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  • Regulation of Buy-Now Pay-Later products fast approaching

    HM Treasury has published the highly anticipated consultation paper (“CP”) setting out policy options to achieve a proportionate approach to regulation of buy-now-pay-later (“BNPL”) products. Earlier this year, HM Treasury announced its intention to bring interest-free BNPL products within the FCA’s perimeter after the Woolard Review highlighted the probable risk ...
  • Polish FSA issues statement on improper practices in insurance distribution

    In response to irregularities in the application of the Polish Act on Insurance Distribution (implementing an EU Directive) uncovered during audits, the Polish Financial Supervision Authority (PFSA) issued a statement on 1 October 2021, which outlines recommendations in response to crucial distribution issues. The Statement is addressed to insurance undertakings ...
  • Luxembourg: New CSSF Circular on the new EBA guidelines on AML/CTF risk factors

    On 24 September 2021, the CSSF released its Circular 21/782 which (i) provides information on the EBA Guidelines (the “GL”) on customer due diligence (the “CDD”) and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing (“ML/TF”) risk associated with individual business relationships ...
  • Belgium introduces new insurance industry client money and risk transfer rules

    Belgium recently amended legislation on client money rules applicable to Belgian insurance intermediaries, bringing the law in line with regulations found in the EU's Insurance Distribution Directive (IDD), although the rules still contain gaps regarding reinsurance contracts. For years, Belgian insurance law provided for a general regime of risk transfer ...
  • Singapore and UK strengthen cooperation in financial services

    Introduction On 30 June 2021, Singapore and the UK entered into a landmark partnership for cooperation on financial services (Financial Partnership) at the sixth UK-Singapore Financial Dialogue (Financial Dialogue).[1] The Financial Partnership, which follows shortly after the Joint Political Statement on the Singapore-UK Partnership for the Future on 4 March ...
  • FCA consultation on new Diversity and Inclusion Listing Rules

    Over the summer, the FCA announced a consultation on its proposal to introduce a new continuing obligation in the Listing Rules that would require UK and overseas companies with a UK premium or standard listing (subject to certain exemptions) to make annual disclosures relating to whether they meet specific board ...
  • Belgium: Directors of regulated firms can no longer be bound by an employment contract

    Until recently, directors of regulated firms were permitted to serve as directors on a self-employed basis and, at the same time, to perform their operational functions as employees. Those days are now over. This change has involved a number of stages. The first milestone in this reform was the adoption ...
  • New HM Treasury Consultation Response: changing the way financial promotions are approved for unauthorised persons

    On 22 June 2021, HM Treasury (“HMT”) published its response (the “Consultation Response”) to its earlier consultation (the “Consultation”) in July 2020, announcing changes to legislation and the regulatory framework for approving financial promotions for unauthorised persons. 1. Background Currently, authorised firms may approve the financial promotions that are made ...
  • UK Government explores AML reform for Open Banking payment service providers

    On 22 July 2021, HM Treasury published a consultation paper covering various proposed amendments to the UK’s anti-money laundering (AML) framework, including the potential removal of account information services (AIS) from the scope of the Money Laundering Regulations (MLRs). HM Treasury is also inviting feedback on the potential money laundering ...
  • New SM&CR for FMIs proposed by HM Treasury

    HM Treasury is proposing to introduce a Senior Managers and Certification Regime (“SM&CR”) for financial market infrastructures (“FMIs”) to encourage effective governance, incentivise good behaviour and ensure employees give adequate oversight to the areas for which they are responsible. The deadline for responses is 22 October 2021. The FMIs covered ...