• Increasing Focus on AI — AI developments and uses and the evolving legal and regulatory landscape may bring about new litigation and enforcement risks stemming from claims of algorithmic bias, discrimination, errors made by autonomous AI agents, fraud perpetrated using AI, misuse relating to privacy and governance, monitoring and reporting, and other areas. Evolving theories
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The UK Financial Conduct Authority (FCA) is expanding the reach of its Code of Conduct (COCON) for non-bank firms and consulting on new guidance related to non-financial misconduct, with changes taking effect from September 2026 that will align requirements more closely with those already applicable to banks.…

Continue Reading UK FCA Expands the Reach of COCON and Consults on Non-Financial Misconduct

The FCA has initiated significant engagement with the private funds sector, akin to its 2013 AIFMD implementation efforts. In 2025, it plans to streamline UK regulatory requirements for fund managers and review conflict of interest management, focusing on governance and investor protections.
Continue Reading FCA Review of Private Fund Market Valuation Practices

In late 2024, the United Kingdom’s Financial Conduct Authority (FCA) published a “Dear CEO” letter related to the FCA’s “Custody and Fund Services Supervision Strategy.” The letter shares the FCA’s expectations of UK FCA-authorised firms that act as custodians, depositories, and administrators in the funds sector. Importantly the letter also highlights some of the regulatory…

The UK Financial Conduct Authority (FCA) has proposed significant changes to the safeguarding requirements for UK registered payments and e-money firms (CP24/20). The FCA’s goal is to replace the current safeguarding regime with a new one influenced by existing client money rules that apply to authorised firms holding client money (CASS). 

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The UK’s Financial Conduct Authority (FCA) released a Discussion Paper (DP23/2: Updating and improving the UK regime for asset management) in February 2023 which recognises that, as a consequence of Brexit, it is time to consider what the shape of the UK’s asset management regulatory regime will take in the future.

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1. Non-financial misconduct – FCA guidance expected

It is anticipated that in 2023 the Financial Conduct Authority (FCA) will provide further guidance on the increasingly uncertain question of what kinds of “non-financial misconduct” may be relevant to an assessment of a regulated individual’s “fitness and propriety”. “Fitness and propriety”…

In December 2021, the UK Financial Conduct Authority (FCA) published a consultation to set a higher standard of consumer protection in retail financial markets, an endeavor which began in July 2018. At the core of the proposed new rules is a new Principle for Businesses: “A firm must act to deliver good outcomes for…

The Appointed Representatives Regime (ARR), a well-known and important feature of the UK regulatory landscape, enables certain businesses – Appointed Representatives (ARs) – to conduct regulated activities without having to be authorised by the Financial Conduct Authority (the FCA). The FCA is proposing significant new rules and guidance that seek in the main to increase…