Katie Stephen (UK)

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FCA commences criminal proceedings against five individuals for conspiracy to commit insider dealing and money laundering

Demonstrating its continuing focus on preventing, detecting and punishing market abuse, on 25th January 2023, the FCA announced that it has commenced criminal proceedings against five individuals, alleging that they conspired to commit offences of insider dealing between December 2019 and March 2021. In addition to insider dealing, the five individuals are charged with money … Continue Reading

Key points from the FCA’s most recent whistleblowing data

On 12 January 2023, the FCA published its whistleblowing data for the period July to September 2022 (Q3 2022). During this period, it received 291 new whistleblowing reports, containing 734 allegations. Most of the new reports were received via the online reporting form and the majority of whistleblowers provided their contact details, rather than seeking … Continue Reading

Takeaways from the FCA’s latest Skilled Person data

On 11 January 2023, the FCA published its latest quarterly Skilled Person data for the period July to October 2022 (Q2 2022/23). There were 11 reports commissioned during this time (following nine in the first quarter of the year). This is broadly in line with the number of reports commissioned last year (when 38 reports … Continue Reading

New briefing note: Governance – lessons for 2023 from regulatory enforcement

It is widely recognised that poor culture has been a major root cause of past conduct failures. To assist firms in this area, we have analysed some of the key FCA enforcement cases from the past year to draw out some learning points on governance, focusing on the following themes: roles and responsibilities; oversight; policies … Continue Reading

Spotlight on the Appointed Representatives regime: new FCA webpage on section 165 request for principal firms

On 8 December 2022, the FCA published a new webpage concerning the section 165 data request which it is sending to principal firms asking for more information about their appointed representatives. The webpage also includes responses to common questions. Principal firms have until 28 February 2023 to respond to the request.… Continue Reading

Spotlight on the Appointed Representatives regime: the new rules come into force

On 8 December 2022, the FCA’s new rules for the Appointed Representatives (AR) regime come into effect. In our previous briefing note covering the FCA’s Policy Statement on the updated AR regime we described 5 key areas of change and key steps for principal firms to consider when preparing for the new regime. As part … Continue Reading

New briefing note – Spotlight on the Appointed Representatives regime: what you should be doing now

We have published a new briefing note, Spotlight on the Appointed Representatives regime: what you should be doing now. This briefing note follows our first briefing note on the revised Appointed Representatives regime. In this briefing note, we have focussed on five key areas including where the FCA has revised its original consultation proposals. We … Continue Reading

Germany’s plan to legalise recreational cannabis poses anti-money laundering risks for UK business

Germany has become the latest country to agree on a plan to legalise recreational cannabis use among adults in a move that presents significant opportunities for investments in the EU’s largest economy. The Federal Cabinet has approved the key points paper for the legalisation, however a concrete draft law will only be presented once it … Continue Reading

FCA publishes Consultation Paper on sustainability disclosure requirements and investment labels

On 25 October 2022, the FCA published Consultation Paper CP22/20 on sustainability disclosure requirements (SDR) and investment labels. In the Consultation Paper, the FCA expresses that there are growing concerns that firms may be making exaggerated, misleading or unsubstantiated sustainability-related claims about their products; claims that don’t stand to closer scrutiny (so-called ‘greenwashing’). The FCA … Continue Reading

New briefing note: Key takeaways in relation to the FCA’s decision concerning Sir Christopher Gent

The FCA has recently fined Sir Christopher Gent, former non-executive Chairman of a global medical products and technologies company (the Company), £80,000 for the unlawful disclosure of inside information relating to the Company in contravention of the EU Market Abuse Regulation (EU MAR). The published decision contains a number of key takeaways in relation to … Continue Reading

Global webinar on 18 October 2022: Crypto regulatory investigations and enforcement – Key developments and practical steps for clients

Against the backdrop of recent turmoil in the crypto market and with increasing regulatory scrutiny in this area, understanding the regulators’ approach to investigations and enforcement and how best to avoid the common pitfalls is even more of a priority. In the latest webinar of our financial services crypto series, members of our global financial … Continue Reading

New Regulation Tomorrow Plus podcast – ESG: Key regulatory risks in the UK and US and practical steps to manage them

Our latest episode of Regulation Tomorrow Plus is now available to stream and download on ‘Apple podcasts‘ and ‘Spotify‘ In this podcast Katie Stephen, Co-Head of our Contentious Financial Services Group in London, and Celia Cohen, Co-Head of Financial Institutions in the United States, discuss the key regulatory risks for financial services firms in their … Continue Reading

