Rebecca Dulieu

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New briefing note: Financial Reporting Council’s 3-Year Plan – What it means for supervisory intervention and enforcement

Following publication of the Financial Reporting Council’s (FRC) latest 3-Year Plan for 2023-26, in our latest briefing we consider the potential impact of FRC stated enforcement strategy and likely increased ‘constructive engagement’ and enforcement activity that companies can expect to see over the coming period, with additional experienced resource within the FRC focusing on issues … Continue Reading

Whistleblowing – latest FCA quarterly data and key practical steps to manage reports

Whistleblowing remains a key tool for the Financial Conduct Authority (FCA) to identify actual or potential harm to consumers, markets, the UK economy and wider society. On 4 May 2023, it published its latest whistleblowing data for the final quarter of 2022 (for the months October to December 2022) (Q4 2022). During this quarter, the … Continue Reading

New briefing note: Dawn Raids – Key practical steps for firms

Firms should have in place, and keep up to date and easily accessible, a documented policy and procedure which employees must follow in the event of an unannounced visit from a regulator. To assist firms in this area we have published a new briefing note setting out a reminder of some of the key steps … Continue Reading

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

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

FCA updates webpage on PS22/11: Improving the Appointed Representatives regime

On 19 August 2022, the FCA updated its webpage regarding Policy Statement 22/11: ‘Improving the Appointed Representatives regime’. The FCA has added new text under the heading ’Next Steps’. The full section now reads: The changes will take effect on 8 December 2022. Principals should read our updated rules and expectations and take any necessary … 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

Cyber-attacks are on the increase: reminder of FCA and PRA expectations on regulated firms

It has been reported that, in 2021, the FCA experienced a 52% increase in reports of “material” cyber security incidents and we expect this upward trend to continue into 2022.  The rise in ransomware in particular was highlighted in the very recent paper published by UK Finance, which called on UK authorities to focus on … Continue Reading

RT Plus – PS 21/16 on issuing statutory notices: A new approach to decision makers

A new episode of RT Plus is available now to stream and download. In this episode, Katie Stephen, Co-Head of the Contentious Financial Services Group in London, is joined by Rebecca Dulieu, Senior Associate, to discuss the FCA’s recent Policy Statement on issuing statutory notices, under which the FCA is reforming its decision-making process. Katie … Continue Reading