The question of what is or might be in the Financial Conduct Authority perimeter – i.e. covered by FCA regulation – isn’t always straightforward and can cause even a seasoned expert to...
On the 16 July 2025, the Payment Systems Regulator (PSR) published its dashboard on the management of reimbursement claims since its policy was imposed on in-scope firms 6 months ago. It remains...
The announcement from the UK Supreme Court will be welcomed by those across the motor finance industry. It has been deemed that non-discretionary commission does not amount to a bribe, nor does...
The UK government’s 2025 National Risk Assessment (NRA) has arrived, offering critical updates on money laundering and terrorist financing risks since the last assessment in 2020. This is the first NRA in...
Digital Finance Newsletter July 2025 Welcome to the latest edition of our compliance newsletter. The eagle eyed among you will have noticed that we have had a change of name since the...
On 15 July 2025, Rachel Reeves, set out the government’s next steps to boost the UK’s financial services industry in her Leeds Reforms. Simultaneously, HMT, the FCA and the Bank of England...
Published in May 2025, the FCA’s Policy Statement PS25/4 introduced a significant regulatory shift for UK fund managers. While the policy came into effect two months ago, its practical implications are only...
New rule under COCON The Financial Conduct Authority (FCA) is introducing a new rule under the Code of Conduct (COCON) to explicitly address non-financial misconduct (NFM), such as bullying, harassment, and violence,...
On 7 November 2024, we published an article about how the FCA interviewed twenty finfluencers under caution. That was at the end of October 2024. Well, it seems that the FCA has...
In 2024–25, the Financial Conduct Authority (FCA) conducted a thematic review of 14 e-money and payment firms, assessing their frameworks for enterprise and liquidity risk, as well as their preparedness for an...
In a recent news blog, Nikhil Rathi, FCA Chief Executive, and John Edwards, UK Information Commissioner (ICO) have stated that the FCA and ICO will be joining forces and working together to...
Prudential Services is now part of the Financial Resilience sector at Cosegic. The Financial Conduct Authority’s (FCA’s) release of the new draft rules is relevant to firms and consumers that either plan to or...
The Financial Conduct Authority (FCA) recently held two separate information sessions to support firms seeking authorisation in the Crypto and the Digital Finance sectors. The session for Cryptoasset applicants took place on...
The latest UK Finance Annual Fraud Report offers a detailed view of the evolving fraud environment that directly affect payment service providers (PSPs). In 2024, the UK saw a record-breaking 3.31 million...
In a recent update published 5 June 2025, the FCA is looking ahead of the Supreme Court decision and are setting out the points for consideration if a redress scheme was introduced...
Following the recent publication by HM Treasury, which proposes regulating cryptoassets under FSMA, the FCA has published two consultation papers titled CP25/14 and CP25/15. This article focuses on CP25/14, specifically on two...
Managing conflicts of interest, is something no one (other than complete reprobates) objects to in principle. However, it is something that can be tricky to navigate in practice. For FCA regulated firms...
The Financial Conduct Authority’s (FCA or the ‘regulator’) latest communication on improving contactless payments has sparked a great deal of interest in the payments industry. The proposed approach involves a physical payment...
Financial crime and anti-money laundering (“AML”) controls are only effective when they work as intended: to prevent and mitigate illicit activity. Regular audits are one of the most reliable ways to evaluate...
Last year, the Government ran a six-week consultation between 17 October and 29 November 2024 on proposals for bringing currently unregulated Buy-Now, Pay-Later (BNPL) products into regulation. This consultation also included draft...
In 2025, one of the most exciting trends in UK capital markets is unfolding quietly but powerfully: retail access to private markets. Historically the preserve of institutions and ultra-high-net-worth investors, private equity,...
The UK is a world leader and a global hub for commercial insurance, providing expertise in underwriting complex and specialty risks, and handling risks from all over the world. At the same...
Since the introduction of the UK’s Authorised Push Payment (APP) scam reimbursement requirement on 7 October 2024, the Payment Systems Regulator (PSR) has reported encouraging progress in both consumer protection and industry...
On 8 May 2025, the FCA published the findings of its review into the business models of smaller asset managers and alternative investment firms. The review aims to support new market entrants...
On the 9th May 2025, Matthew and Nikolas West (“the brothers”) pleaded guilty to insider dealing in the shares of four companies between November 2016 and January 2020 (“the period”), following a...
“Something old, something new”: this traditional wedding phrase mirrors HM Treasury’s approach to cryptoasset regulation. On 29 April, the HMT released draft rules proposing that cryptoassets be regulated under the Financial Services...
The relationship between financial firms and the FCA is largely centred around the regular submission of reports and data. However, the volume of reporting can, at times, be overwhelming, and it can...
On the 12 April 2025, the FCA provided a concentrated review on how banks and building societies handled customer bereavement and power of attorney (PoA). Whilst the review focused on banks and...
Preparing the Consumer Duty Board Report 2025 – Tips to Consider You might think that it has been only a few months since you were knee-deep in preparing your first Consumer Duty...
Payment Services Compliance Newsletter March 2025 Welcome to the latest edition of our compliance newsletter aimed at Payments firms, including EMIs, PIs, AISPs, PISPs and prospective applicant firms. This newsletter contains a...
I hope people found the webinar we at Cosegic did with Clear Junction last month useful and interesting. If you missed it, or would like to remind yourself of what was said,...
Last year, the Financial Conduct Authority (FCA) announced that it was conducting a review of how firms treat customers in vulnerable circumstances. It also took the opportunity to consider whether its existing...
Consumer Credit & Insurance Compliance Newsletter February 2025 Welcome to the latest edition of our compliance newsletter for Consumer Credit & Insurance. Since the turn of the year, there has been a...
On 30th January 2025, the FCA issued a Portfolio letter to the CEOs of Mortgage Intermediaries outlining the new strategy for supervising firms. Mortgage intermediaries play an important role in matching consumers...
