Daily FSR update 9 – 12 April 2019

Due to difficulties with our publishing software, we have been unable to deliver our Daily FSR Update to you over the last few days. In the interim, we have consolidated the updates, which you can view here. Read more

Anti-money laundering regulatory round-up

Author: Susannah Cogman Late 2018 and early 2019 saw a flurry of regulatory developments and proposals relating to anti-money laundering. We have reported on these in brief in our regular corporate crime updates, but for those who have been –… Read more

FCA consults on further changes to SMCR

Authors: Sarah Thomas, Cat Dankos and Hywel Jenkins At the end of January, the UK Financial Conduct Authority (FCA) issued a further consultation paper (CP19/4, the CP) on the Senior Managers and Certification Regime (SMCR). Responses to the CP are… Read more

OFSI publishes Annual Review

On 5 October 2018, HM Treasury's Office of Financial Sanctions Implementation (OFSI) published its Annual Review for the 2017-18 financial year. This is the first such review published by OFSI and provides an overview of OFSI's activities in 2017-18, as… Read more


The Anti-Corruption Commission (Amendment) Act 2018 was passed by the Senate of Malaysia on 5 April 2018. One of the major amendments is the introduction of section 17A. Modelled on the UK Bribery Act's corporate offence, it penalises commercial organisations… Read more

Market Abuse Update – May 2017

The latest edition of our Market Abuse Update covers developments from the second half of 2016 through to April 2017. It features: the latest UK civil and criminal market abuse proceedings; significant international developments and enforcement cases; the FCA's recent Market… Read more


New Market Abuse powers for the FCA (2) Powers to require information from issuers, PDMRs and persons closely associated to PDMRs The Financial Services and Markets Act 2000 (Market Abuse) Regulations 2016 (the "regulations") were passed to ensure that UK law… Read more


New Market Abuse powers for the FCA   The Financial Services and Markets Act 2000 (Market Abuse) Regulations 2016 On 29 June 2016, the Government adopted the Financial Services and Markets Act 2000 (Market Abuse) Regulations 2016 (the "regulations").  This left… Read more


Investment recommendations Increased scope The former Market Abuse Directive (MAD) imposed requirements designed to ensure the objective presentation of investment recommendations and the disclosure of interests and conflicts of interest on the part of producers or disseminators of such recommendations. … Read more

Market abuse update – July 2016

The Market Abuse Regulation (MAR) and the Criminal Sanctions (Market Abuse) Directive came into application in Europe on 3 July 2016.  Various outstanding pieces of secondary legislation were published in the Official Journal shortly before then, and further material has… Read more


Suspicious transaction and order reporting Under Article 16 of MAR, market operators and investment firms operating a trading venue1, and any person professionally arranging or executing transactions, should have in place arrangements, procedures and systems for the detection and reporting… Read more

Material adverse change clauses – staging a return

Material adverse change (MAC) clauses aim to give buyers a right to withdraw from M&A deals on the occurrence of certain events that are detrimental to the target company. While MAC clauses have been a standard feature of US M&A agreements… Read more

Ensuring due process when regulators co-operate

Summary A recent Hong Kong judgment highlights the importance of ensuring due process when regulators exchange information with each other. Regulatory confidentiality In the UK a statement made to an investigator appointed by the FCA or PRA in compliance with… Read more

Market abuse update – April 2016

This will be our last quarterly Market Abuse update before 3 July 2016, the date when both the new Market Abuse Regulation and the Criminal Sanctions (Market Abuse) Directive come into application across Europe. Some significant pieces of the regulatory… Read more

Financial firms: protecting customer personal data

A recent case provides a rare example of the criminal prosecution of an individual (in this case the former employee of an insurer) for breach of the Data Protection Act 1988 (DPA).  David Barlow Lewis was a former employee of… Read more

Recent developments in Scottish and English bribery enforcement

On 5 April 2016, The Scottish Crown Office and Procurator Fiscal Service ("COPFS") announced the latest resolution of a Bribery Act enforcement action against the Glasgow-based logistics company, Braid Logistics (UK) Limited. Braid agreed to pay £2.2 million pursuant to… Read more

UK Financial Advice Market Review recommendations published

The Financial Advice Market Review (FAMR) has today published its report and recommendations.  FAMR was launched in August 2015 to explore what steps the Government, industry and regulators might individually and collectively take to stimulate the development of a market… Read more

“Brexit”: Financial Services Regulation

Audio Webinar: Brexit: Implications for Financial Services Regulation In the second of our series of Brexit webinars, held on 17 February 2016, we looked at the implications on financial services of a UK exit from the EU. ... Read more

Middle East financial services briefing

A round-up of key legal and regulatory developments in the United Arab Emirates, Kuwait, Qatar, Bahrain and Saudi Arabia  Overview & Outlook for 2016 Legislative and regulatory reforms and enforcement actions by regulators in the Middle East in 2015 indicate… Read more

Update on conglomerate regulation

Geoff Maddock, partner Email | Profile tel: +44 20 7466 2067 mobile: +44 7785 255016 By Geoff Maddock, corporate insurance partner and Jonathan Goodliffe, solicitor The Joint Committee of the European Supervisory Authorities has published an updated list of groups… Read more

Germany intensifies fight against corruption abroad and at home

Germany's recently enacted "Law for the fight against corruption" (the "New Law"[1]) has intensified the fight against corruption by broadening in multiple ways the scope of German anti-corruption legislation.  The New Law implements various legal acts of the Council of… Read more