Many regulated firms rely on third parties for services such as accounting, external audit or human resources, through to developing products and services, networking arrangements, payment processing, use of services provided by affiliates, joint ventures, and subsidiaries. The current operating…
Earlier this year Goldman Sachs (GS) reached settlements with regulators in the US, UK, Singapore, and Hong Kong over 1MDB. On 22 October 2020, the Chief Executive Officer (CEO) of GS sent an email to all employees globally reflecting on…
The environment in which we are working has changed. This will change how you previously assessed risks. The FCA has been reminding us recently of the need to review your risk assessments in light of the new operating environment. But…
ESMA’s review of the Market Abuse Regulation places reliance and expectations on the Global FX Code. Particularly in relation to whether, or when, to regulate spot FX (forex). Both ESMA and the FCA want to see the impact of the…
Market conduct poses risks to regulated firms irrespective of the markets they are in or the clients they serve. The nature of market abuse varies which we show in the Market Abuse Themes chart below. The FCA is of the…
FCA works on a risk-based approach and as such they group firms according to the level of risk the firm poses to the FCA objectives. For CASS (the FCA’s Clients Assets Sourcebook), the FCA determines this according to how much…
1. Brexit Readiness EEA Incoming Firms FCA has said that it intends to allow substituted compliance with the equivalent obligation in your firm’s home state. This means that you do not have to do a massive rewrite and mapping of…
For several years now the FCA has been repeating its concern that the reporting of STORs (Suspicious Transaction Order Reports) is dominated by suspicious transactions in equities. More specifically what the FCA has referred to as the “poster child” of…
Rules breaches can have negative connotations after all non-compliance is never good. It can depend of course on what the breach is, whether its material, affects many clients or appears systemic. A breach that you identify yourself, in-house, perhaps through…
Market Watch 64 is a timely reminder that the count down to the end of the Brexit Transition on 31 December 2020 is underway. Back in June 2016 FCA said that EU Regulation would continue to apply to UK firms…