Because firms, particularly those in the financial sector, face increasingly complex, interlinked and sophisticated challenges, effective risk management is a key element of good governance. Having a risk register and completing the...
On 30th January 2025, the FCA issued a Portfolio letter to the CEOs of all Claims Management Companies (CMCs) outlining the new strategy for supervising firm. As a reminder, the transfer of...
Whilst the latest Dear CEO letter to the Payments portfolio has garnered much interest, there are a couple of ‘highlights’ that have largely slipped below the radar. One of these is a...
Following hot on the heels of the FCA CEO Nikhil Rathi’s letter to the Chancellor, Rachel Reeves, we see the FCA doubling down on its commitment to growth and commitment in the...
Keen followers of the political news will have seen that the Chancellor of the Exchequer recently held a meeting with the heads of UK regulatory bodies, urging them to remove barriers to...
Shockwaves flew through the car finance industry last month when the Court of Appeal ruling on secret commissions being received by credit brokers, expanded the scope of the commission disclosure issues. It...
In September, the FCA announced an extension to the implementation timeline for the new naming and marketing rules under its Sustainability Disclosure Requirements and Investment Labels regime (SDR). The FCA observed it...
“Reputation, reputation, reputation! O, I have lost my reputation!” William Shakespeare, Othello (Cassio, Act II, Scene iii) Firms with positive reputations increase customer acquisition and retention, as well as attract better employees. The market...
Last month the FCA published a proposed Terms of Reference (ToR) for a new market study into the provision of premium finance for motor and home insurance policies. The scope of this...
The FCA has recently published its finalised guidance (FG) to explain how firms are expected to apply changes introduced by the Payment Services (Amendment) Regulations 2024 (the regulation). The regulation introduces new...
Following the introduction of the Markets in Financial Instruments Regulation (“MiFIR”) in 2014, in-scope firms have been required to submit transaction reports to the Financial Conduct Authority (“FCA”) after the execution of...
On 12th November 2024, The Financial Conduct Authority (‘FCA’), the Bank of England (the Bank) and Prudential Regulatory Authority (‘PRA’) (‘regulators’) published a joint Policy Statement (PS) 24/16 ‘Operational Resilience: Critical third...
In January 2024, the FCA (‘the Regulator’) sample tested 23 payment firms (‘firms’) to assess the sector’s response to Consumer Duty (‘the Duty’) implementation and specific risks communicated in its Dear CEO...
At the end of October, the FCA interviewed twenty finfluencers under caution. What is a finfluencer, I hear you say? Finfluencers, or financial influencers, are individuals who offer advice and information on...
The issue of gifts and hospitality has been in the news lately – albeit in the political arena, rather than that of financial services. However, it is an issue that seemingly never...
Payment Services Compliance Newsletter October 2024 Welcome to the latest edition of our compliance newsletter aimed at Payments firms, including EMIs, PIs, AISPs, PISPs and prospective applicant firms. This newsletter contains a...
Consumer Credit & Insurance Compliance Newsletter October 2024 Welcome to the latest edition of our compliance newsletter for Consumer Credit & Insurance. The traditional quiet summer season for regulatory developments – extended...
Last week, HM Treasury has released its latest consultation in respect of the regulation of Buy Now Pay Later (‘BNPL’) with only a six-week consultation period for industry feedback. Once the legislation...
In December 2023, the Payment Systems Regulator (PSR) issued a Policy Statement ‘Fighting authorised push payment scams: final decision’. This introduced, amongst other matters, a new reimbursement requirement for consumer victims of...
Welcome to the latest edition of our compliance newsletter for capital markets firms, including wholesale buy and sell-side firms, wealth managers and corporate finance firms. We are now emerging from the traditionally quiet...
No, this is not a legal case that you had missed. However, in this article I will be delving into the shared, but separate, responsibility of both HM Revenue & Customs (‘HMRC’)...
The FCA has published its final rules on introducing a third option for investment managers to purchase research services through joint research and execution payments. These largely confirm the so-called “guardrails” for...
The FCA has issued its long anticipated consultation paper (CP) on changes to the safeguarding regime for payments and e-money firms CP24-20. “Game changer” is a bit of an overused phrase but,...
Early and High Growth Oversight (“Early Oversight”) is a relatively new FCA initiative which has created an enhanced supervisory framework for newly authorised firms. As they get used to their regulatory status,...
Ambrose Bierce – The Devil’s Dictionary “Consult – To seek another’s approval of a course already decided upon.” Following the last minute decision of the Payment Systems Regulator (PSR) to consult (hurriedly)...
Last week the FCA released a consultation (CP24/19) which aims to increase the level of detail received from consumer credit firms. At present a typical secondary credit broker will provide six pieces...
The treatment of vulnerable customers by financial services firms has been an area of FCA focus for many years, because vulnerable customers often have additional needs and don’t always experience the same...
The National Crime Agency (NCA) released its latest SARs Reporter Booklet in August 2024, which offers a detailed look into how Suspicious Activity Reports (SARs) are leveraged by law enforcement agencies (LEAs)...
On 21st August 2024, the FCA published TR24/2: General insurance and pure protection product governance thematic review. The review supersedes the FCA’s letter from February 2024, which commented on its key observations...
It is a vital element of good governance and risk management for a regulated firm to review its suite of policies and procedures and keep them up to date so that they...
On 30th July 2024, the FCA (the Regulator) issued an update extending its temporary complaint handling rules for discretionary commission arrangement (DCA) complaints in the motor finance industry. The Regulator is proposing to...
On 7th August, the FCA released its quarterly data report on financial promotions (2024 Q2 quarterly data on financial promotions) which raised concerns regarding the compliance of cryptoasset firms’ partner firms and...
