Express consent needed for collateral use of Mutual Legal Assistance material in FCA civil proceedings

The High Court has declined to strike out civil proceedings brought by the Financial Conduct Authority in respect of alleged market abuse, even though it found that the Financial Conduct Authority (FCA) had made impermissible collateral use of material obtained through mutual legal assistance (MLA) requests without first obtaining the consent of the relevant overseas authorities. Read more

Sanctions tracker: new UK sanctions regarding Russian oil

The UK introduced further sanctions against Russia on 4 November 2022, via the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (the "No. 16 Regulations"). These introduce further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The amendments introduced by the No. 16 Regulations will come into force on 5 December 2022 (although, as set out below, certain specific measures will not take effect until February 2023) and introduce further measures relating to Russian oil, as discussed further in this briefing. Read more

Sanctions tracker: UK introduces new Russia lending and trade restrictions

New UK Russia sanctions legislation was published on 28 October: the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (the "No. 15 Regulations"). These amend the UK's principal Russia sanctions legislation: the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). This briefing summarises the key amendments to the Russia Regulations, the majority of which came into force on 29 October. Read more

FCA publishes consultation paper on sustainability disclosure requirements and investment labels

The FCA published today their long-awaited consultation paper on sustainability disclosure requirements and investment labels (the "Consultation"). This follows the discussion paper published in November 2021. The Consultation builds on the core elements of the regime outlined in the discussion paper: sustainable investment labels, consumer-facing disclosures, detailed product-level disclosures and entity-level disclosures. In addition, the Consultation also proposes naming and marketing rules with broader applicability, a general anti-greenwashing rule and other specific obligations on distributors. In this post, we summarise our key takeaways from the Consultation, together with a high-level overview of the FCA's proposals. Read more