On 23 January 2020, the PRA published a letter that it had sent to Chief Financial Officers of PRA regulated UK deposit takers and international banks. The letter was from Sarah Breeden (Executive Director, UK Deposit Takers Supervision) and David Bailey (Executive Director, International Banks Supervision) and concerns the removal of the bespoke liquidity risk appetite given that the likelihood of the UK leaving the EU without a deal now appears very low. The letter…

On 23 January 2020, the FCA and the Bank of England (BoE) announced that they were establishing a Financial Services artificial intelligence public private forum. The forum will explore the means to support safe adoption of technology within financial services, and whether principles, guidance, regulation and/or industry good practice could support the safe adoption of artificial intelligence and machine learning. Participation in the forum is at the invitation of the FCA and BoE.…

On 23 January 2020, the European Union (Withdrawal Agreement) Bill 2019-20 received Royal Assent becoming the European Union (Withdrawal Agreement) Act 2020 (the Act). Amendments made to the Bill in the House of Lords were overturned by MPs sitting in the House of Commons. Article 126 of the Withdrawal Agreement states that there shall be a “transition or implementation period” which shall start when the agreement enters into force and end on 31 December 2020.…

On 21 January 2020, the European Commission published the opening remarks of Executive Vice-President Valdis Dombrovskis at the ECOFIN press conference. Among other things, Mr Dombrovskis notes that by 10 January 2020, Member States should have transposed the Fifth Anti-Money Laundering Directive. However, there are concerns that some Member States have not yet transposed the Directive and Mr Dombrovskis proposes that the Commission initiate infringement proceedings against them as early as February.  …

On January 10, 2020, the United States (US) imposed economic sanctions on: Iranian sectors that previously had not been specifically targeted, namely the construction, mining, manufacturing and textile sectors; Certain Iranian regime officials; Iran’s largest companies operating in the steel, iron, aluminum, and copper sectors ; and Non-Iranian entities for trade in Iranian metals. Norton Rose Fulbright has prepared a legal update that discusses the implications for both US and non-US persons engaging in any…

On 22 January 2020, the FCA published a Dear CEO letter that outlines its view of the key risks of harm that alternative investment firms pose to their customers or the markets in which they operate. Key messages in the Dear CEO letter include: overall standards of governance, particularly at the level of the regulated entity, generally fall below the FCA’s expectations. Often the appropriateness of investment products for investors is not adequately considered. It…

On 20 January 2020, the FCA published a Dear CEO letter to asset managers setting out the key areas of harm asset managers pose to their customers and markets in which they operate. Overall, the FCA has observed that standards of governance, particularly at the level of the regulated entity, generally fall below its expectations. The FCA’s supervision strategy addressing those key areas are set out below: liquidity management. Where the FCA identifies potential liquidity…