In June 2023, the FCA set new rules for the promotion of qualifying cryptoassets to retail clients in its Policy Statement PS23/6 – Financial promotions rules for cryptoassets and related Non-handbook Guidance...
In March, the FCA sent a Dear CEO letter to firms they supervise in relation to Money Laundering Regulations (MLRs), otherwise known as “Annex I firms”. The letter raised concerns with inadequate systems...
On 26th June 2024, the Financial Conduct Authority (FCA) published the results of their insurance multi-firm review of outcomes monitoring under the Consumer Duty. The results come from a review undertaken in...
The FCA used the latest edition of their regular newsletter on market abuse and transaction reporting, Market Watch 79, published in May, to highlight typical failures of market abuse surveillance arrangements caused...
On 19 June 2024, the European Union published its revised anti-money laundering (AML) regime in the Official Journal, which has introduced significant changes for financial services firms and other obligated entities. This...
Consumer Duty has once again been catapulted to the top of firms’ priority lists as the first Consumer Duty board report is due at the end of this month. As stated here, the...
Consumer Credit & Insurance Compliance Newsletter June 2024 Welcome to the very first edition of our compliance newsletter aimed at Consumer Credit and Insurance (CC&I) firms. This newsletter contains a round-up of...
Earlier this year, we hosted a webinar to discuss the FCA’s prudential requirements focus areas for the payments sector. Attendees were asked whether in response to the portfolio letter issued in Q1...
It is a truism that governments are never so powerful as at their inception. Following a campaign that shied away from specific commitments, yet voted in with a record majority, the new...
In April 2024, the Financial Conduct Authority (FCA) issued Policy Statement 24/3, confirming the enhancements to FCA reporting relating to consumer credit lending. This is the latest in the increase of RegData...
Welcome to the latest edition of our compliance newsletter aimed at capital markets firms, including wholesale buy and sell-side firms, wealth managers and corporate finance firms. We are now coming to the end...
Payment Services Compliance Newsletter June 2024 Welcome to the latest edition of our compliance newsletter aimed at Payments firms, including EMIs, PIs, AISPs, PISPs and prospective applicant firms. This newsletter contains a...
Over the last twelve months, many principal firms, looking to onboard Appointed Representatives (ARs) or Introducer Appointed Representatives (IARs), will have noticed a significant increase in the level of scrutiny applied by...
Payments, as I’m sure readers will have either read or heard me say before on numerous occasions, is the plumbing of financial services. Nobody pays it much attention when it is working...
The EBA and ESMA have just released a discussion paper to request advice and feedback on the Investment Firms Regime (IFR), applicable to MIFID investments firms in the EU. The IFR was implemented...
On 28 May 2024, the Office for Financial Sanctions Implementation (OFSI) issued General Licence INT/2024/4761108 (the General Licence), impacting what it calls “Personal Remittances”. The General Licence issues clear and specific conditions...
AI – tomorrow’s regulation, today? The FCA is currently taking a pragmatic approach to the regulation of artificial intelligence (AI) by applying and adapting existing rules and principles to manage AI-related risks....
As part of our review of the FCA’s ‘Transformation Programme’ back in 2022, we analysed the increasingly challenging authorisations process, and why the FCA was creating a ‘more robust gateway’. Indeed, in...
The FCA’s anti-greenwashing rule (the “Rule”) comes into force on 31 May 2024. This is a delayed date reflecting the drafting of, and consultation on, supplementary (non-Handbook) guidance on the Rule which...
The FCA has introduced a new Form A for Senior Manager Function (“SMF”) and Controlled Function (“CF”) applications (the latter applicable to appointed representatives) and has updated its webpage highlighting the changes....
The FCA has issued a new consultation paper, CP24-9 (‘the Consultation’), proposing updates to its Financial Crime Guide (FCG). The updates are aimed at enhancing firms’ understanding of the FCA’s expectations regarding...
The FCA has published its long-awaited Consultation Paper CP24/7 on Payment Optionality for Investment Research (”the Consultation”). This contains its proposals to give UK buyside firms, including asset managers, greater flexibility on...
At the start of March, the FCA released a Dear CEO letter (the “Letter”) to asset managers and alternative investment managers regarding their supervisory strategy of firms in these sectors. Before we...
On the 12 March 2024 HM Treasury (‘HMT’) communicated its proposal to introduce a new statutory instrument, Payment Services (Amendment) Regulations 2024, which will enable payment processing to be delayed, where there...
On 27 February 2024, the FCA published Consultation “CP24/2: Our Enforcement Guide and publicising enforcement investigations – a new approach“. This is a significant and unexpected consultation on what the FCA will...
On 9th February 2024, the Financial Conduct Authority (FCA) announced that multiple insurance firms have agreed to pause sales of Guaranteed Asset Protection (GAP) insurance, following a request from the FCA. GAP...
Last Friday, the FCA announced that it would conduct a review of the actions that firms are taking to understand and respond to the needs of customers in vulnerable circumstances. The review...
Two months on from the FCA announcing it will undertake further work in the Motor Finance sector in respect of commission following Financial Ombudsmen Scheme (FOS) judgements, I thought it was a...
Payment Services Compliance Newsletter Welcome to the latest edition of our compliance newsletter aimed at payments firms, including EMIs, PIs, AISPs, PISPs and prospective applicant firms. This newsletter contains a round-up of...
Imagined scenario: One of your staff, originally a recreational drug user, has been tempted into supplementing their income by dealing drugs to friends and contacts in finance. At some point, they have attracted...
Overview At the end of November 2023, the FCA published its consultation paper (CP23/23) in respect of proposed new capital deductions for redress aimed at personal investment firms (‘PIFs’). The purpose of...
Capital Markets Regulatory Newsletter: February 2024 Welcome to the latest edition of our compliance newsletter aimed at capital markets firms, including wholesale buy and sell-side firms, wealth managers and corporate finance firms. Before...
