report summarizing various findings from recent examinations of its member firms...more

A&O Shearman

UK Brokerage Firm Fined for Inadequate Controls Against Potential Market Abuse

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The U.K. Financial Conduct Authority has published a Decision Notice (dated June 7, 2018) imposing a fine of £409,300 on a U.K. brokerage firm for failure to take reasonable care to organize and control its affairs...more

Latham & Watkins LLP

FCA Proposes New Guidance on Financial Crime Systems and Controls

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The FCA is proposing to add a new chapter on insider dealing and market manipulation to its Financial Crime Guide. Key Points: ..The FCA proposes to add a new Chapter 8 to Part 1 of its Financial Crime Guide, outlining...more

Dorsey & Whitney LLP

Barclays Is Sanctioned By The FCA and The SEC

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Barclays took a double hit from regulators yesterday. First the Financial Conduct Authority in the UK fined Barclays Bank Plc, about £38 million for putting £16.5 billion of client assets at risk. Then the SEC imposed a $15...more

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