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
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
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
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
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
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
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
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
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
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
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