FCA publishes financial promotions intervention data for Q2 2022

On 22 July 2022, the FCA published its financial promotions quarterly data for Q2 2022. Between April and June 2022, 374 promotions were amended or withdrawn following FCA intervention. Retail investments and retail lending were the sectors with the highest amend/ withdraw outcomes and in 58% of cases website or social media promotions were involved. … Continue Reading

Financial Ombudsman Service publishes new guidance for consumers and businesses regarding complaints that involve gambling-related harm

On 27 July 2022, the Financial Ombudsman service (FOS) announced that it has published two new webpages on the subject of complaints that involve gambling-related harm. One page is directed at consumers and the other is directed at businesses.  Key points on the page directed at businesses include that: The FOS has been contacted by … Continue Reading

Upper Tribunal considers the application of the MLRs to a cryptoasset exchange provider and comments on FCA procedures

Vladimir_Consulting_Limited_v_The_Financial_Conduct_Authority.pdf (publishing.service.gov.uk) Introduction The business of Vladimir Consulting Limited (VCL) involved trading in cryptocurrency such as bitcoin on peer-to-peer exchanges which provide a market place for sellers and buyers of cryptocurrency.  The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) were amended with effect from 10 January 2020 … Continue Reading

Commission Implementing Regulation laying down ITS for the application of MAR with regard to the format of insider lists and their updates

On 14 July 2022, there was published in the Official Journal of the EU (OJ) Commission Implementing Regulation (EU) 2022/1210 of 13 July 2022 laying down implementing technical standards for the application of the Market Abuse Regulation with regard to the format of insider lists and their updates. The Implementing Regulation enters into force on … Continue Reading

Spotlight on the Appointed Representatives regime: what is changing and how best to prepare

Ahead of the anticipated FCA policy statement and final rules on the changes to the Appointed Representatives regime, which were expected to be published in H1 2022, in this briefing paper we consider some of the steps that firms should be taking to prepare for the anticipated changes in the FCA’s final policy.… Continue Reading

FCA publishes decision notice regarding a fine of £5.8 million for Ghana International Bank Plc in connection with failings in its anti-money laundering controls over its correspondent banking activities

Anti-money laundering and the prevention of financial crime continues to be a key focus for the FCA, which reiterated in its most recent Business Plan its commitment to continue to use its enforcement powers to pursue those committing financial crime and their enablers.   According to the notice published on 23 June 2022, the FCA has … Continue Reading

ESG – Key regulatory risks for financial services firms in the UK and US and how to manage them

Investors are increasingly seeking sustainable financial products and ESG investing, traditional investing combined with sustainable or otherwise philanthropic aims, has seen huge growth in recent years. Regulated firms are also seeking to improve their own ESG performance more generally to build stronger relationships with their stakeholders, including those who use their services. Whilst the growing … Continue Reading

Recent developments signal a rise in sanctions enforcement risk for UK regulated firms

Whilst historically there have been relatively low levels of sanctions enforcement in the UK, in light of recent developments, in the coming months we expect to see more scrutiny in this area and increased enforcement activity in relation to sanctions breaches. In our latest briefing, first published on Thomson Reuters Regulatory Intelligence on 24th June … Continue Reading

Panel discussion: What should firms focus on in a fast-evolving risk landscape?

On July 12, 2022 our financial services and risk advisory teams will be holding a panel discussion event on the key financial crime issues facing financial services firms. The event, held at our offices in 3 More London Riverside, will include a keynote speech by Louise Stanway, chair of the Joint Money Laundering Steering Group. … Continue Reading

The FCA Business Plan: what does it mean from a governance perspective?

Earlier this year the Financial Conduct Authority (FCA) published its latest Business Plan. The Business Plan itself took a different form when compared to previous incarnations by having a shorter summary of priorities and planned activities and cross referring to other documents including the three-year strategy and the regulatory initiatives grid. Notwithstanding this, the Business … Continue Reading

Financial crime: What should firms focus on in a fast-evolving risk landscape?

On 12 July 2022, at 5pm to 7:30pm we are holding a financial crime panel event at our offices in 3 More London Riverside. Our financial regulation and risk advisory team will be joined by senior individuals from across the sector to discuss themes including anti-money laundering, sanctions, and market abuse, as well as the … Continue Reading
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