Download Guide Compliant and effective safeguarding measures are a pre-requisite for being granted and retaining an authorisation for the provision of payment and e-money services. A portfolio Letter issued by the FCA in...
The FCA has communicated to the industry that the potential for firms to cause harm, due to the disorderly failure of their business, often arises due to insufficient liquidity. As such, the...
Outcomes Monitoring and Testing Consumer Duty was never intended to be a “once and done” exercise by the Regulator. Indeed, from the start of our communications and guidance in and around Consumer...
Make sure it has been applied correctly to your firm to avoid unnecessary payments. Last year, many Consumer Credit firms were assigned the new FIN074 report on Regdata by the FCA, when it...
Findings from the FCA Consumer Duty Webinar – 6 December 2023 The FCA presented its long-awaited Consumer Duty webinar last month, which was one of the longest webinars they have hosted. They...
Some key considerations from the FCA Discussion Paper (DP23/4) As part of its recently published discussion paper (DP23/4) on stablecoin regulation, the Financial Conduct Authority (FCA) has clarified, in alignment with the...
Key takeaways from the FCA DP23/4 The Financial Conduct Authority (FCA) released a discussion paper in November (DP23/4) setting out how it proposes to regulate the issuance and custody of fiat-backed stablecoins...
Payment Services Regulatory Newsletter: November 2023 Welcome to November’s issue of our Payment Services Newsletter. This newsletter contains a round-up of regulatory articles that provide the latest insight into compliance issues and...
The Financial Conduct Authority (FCA) has recently published details of its key findings from its multi-firm review of how the risks of Authorised Push Payment Fraud (‘APP Fraud’) and fraud attacks are mitigated...
On 7 November 2023, the Treasury published a response to its own Consultation on the financial promotion exemptions for high-net worth individuals and sophisticated investors, first launched back in December 2021. By...
Whilst much of the focus of the recent joint statement from the Prudential Regulation Authority (PRA), the Financial Conduct Authority (FCA) and the Bank of England (BoE) on the ‘Cross-authority roadmap on...
Following the flurry of activity that preceded the launch of Consumer Duty back in July, things got a little quieter. However they have suddenly got loud again! On Wednesday 8th November, the...
Regulators have long been aware of the risks posed by market soundings to the integrity of markets. By definition, market soundings involve the disclosure of confidential information to a limited circle of...
New attestation requirement for Principal Firms regarding the details of their Appointed Representatives The FCA recently introduced a new requirement for Principal Firms to confirm (and amend, if necessary) the details of...
“Nobody reads terms and conditions… do they?” We are all guilty of clicking on a button saying we have read and agree to terms and conditions online, without giving them even a...
Capital Markets Regulatory Newsletter: October 2023 Welcome to the latest edition of our compliance newsletter aimed at capital markets firms, including wholesale buy and sell-side firms and wealth managers. Since I last...
Last month the FCA published a report on the findings of its recent review of sanctions systems and controls in over 90 financial services firms. The review found that, while many firms...
On 23 August 2023, the SEC adopted the Private Fund Advisers Rules (the “Rules”), a series of rules and amendments under the Investment Advisers Act of 1940. This is effectively the final...
On Monday, the FCA and PRA published the consultation, CP23/20 on Diversity and Inclusion (“D&I”), to the financial sector. This is a topic that has been much discussed in FCA speeches in recent years...
On 31st July 2023, the FCA implemented the Consumer Duty as a regulatory requirement for new and existing products and services that are open for sale or renewal, by regulated and authorised...
Introducing a gateway for firms who approve financial promotions The FCA has recently published details of the new application gateway for firms that wish to apply to approve financial promotions for unauthorised...
Introduction Jeremy Hunt confirmed, in his Mansion House speech on 10th July 2023, the UK government’s acceptance of the recommendations of Rachel Kent’s Investment Research Review (“the Review”). This brings to a...
On 21st July 2022, amendments to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the “MLRs”) introduced the requirement for in-scope cryptoasset businesses (cryptocurrency exchanges,...
A year on from the implementation of the Investment Firm Prudential Regime (IFPR), MIFIDPRU investment firms should already be in the process of updating their Internal Capital Adequacy and Risk Assessments (ICARAs) in advance...
On 11 July 2023, HM Treasury published the Government Response on its Call for Evidence on the Short Selling Regulation (“SSR”), published last December. Also announced was a Consultation on the Short...
Capital Markets Regulatory Newsletter: July 2023 Welcome to the latest edition of our compliance newsletter aimed at capital markets firms, including wholesale buy and sell-side firms and wealth managers. Since I last...
The Payment Systems Regulator (‘PSR’ or the ‘regulator’) has recently introduced its world-first reimbursement requirement (‘reimbursement’) to Authorised Push Payment Fraud (APP) victims and E-money Institutions, Payment Institutions (PSPs) and banks, in...
This year marks the 4th anniversary of the FCA’s ownership of regulation of the Claims Management sector. The Claims Management Company (CMC) landscape has undergone significant change in that time. CMCs who...
With just over one month to go to Consumer Duty implementation, the FCA is continuing to publish additional information to firms, with updates posted on their website yesterday 28th June (2023). From...
The SEC has adopted Final Rules on amendments to Form PF reporting requirements for registered investment advisers (“RIA”) to private funds. Since their introduction 12 years ago, Form PF reports have been...
Regulatory reminder: new disclosure requirements under IFPR The Investment Firm Prudential Regime (IFPR) has introduced new Public Disclosures requirements for investment firms, replacing the Pillar 3 disclosure obligations under previous regimes. Not only do...
Avid watchers of the FCA’s Twitter feed such as myself (and yes, I know how sad that makes me) may have spotted the regulator’s announcement on 31 May that Monneo Limited has...
On 2nd May 2023, the FCA issued policy statement ‘PS23/3 Creation of a baseline financial resilience regulatory return: Feedback to CP22/19 ‘creation of a baseline financial resilience regulatory return and final rules’....
