September 2019

On 25 September 2019, the Netherlands Authority for the Financial Markets (Autoriteit Financiële Markten, AFM) and the Dutch Central Bank (De Nederlandsche Bank, DNB) published their findings and best practices on the transitioning to alternative benchmarks.

The transitioning to alternative benchmarks follows from the EU Benchmarks Regulation (BMR). The

On 26 September 2019, the Decree implementing the Fifth Anti-Money Laundering Directive (5MLD) (Implementatiebesluit wijziging vierde anti-witwasrichtlijn, the Decree) was published for public consultation.

The Decree provides further details on the registration regime of virtual currency exchange platforms and custodian wallet providers that is introduced by the Act implementing 5MLD

On 27 September 2019, the FCA published Handbook Notice 69.

This Handbook Notice provides a summary of the changes the FCA board made to the Handbook on 26 September 2019. The relevant instruments are:

  • Handbook Administration (No 51) Instrument 2019;
  • Waiver Application Form (Amendments) Instrument 2019;
  • Reporting of Changes to the Management Body (FCA-Authorised

On 27 September 2019, the PRA published Policy Statement 20/19: strengthening individual accountability – resolution assessments and reporting amendments (PS20/19).

In PS20/19 the PRA sets out its final policy in respect of amendments to:

  • the prescribed responsibility (PR) for recovery plans and resolution packs contained in the Allocation of Responsibilities part

On 30 September 2019, the European Banking Authority (EBA) published its work programme for 2020. The programme is defined under six strategic areas:

  1. supporting the deployment of the risk reduction package and the implementation of the global standards in the EU;
  2. providing efficient methodologies and tools for supervisory convergence and stress testing;
  3. moving

On 27 September 2019, the Securities and Futures Commission (SFC) issued a consultation paper on the proposed regulatory regime for depositaries of SFC authorised collective investment schemes (the Proposals).

The Proposals, which are part of the SFC’s strategy to strengthen Hong Kong as an international, full service asset management centre and to enhance the regulation

The Volcker Rule prohibits “banking entities” (generally, insured banks and their affiliates, and non-US banks with US banking operations) from engaging in proprietary trading or sponsoring or investing in private equity funds. Regulations initially implementing the rule were adopted by the federal banking, commodities and securities regulators (Agencies) in 2014.

In 2018, the Agencies proposed

On 24 September 2019, the German Federal Financial Supervisory Authority (BaFin) published a draft guidance notice on dealing with sustainability risks for consultation (link; only available in German). BaFin expects supervised entities to also take into account environmental risks, social risks and risks arising from corporate governance (commonly referred to as

Our regulatory compliance consulting team are pleased to be sponsoring the 1LoD Summit, the leading event dedicated to front office risk and control functions within financial institutions, which takes place in London on November 21 this year.

The Summit will bring together over 200 senior practitioners from across the three lines of defence for