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Topic: Beyond Sanctions: Key considerations for financial services firms

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Hot topics in sanctions compliance for financial services firms and broader considerations

The events in Ukraine and the economic sanctions imposed on Russia raise a number of issues that financial services firms will need to consider. Above and beyond the immediate challenges arising from the imposition of sanctions on clients and counterparties, firms may also need to address concerns about market conduct and systems and controls. This … Continue Reading

New FCA webpage – Reporting sanctions evasions

On 17 May 2022, the FCA published a new web page concerning the reporting of sanctions evasions. The web page provides information concerning the ways in which firms and individuals can report sanctions evasion to the FCA. It also covers what to tell the FCA and how to report another firm or individual. The web … Continue Reading

Russian sanctions: European Commission’s guidance

Following adoption of a series of trade and economic sanctions against Russia (see our earlier Beyond Sanctions publication), the European Commission (the Commission) continues to update dedicated industry guidance in a form of Frequently Asked Questions (FAQs). The FAQs are divided into five thematic sections: Horizontal Individual financial measures Finance and banking Trade and customs … Continue Reading

RT Plus – Beyond Sanctions – Sanctions and governance insights

In this episode of our Beyond Sanctions series, David Harris and Katie Stephen, Co-Heads of our Contentious Financial Services Group in London, discuss their sanctions and governance insights from recent work, as well as some practical takeaways for firms from these. The podcast is available to stream and download from the Norton Rose Fulbright website, … Continue Reading

Beyond Sanctions – new financial services hub

Our financial services and regulation team have launched the ‘Beyond Sanctions’ insights hub, highlighting the broader issues that financial services firms will need to consider, above and beyond the immediate concerns and challenges arising from the economic sanctions. Visit our hub to find out more.… Continue Reading

RT Plus – Beyond Sanctions – Market manipulation

In this next instalment of our Beyond Sanctions series, Katie Stephen and Joe Smallshaw discuss examples of market manipulation, red flags for firms and practical steps firms can be taking now to help detect and prevent market manipulation. The podcast is available to stream and download from the Norton Rose Fulbright website, Apple Podcasts and … Continue Reading

Russian sanctions: European developments in the area of financial services

In the light of the ongoing Russian invasion of Ukraine, the European Union (EU) Member States adopted a series of new sanctions against Russia. Both the scope, complexity and the expedited pace of adoption of the new restrictive measures is unprecedented, which can make it challenging for financial and non-financial institutions to keep a track … Continue Reading

FCA to consult on use of ‘side pockets’ for retail funds with exposure to sanctioned and suspended Russian assets

On 16 March 2022, the FCA issued a statement on its website stating that it has begun discussions with stakeholders about options to allow UK authorised retail funds to make exceptional use of ‘side pockets’ given the practical issues in disposing of Russian and Belarussian assets in the context of suspensions and extensive global sanctions. … Continue Reading

Economic Crime (Transparency and Enforcement) Act

Beyond Sanctions: Practical guidance for financial services firms series   Introduction On 15 March 2022, the Economic Crime (Transparency and Enforcement) Bill (the Bill) received Royal Assent becoming the Economic Crime (Transparency and Enforcement) Act 2022 (the Act). The Act has been some time in the making and can be traced back to 2016 when … Continue Reading

RT Plus – Beyond Sanctions – Market conduct and Economic Crime Bill

In the first instalment of our ‘Beyond Sanctions’, Jonathan Herbst and Haney Saadah consider market conduct issues in light of the developments in Ukraine and the UK’s Economic Crime Bill. The podcast is available to stream and download from the Norton Rose Fulbright website, Apple Podcasts and Spotify.… Continue Reading

Manipulative trading practices: A guide for banks’ legal and compliance departments

The events in Ukraine are having a significant impact on financial markets. In the UK, the FCA recently issued a statement reminding issuers of securities admitted to UK trading venues of their disclosure obligations under the UK Market Abuse Regulation. More widely, the FCA will be keeping a close eye on market conduct during this … Continue Reading

Russian sanctions – practical guidance for regulated firms

We recently published a blog reporting on governance considerations for regulated firms in relation to Russian sanctions. As the sanctions landscape continues to evolve, impacted firms operating in different jurisdictions are grappling with overlapping and differing requirements, and global firms will need to ensure a coordinated approach across their operations. We have set out below … Continue Reading

FCA statement ‘Events in Ukraine – impact on financial markets’

On 3 March 2022, the FCA issued a statement on its website concerning events in Ukraine and the sanctions imposed on Russia, reminding issuers of securities admitted to UK trading venues of their disclosure obligations under the UK Market Abuse Regulation (MAR). The statement goes on to remind companies in scope of MAR that they … Continue Reading

Economic Crime (Transparency and Enforcement) Bill 2022: overarching documents

On 28 February 2022, there was published on the UK government’s website The Economic Crime (Transparency and Enforcement) Bill 2022 (Bill) and a factsheet regarding the Register of Overseas Entities. The Bill has three main objectives: Prevent and combat the use of land in the UK for money laundering purposes by increasing the transparency of … Continue Reading

Russian sanctions – governance considerations for regulated firms

Earlier this week we published a blog reporting on the FCA’s statement regarding the new financial sanctions that the UK has imposed on Russia. As the FCA identified in its statement, the imposition of sanctions creates a regulatory risk for firms and their staff (particularly senior managers) in the sense that, where the regulator identifies … Continue Reading

New FCA webpage on financial sanctions measures in relation to Russia

On 22 February 2022, the FCA published a new webpage concerning its expectations of firms in light of the UK’s sanctions on Russia. The key message from the FCA is that it expects firms to have established systems and controls to counter the risk that they might be used to further financial crime and this … Continue Reading
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