On 30 March 2023, the FCA and PRA jointly published DP23/3: Review of the Senior Managers and Certification Regime (“SMCR”). In parallel, the HM Treasury issued a Call for Evidence on the...
The UK government is introducing a new failure to prevent fraud offence aimed at holding organisations accountable if they benefit from fraud committed by their employees. This new offence will strengthen existing...
The UK Economic Crime Levy is a new annual fixed fee, that has been introduced to tackle the rising problem of economic crime in the country. Economic crime refers to any criminal...
LEARN MORE ABOUT OUR CONSUMER DUTY OFFERING After the FCA’s Consumer Duty portfolio letter to consumer investment firms, Wealth Management firms were scarcely able to draw breath before the FCA wasted no...
Blackadder – “I’ve got a plan so cunning, you could put a tail on it and call it a weasel!” The similarities between Nikhil Rathi, Chief Executive of the FCA and Edmund...
On 13 January 2023, HM Treasury (HMT) published a Review and Call for Evidence on the Payment Services Regulations 2017 (PSRs). This document fulfills its statutory obligation to review the PSRs and...
Some key areas of consideration… It’s hard to believe that it’s only been 15 months since the Investment Firm Prudential Regime (‘IFPR’) came into force. Since the go live date, we have...
The late Sir Edward George, when Governor of the Bank of England, was fond of the phrase “a stitch in time saves nine”. By which he meant, of course, better to act...
It’s now two years since the final implementation date of the Senior Manager & Certification Regime (SMCR) (March 2021) and over three years since the initial implementation date for solo regulated firms....
The FCA’s focus on customer protection and service, as evidenced by the new Consumer Duty, is being reinforced by their actions across the regulatory piece. This can be seen in the regulator’s...
On 3 February 2023, the FCA published a Letter addressed to the Chief Executives of Asset Management firms, detailing its supervisory priorities in this sector. As the letter explains, Asset Managers are...
In December, the FCA sent S165 information requests to all Principal firms requiring them to provide additional information regarding their Appointed Representative (AR) & Introducer Appointed Representative (IAR) population. The information relates...
On 11 January 2023, the FCA published a letter addressed to CEOs of wholesale brokers. The letter outlined the important risks arising from wholesale brokers’ business activities, the driving factors behind those...
On 6 December 2022, the FCA published its Consultation CP22/27 on introducing a new regulatory gateway for firms approving financial promotions. As proposed in the Financial Services and Markets Bill, this is...
We issued a Talking Regulation post on Consumer Duty implementation in mid-January, reminding firms of where they should be ahead of the fast approaching deadline. In the post we mentioned that we...
There were many standout events of 2022; the Ukraine war, the death of Queen Elizabeth and who can forget the Liz Truss premiership. In financial markets terms however, 2022 may come to...
In December, His Majesty’s Treasury (HMT) released its consultation paper in relation to the long overdue reformation of the Consumer Credit Act (CCA) 1974. I think it is safe to say that...
Fraudsters are very good. Very good at convincing ordinary people to send them money, by thinking that they are protecting themselves, or paying a valid invoice. You can tell this from UK...
On 9th December 2022, the Chancellor of the Exchequer, Jeremy Hunt, made a Statement on a series of proposed reforms (‘The Edinburgh Reforms’) to the regulation of the UK financial services sector....
Dedicated readers (there must be some?!), may recall my article on the implications of the Appeal Court judgment in the Ipagoo case which the FCA lost, where I said that, in that...
The FCA has recently updated its guidance page for firms that are currently in the temporary permissions regime (TPR). Firms in the TPR were reminded that if they do not intend to seek full...
The indie rock bank Arcade Fire have a song on their “Neon Bible” album titled “Intervention”. The song begins with crashing chords on a church organ, building up an ominous sense of...
On 1 December 2022, the FCA is introducing a new classification of investment products, together with new restrictions on issuing financial promotions on higher-risk products to retail consumers. From this date, the...
In times of increasing scrutiny, the Financial Conduct Authority (FCA) continues to remind firms of its powers and intent to ensure that only firms conducting regulated activities remain authorised. Following changes made by...
Following the announcement of the enhancements being made to the Appointed Representative (AR) Regime, which are due to come into force in December this year, both Principals and ARs may currently be...
As one of the aims of The Payment Services Directive (PSD), (from the very first European Commission proposal for “A New Legal Framework for Payment Services in the Internal Market”), was always...
Listeners to Radio 4’s venerable “I’m Sorry I Haven’t a Clue” will know the ”Uxbridge English Dictionary” round, where panelists provide new definitions for common words. Among my favourites (well, those that...
Even in post-Brexit UK, the Payment Services Directive (PSD) continues to throw its long shadow over everything related to payments, so the EU’s plans for and discussions about the content of the...
Following on from our series of articles on new firm authorisations, and our popular webinar on the FCA Authorisations ‘gateway’ function, this article looks at two of those other regulatory transactions –...
Any experienced Compliance Officer or MLRO (Money Laundering Reporting Officer) reading the EBA’s Final Report and Guidelines on the Role of the AML/CFT Compliance Officer is likely to be struck by how...
HM Treasury (HMT) has published a response to its previous consultation on amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the ‘MLRs’ (we...
With the first set of Investment Firms Prudential Regime (IFPR) returns submitted in May of this year, the FCA has highlighted its discontent with what it received in its latest IFPR newsletter,...
The Office of Financial Services Implementation (OFSI) has published an updated version of its enforcement and monetary penalty guidance which comes into force today, 15th June 2022. These updates are following measures...
The Financial Conduct Authority (FCA) issued its annual business plan setting out its priorities for the next year along with its 3-year strategy. Following on from last year’s tone, the FCA is clearly looking...
