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Regulators around the world are focused on the operational resilience of financial institutions, financial market infrastructures and the financial system as a whole. One area of significant risk to the financial system are the significant dependencies of financial institutions on Critical Third Parties (CTPs), particularly in relation to the cloud and other Information and Communication Technology (ICT) services. Both the UK and the EU have advanced proposals for new regulatory frameworks in this area. Read more
On 19 December 2022 the Bank of England ("BoE") published its annual report on Financial Market Infrastructures' ("FMIs") supervision which sketches the BoE's work undertaken during 2021/22 and sets out its supervisory approach for 2022/23 ("Report"). Read more
Our Global FSR Outlook 2023 has been published. In the Outlook, our Financial Services Regulatory (FSR) team surveys the regulatory landscape for 2023 and considers the challenges confronting firms and regulators. Read more
On 21 July 2022 the Bank of England, the PRA and the FCA publishedDiscussion Paper 22/3 - Operational resilience: Critical third parties to the UK financial sector (DP22/3). DP22/3 sets out how the financial services regulators could use new powers proposed under the Financial Services and Markets Bill (FSM Bill) to assess and strengthen the resilience of material services provided by critical third parties to the UK financial services sector. Publication of DP22/3 marks an early step on the road to the introduction of a new designation regime for third party providers in respect of the material services they provide to the financial services sector.Read more
We have updated our Operational Resilience timeline to include key recent developments from the UK, EU, Hong Kong, Singapore, Australia and international standard setting bodies. Operational resilience is the ability to 'prevent, adapt, respond to, recover and learn from operational disruptions'. Read more
Following the HKMA’s 21 April 2021 circular highlighting the additional guidance issued by the BCBS on 31 March 2021, namely the Principles for Operational Resilience and the Revised Principles for Sound Management of Operational Risk, the HKMA launched a consultation on 22 December 2021 on a new proposed Supervisory Policy Manual module OR-2 (Operational Resilience) and proposed amendments to existing SPM modules TM-G-2 (Business Continuity Planning) and OR-1 (Operational Risk Management) in order to align with the BCBS’s operational resilience guidance. Read more
The latest edition of our Regulation in Focus podcast series features two former regulators in conversation about operational resilience – Andrew Procter from Herbert Smith Freehills and Michael Sicsic from Sicsic Advisory. Read more
In this blog post, we round-up key forthcoming developments in the UK and at EU and International levels in financial services regulation which are expected to happen in February and March 2022. Read more
When the UK authorities published their final policy on operational resilience at the end of March 2021, it was broadly acknowledged – including by the PRA itself – that the operational resilience landscape would continue to develop. The latest act on the UK stage is the PRA's proposals to apply the group provisions in the Operational Resilience Part of the PRA Rulebook relevant to Capital Requirements Regulation (CRR) firms to holding companies. Read more