Compliance: Delivered – Interim Compliance Officer and resource management solutions
Finding, hiring and on-boarding compliance staff with the right expertise and level of experience is difficult. We know – we’ve hired many compliance professionals ourselves over the past 20 years. Additionally, you may not need, or have budget for, full time and/or permanent hires – you just know you need someone to fill a gap […]
FCA’s Data Led Enforcement – Enforcing Minimum Standards
Data Led Enforcement – Enforcing Minimum Standards When thinking of enforcement action by financial regulators it is the images of insider dealers being led away in handcuffs or the headlines announcing large fines for failure to store electronic communications that often spring to mind, but the FCA’s enforcement data, published last month, offers a different […]
Back to the Future – Part III – Joint Payments (fka Bundled Commissions)
As referenced in our alert from May, the FCA has now released Policy Statement PS24/9 Payment Optionality for Investment Research. The Policy Statement and release of the final rules confirms that asset management firms may buy investment research using joint payments for third-party research and execution services, provided that they meet the new FCA requirements. […]
Criminal Background Checks for Controllers
July 2024 Dear Clients and Friends, Criminal Background Checks on Controllers A brief but potentially important update from the FCA…you may have missed it but in their June quarterly consultation paper the FCA proposed plans to require proposed controllers of regulated firms to complete criminal background checks. If adopted, from January 2025, new controllers, either […]
Year of the Election and Political Donations
June 2024 Dear Clients and Friends, Political Donations – What is the issue? We are all aware that 2024 is the year of the election – globally more voters than ever in history will head to the polls. The UK vote in July, France announced a snap election last week and the US cast their […]
Market Surveillance – Lessons from Failures
May 2024, Dear clients and friends, A recent market watch newsletter (Market Watch 79) saw the FCA return to the topic of market abuse surveillance system and their effective use. What were we reminded of? In brief, a firm must have effective arrangements to detect and report suspicious activity. It is up to each firm […]
Bundled Commissions, FCA Sustainabilty Disclosures and more
Dear clients and friends A mix of news for you in this alert, from bundled commissions to the FCA’s SDR and labelling regime to the proposed updates to the FCA Financial Crime Guide and finally a few statistics from the results of the FCA’s financial resilience survey. Back to the Future – Part II – […]
FCA Alternatives Supervisory Strategy
Dear clients and friends, On 1st March 2024 the FCA published their interim update on its asset management and alternatives supervisory strategy. In this alert we highlight what we believe to be the more applicable and impactful topics for our clients and contacts. Governance The FCA’s first key point is to highlight, not unsurprisingly, that […]
UK and US short selling regimes – a short note on the changes.
The FCA recently amended their short selling webpage with numerous updates related to the UK short selling regime. As you may recall – and as we referenced in a communication back in July – the Treasury had previously proposed significant changes to the UK short selling regime, and we now have more clarity – if […]
ICARAs – the FCA’s observations (and therefore expectations)
In late November the FCA published their IFPR implementation observations concluding report which details the regulator’s findings on how firms are implementing the ICARA under IFPR. This most recent report builds on the FCA’s multi-firm review, which was published in February, and outlines good and poor practices, which should assist firms in identifying where their […]