The Payment Systems Regulator (PSR) has cast a keen eye on managing the ever-rising battle for the payments industry to address the increasing problem of Authorised Push Payment (APP) fraud. With backing...
Dear CEO’s : Attention all Credit Firms In May this year, the FCA issued one of the latest in its line of Dear CEO Letters aimed towards Consumer Credit Firms. In this...
Final proposals from the FCA regarding Consumer Duty are expected by the end of July 2022. This will introduce the requirement for firms to consider the impact of the products and services...
Avid watchers of FCA court cases may have noticed that on 9 March the FCA lost its appeal against the decision of the High Court in the case of Ipagoo LLP that...
My old maths teacher at school used to say, “If you assume, it makes an ass out of u and me”. Reading the FCA’s Thematic Review TR 22/1 on wind-down planning, along...
The long awaited (and feared by some!) response from the government on its strategy for cryptoassets in the UK has been finally revealed. On 4th April, the government announced its plans to...
The above misquote from my illustrious ancestor, Robert Burns (the actual line from his poem “To a Mouse” is “the best laid schemes o’ mice and men, gang aft agley”) came to...
Filter by sector: All Wealth Management Wholesale Investment Firms Capital Markets Payment Services & Cryptoassets Insurance, Mortgages & Claims Asset Management Hedge Funds Corporate Finance Brokers Private Markets Broker Dealers Portfolio Management...
Filter by sector: All Wealth Management Wholesale Investment Firms Capital Markets Payment Services & Cryptoassets Insurance, Mortgages & Claims Asset Management Hedge Funds Corporate Finance Brokers Private Markets Broker Dealers Portfolio Management...
The announcement from the Open Banking Implementation Entity that the number of users of open banking services in the UK has passed the 5 million mark means that open banking is a...
Filter by sector: All Wealth Management Wholesale Investment Firms Capital Markets Payment Services & Cryptoassets Insurance, Mortgages & Claims Asset Management Hedge Funds Corporate Finance Brokers Private Markets Broker Dealers Portfolio Management...
In a fast-changing environment, it can be challenging for financial institutions to figure out how to comply with sanctions and manage the risk of breaches. Regarding the new UK sanction regime relating...
As I have mentioned in my article of 8 July last year (What is a Consumer?), whenever FCA guidance refers to dealing with consumers, it is always a good idea to check...
At the end of April last year, we held a Webinar on the New Operational Resilience requirements which the FCA is introducing Payment Services: Building Operational Resilience and which apply to all payment...
HM Treasury (‘HMT’) has published its response to the consultation on cryptoassets promotion, previously released in July 2020. The consultation response sets out HMT’s plan to bring the promotion of cryptoassets within...
Following our previous article (on 08 September 2021) on the proposed delivery and regulation of the New Payments Architecture (NPA), this article provides a snapshot review of the Payment System Regulator’s (PSR’s)...
According to its website, the FCA levied fines totaling £567,765,219.95 in 2021. This is a huge increase from the £192 million levied in 2020. This includes the huge £264,772,619.95 fine imposed on...
The past 18 months have seen a number of changes at the FCA, some might argue it has been their (prolonged) annus horribilis and although this article asks what went wrong, many...
As we come to the end of 2021, compliance officers might find themselves dedicating a lot of their time reminding employees to complete their compliance training before the year end and following...
In its Business Plan 2021/22 in July 2021, the Financial Conduct Authority (FCA), reminded us of its intention to remove firms’ permissions that aren’t being used. In line with Nikhil Rathi’s priorities...
On 16 November 2021, The FCA released its latest newsletter on market conduct and transaction reporting issues, ‘Market Watch 68’. The message from the regulator is clear, five years after the introduction...
Payment Institutions and EMIs who are clients of Cosegic will have heard James Borley and myself say many times over the past couple of years that, while the Senior Managers & Certification...
There are only 37 days to New Year’s Day – the date by which affected firms must have implemented the changes needed to meet the regulatory obligations of the new Investment Firms Prudential...
With the IFPR implementation date now only a matter of weeks away, the FCA has started sending firms IFPR set-up questionnaire forms over the last few days. This will enable the FCA...
Following the Woolard Review at the start of the year calling for the unregulated Buy Now Pay Later (BNPL) to be regulated by the FCA, HM Treasury accepted the findings of this...
In July of this year, The Competition & Markets Authority (CMA) wrote a letter to the Open Banking Implementation Executive, which marked a significant step forward for the Payments industry by facilitating transfers...
The COVID pandemic, and subsequent lockdowns, has meant that many firms have been forced to reassess their way of working, with employees working from home all or part of the time becoming...
LONDON – 14 September 2021 – Cosegic is the UK’s leading provider of compliance consultancy and regtech services to payments services and e-money firms. We have identified a common misunderstanding that is...
HMT Financial Crime Consultation Series On 22 July 2021, HM Treasury (HMT) released two important financial crime regulation consultation documents. To help regulated firms and other stakeholders understand and consider the proposals, we are...
Background On 29 July 2021, the Payment Systems Regulator (PSR) announced its decision to phase the development of the UK’s New Payments Architecture (NPA) by narrowing the scope of the NPA central...
The Financial Conduct Authority (FCA) has announced that as of 29 July 2022, it will be regulating the pre-paid funeral plans sector. This means that both funeral plan providers and intermediaries will need...
HMT Financial Crime Consultation Series On 22 July 2021, HM Treasury (HMT) released two important financial crime regulation consultation documents. To help regulated firms and other stakeholders understand and consider the proposals, we are...
When the Financial Conduct Authority (FCA) published their 2021/22 Business Plan on 15 July 2021 the Chief Executive Officer, Nikhil Rathim, promised a consultation into the decision-making procedures as part of its...
The Financial Conduct Authority (FCA) yesterday published its second Policy Statement (PS21/9) relating to the Investment Firms Prudential Regime (IFPR). This Policy Statement covers the areas discussed in the second Consultation Paper (CP21/7)...
HMT Financial Crime Consultation Series HM Treasury (HMT) published two important financial crime regulation consultation documents on 22 July 2021. The first document invites responses about proposed changes to the Money Laundering, Terrorist Financing...
The Financial Conduct Authority (FCA) Business Plan for 2021/22 made clear the FCA’s intent to apply a more intensive assessment with greater scrutiny of financial information and business models. As John Burns...
The Financial Conduct Authority (FCA) have issued their annual business plan setting out their priorities by sector and cross sector considerations. It’s now 16 months since the first Covid lockdown, a period...
In the blizzard of tweets, e-mails and other output emitting from the Financial Conduct Authorirty (FCA), it may seem that the publication this morning of the FCA’s Business Plan for 2021/22 is...
On 2nd July 2021, the Financial Conduct Authority (FCA) sent out a ‘Dear CEO’ letter to all general insurance intermediaries holding client money. This letter reminded firms holding or controlling client money...
As readers will be painfully aware, the Financial Conduct Authorities (FCA’s) focus on payment services and E-money is becoming ever greater. This is in huge contrast to the previous reactive approach and...
The Financial Conduct Authority’s (FCA’s) operational objectives specifically include securing an appropriate degree of protection for consumers, and promoting effective competition in the interests of consumers. The FCA’s 2020-21 Business Plan mentions...
The Financial Conduct Authority (FCA) has today published its first Policy Statement (PS21/6) relating to the Investment Firms Prudential Regime (IFPR). This Policy Statement covers the areas discussed in the first consultation...
Payment Services and E-money Institutions will be aware that they have (in theory) had the option to safeguard using the bank guarantee method since the implementation of the first Payment Services Directive (PSD1)....
On 9th July 2021 it will be a year since the FCA published their ‘Dear CEO’ letter to e-money and payments firms. Within this letter was a requirement for all E-Money Institutions,...
On 14 May 2021, the Financial Conduct Authority (FCA) published its latest Consultation Paper CP21/13. The paper sets out the regulator’s proposal for a new ‘Consumer Duty’, that would set a higher...
The Financial Conduct Authority (FCA) has announced another six month extension to the deadline for implementing Strong Customer Authentication (SCA) for card-based e-commerce transactions. The new deadline is now 14 March 2022....
The latest missive from the FCA’s Payments Supervision department has hit e-money firms’ virtual letterboxes. This ‘Dear CEO’ letter is certainly a curious thing. What is curious is how narrow the letter...
Those who joined our ‘Payment Services: Building Operational Resilience‘ webinar on 29 April 2021 will have an understanding of the work that Payment and E-money Institutions will have to carry out to...
On 31 March 2021, the Financial Conduct Authority (FCA) published PS21/4, extending the scope of firms required to submit an annual financial crime report. Firms that already submit this return will know...
Below we summarise some of the key questions which will have to be addressed when considering an application. There are potentially many other questions and we are on hand to offer...
There are eight application steps for EEA firms. It’s important that firms submit an articulate and complete application to the FCA (and, if dual-regulated, to the PRA) at the first time of asking,...
Authorised Payment Institutions (APIs) and E-money Institutions (EMIs) are required to safeguard ‘relevant funds’ by virtue of the Payments Services Regulations 2017 (PSRs) or the E-Money Regulations 2011 (EMRs). Many foreign exchange (FX)...
The Financial Conduct Authority (FCA) have identified barriers to the success of open banking and future innovation in UK payments. To address these, they are proposing amendments to the Technical Standards on...
Consultation Paper 20/22, regulatory fees and levies: policy proposal for 2021/22 On the 19th November 2020, the FCA published a consultation paper which set out proposed policy changes to the way they...
In September 2020 we published guides about a new prudential framework that was being proposed for MiFID investment firms and including Principal Brokers and Matched Principal Brokers, MiFID Authorised Investment Managers and firms...
Many cryptoasset firms are today breathing a huge sigh of relief, as the Financial Conduct Authority (FCA) announced that it is extending the deadline for firms requiring registration under the Money Laundering...
Compliancy Services, one of the UK’s leading providers of compliance consultancy and regtech services, is delighted to announce the appointment of Abou Bangoura as a consultant within their Payment Services team. This...
Compliancy Services, one of the UK’s leading providers of compliance consultancy and regtech services, is delighted announce the appointment of Harpartap Singh as Head of Prudential. He will be responsible for the...
MiFID II specifies a number of actions which firms are expected to comply with on an ongoing basis. One of these relate to the publication by execution venues of the quality of...
What do the terms ‘money laundering’, ‘fraud’, ‘bribery’, and ‘market abuse’ all have in common? Hopefully, you correctly guessed that they all relate to financial crime. All regulated firms have financial crime...
The UK is set to leave the European Union on the 31st December 2020, after this date passporting will no longer exist and international firms will need to seek full authorisation in...
Increasingly, we are seeing enquiries from firms wishing to become licensed by the Financial Conduct Authority (FCA) to provide the payment services of ‘account information services’ (AISP) and ‘payment initiation services’ (PISP)....
The REP018 reporting format, on the face of it, is a simple return to be completed by all Payment Service Providers (PSPs). However, Regulation 98 of the Payment Services Regulations 2017 (PSRs)...
Do you know your Bitcoin from your Blockchain? The world of cryptoassets is highly complex and jargon rich, our glossary explains the key terms of crypto and regulation. crypto regulation glossary
Compliancy Services, one of the UK’s leading providers of regulatory compliance consulting and regtech services, has announced that Dimitrios Sachinidis has joined as a Consultant in its Capital Markets team. Dimitrios joins...
On 20th July 2020, Her Majesty’s Treasury (HMT) published two consultations focused on the promotion of cryptoassets. The consultations were entitled ‘Cryptoasset Promotions’ and ‘Regulatory Framework for Approval of Cryptoasset Promotions’. Each...
On 10 January 2020 businesses that were conducting cryptoasset activity in the UK became subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as...
Payment Institutions and E-Money Institutions struggling to find a safeguarding account in the UK may be unaware of a potential new opportunity as a result of Brexit. But those firms looking to...
Payment and e-money institutions navigating the EEA after the transition period ends At the time of writing, the hope of a UK/EU trade deal upon expiry of the Brexit transition period hangs...
Regularly reviewing your compliance framework not only helps you to ensure you are meeting your regulatory requirements but also provides you with peace of mind that you have the right compliance policies,...
Whilst commentary on the FCA’s updated guidance for payments firms in July focussed mainly on safeguarding and prudential requirements, there was a further, implicit, message for firms that seems to have passed...
Across European Union (EU) member states, there is a wide variation in how investment firms are prudentially supervised. In the UK, for example, there are three prudential sourcebooks for investment firms- BIPRU,...
The passporting regime will cease to continue when the transition period for the UK leaving the European Union (EU) ends on 31 December 2020. From that moment, European Economic Area (EEA) firms...
Capital Market firms are increasingly seeking additional compliance assurance or to outsource some or all of their compliance functionality. It’s being driven by increasing regulatory compliance demands, a spectre of greater personal...
Financial services compliance is certainly not getting any easier, in fact many would argue it is getting more complex. Regulators producing a continuous stream of regulatory updates, consultations and thematic reviews, and...
The Joint Money Laundering Steering Group (JMLSG) recently published a new section to Part II of its Anti Money Laundering/Counter Terrorist Financing (AML/CTF) guidance for the financial services sector. The new section,...
Authorised Payment Institutions (APIs) and E-Money Institutions (EMIs) could be forgiven for not paying attention to the launch of a new consultation last month. But they might be well advised to take...
The Financial Conduct Authority (FCA) announced on 9 July 2020 that they require all E-Money Institutions, and any Payments Institution that is required to arrange an audit of its annual accounts under...
On the 9 July 2020 the Financial Conduct Authority (FCA ) published additional guidance for payment and e-money institutions. This followed a consultation that involved more than 60 organisations including payment firms,...
As COVID-19 continues its hold over the globe discussions on Brexit have, understandably, been relegated in importance. But, the UK stance continues to be fairly dogmatic, insisting that the transition phase will...
On 22 May 2020, the Financial Conduct Authority (FCA) issued a consultation proposing additional temporary guidance to strengthen payment firms’ prudential risk management and arrangements for safeguarding customers’ funds, in view of...
Often touted as an ‘AML Compliance Audit’ or something similar, an external financial crime assurance review provides payment firms with an independent opinion on the adequacy of their policies and procedures, and...
Even during these challenging times, compliance with the regulations is as important as ever for payment services firms. The advent of PSD2, GDPR and 5MLD has come alongside two other important developments....
From the 10th January 2020, the FCA became the Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) supervisor of UK cryptoasset businesses under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the...
Payment Service Providers (PSPs) with permission to provide payment accounts may have or be about to receive a communication from the Financial Conduct Authority (FCA). This requests information about the payment accounts...
Compliancy Services, one of the UK’s leading providers of compliance consultancy and regtech services, has announced that Philip Naughton has joined as Joint Chief Executive Officer, with responsibility for strengthening their consultancy...
Each year in April the Financial Conduct Authority (FCA) publishes its annual business plan and it usually garners much interest. This year it seems to have gone below the radar as firms...
The past 12 months has seen unprecedented Financial Conduct Authority (FCA) supervisory activity in the payments sector. Payment firms ignore this increased regulatory threat at their peril. A high proportion of firms...
In the context of the Covid-19 (Coronavirus) outbreak, financial services regulators have been working with firms to ensure they are responding effectively to the threat of disruption. All firms are expected to...
COVID-19 has caused unprecedented disruption to regulated financial services firms. Having implemented business continuity and crisis management plans these firms will now be discovering just how effective these plans were. It’s important...
The FCA recently released its Sector Views report, a summary of its findings on each sector – areas of investor harm, drivers of change and how each sector is changing. It provides...
The FCA recently released its Sector Views report, a summary of its findings on each sector covering areas of investor harm, drivers of change and how each sector is changing. It provides...
Thursday 28 November 2019 was a proud night for Compliancy Services. Since 2003 it’s been the night that financial services, law, recruitment and compliancy consultancy firms come together to recognise those individuals...
From experience, the following are key to delivering a successful SMCR implementation project: Setting the tone at the top to embed the right culture adopting the spirit, not just the letter of...
The Financial Conduct Authority is busy. In its 2017-18 annual report the regulator highlighted some telling stats on its authorisation activities during that year: over 4,400 applications for authorisation from firms, nearly...
Ben Mason, our CEO, sat down with Mike Barrell from event organisers Juliet Media to discuss regulation of securities, how this is impacting firms in the sector and Compliancy Services can support...
We brought 100 delegates from the crypto sector together with legal and compliance experts to demystify the unfamiliar world of regulation and answer some of their key questions. Watch our video to...
Security Tokens Realised was the first specialist Security Tokens event Compliancy Services has attended (and the first we are aware of.) We were delighted to be Gold Sponsors of what turned out to...
As a newly authorised crypto asset business one of the most important things you’ll need to ensure, right from the start, is that you have set up and embedded your governance, risk...
Getting regulated by the FCA requires you to go through a fairly structured process all of which contribute to your application pack. These are abbreviated in the diagram below. Diagram – Key...
Navigating your way through an application to be authorised by the Financial Conduct Authority can be hazardous. It can seem complicated, especially if you’re a crypto asset entrepreneur or technologist who’s not...
Introduction MIFID II, which went live on 3 January 2018, introduced a significant raft of new rules for the financial services sector in Europe. However, rather than a once-and-for-all set of changes,...