Leading insights in financial services
We provide advice across the entire spectrum of financial services, offering valuable insights into the latest regulatory, market, and governance developments. Our expertise spans financial crime and multi-jurisdictional investigations to fintech and sustainability, helping clients navigate the evolving landscape and stay ahead of the curve.
Where legal expertise meets the future of financial markets
The financial services sector is constantly evolving, driven by rapid regulatory change, market innovation and shifting client demands. Freshfields is deeply engaged in these changes, offering expert insights across a wide range of financial services areas.
We provide timely reactions and actionable insights on the latest legal developments, helping clients understand and navigate complex issues from investment trading and governance to financial crime and fintech.
Regulators and regulatory framework
Regulators and regulatory framework
Jan 13 2026
The year ahead in financial services: 12 trends to watch in 2026
2025 was another transformative year for the financial services industry. Geopolitical risks arising from conflicts in Ukraine and...
Dec 23 2025
2025 Bank Regulatory Roundup and What to Look for in 2026
U.S. banking regulation underwent a material reset in 2025. With new leadership at the Federal Reserve, the OCC, and the FDIC, the second...
Dec 16 2025
FCA publishes final rules on non-financial misconduct
Following a policy statement and consultation in July 2025 (see more detail here), the FCA has published its final rules and guidance on...
Dec 12 2025
FCA consults on regulatory regime for ESG ratings providers
In late October, the UK Government published draft legislation to bring Environmental, Social and Governance (ESG) ratings providers into...
Dec 2 2025
From EU legacy to UK innovation: FCA consults on short selling changes
The Financial Conduct Authority (FCA) has published Consultation Paper CP25/29 setting out proposed rules and guidance to implement the...
Nov 21 2025
ESG ratings providers: UK legislation will bring sector within FCA regulation
The UK Government has been working to finalise the legislation required to bring Environmental, Social and Governance (ESG) ratings...
Nov 20 2025
A cautious step forward: the Bank of England’s proposed regime for systemic stablecoins
The Bank of England has published its long-awaited consultation paper on a regulatory framework for sterling-denominated systemic...
Oct 29 2025
Regulating for innovation: the Bank of England’s emerging technology blueprint for the UK financial system
On 15 October 2025, the Bank of England (BoE) published a comprehensive paper outlining its approach to innovation in artificial...
Oct 21 2025
Tokenising the future: FCA consults on progressing fund tokenisation
On 14 October 2025, the FCA published a consultation paper (CP25/28) setting out its proposals to facilitate the adoption of tokenisation...
Oct 16 2025
PRA and FCA announce changes to banker bonuses
In November 2024, the PRA and FCA published a joint consultation proposing changes to the current senior banker remuneration regime for...
Oct 8 2025
Shaping the regulatory landscape for targeted support: FCA consults on consequential Handbook changes to support the new regime
On 26 September 2025, the Financial Conduct Authority (FCA) published a consultation paper (CP25/26) setting out additional changes to...
Oct 7 2025
Navigating the New Regulatory Momentum: AI in UK Financial Services
Artificial intelligence (AI) is already reshaping financial services, but regulators are moving fast to ensure opportunity does not...
Sep 30 2025
Reshaping UK payments regulation: HM Treasury consults on consolidating the PSR within the FCA
The UK's payments landscape is on the cusp of significant regulatory change. In March 2025, the UK government announced that it would...
Sep 26 2025
FCA invites discussion on applying its Handbook to cryptoasset firms
The UK Financial Conduct Authority (FCA) published a consultation and discussion paper on 17 September 2025 outlining its proposals for...
Sep 26 2025
FCA publishes proposals for applying its Handbook to cryptoasset firms
The UK Financial Conduct Authority (FCA) published a consultation paper on 17 September 2025 outlining its proposals for applying the...
Jul 17 2025
The UK government’s new financial services strategy: a catalyst for growth?
On the evening of Tuesday 15 July 2025, the Chancellor of the Exchequer, Rachel Reeves, delivered her second Mansion House speech, in...
Jul 15 2025
FCA confirms new 75% threshold for further issuances
The FCA has today published final rules to implement the new public offers and admissions to trading regime (in PS 25/9, following its...
Jul 15 2025
UK Government and regulators announce reforms to the Senior Managers and Certification Regime
In 2023, the Financial Conduct Authority (the FCA) and the Prudential Regulation Authority (the PRA) published a joint discussion paper...
Jul 10 2025
E-money and payment firms face FCA scrutiny over risk management and wind-down planning
On 20 June 2025, the Financial Conduct Authority (FCA) published its findings following a multi-firm review into risk management and...
Jun 23 2025
How (not) to regulate for growth: House of Lords committee report on the UK regulators’ secondary international competitiveness and growth objective
On 13 June 2025, the House of Lords Financial Services Regulation Committee (the Committee) published its report on the secondary...
Jun 23 2025
How (not) to regulate for growth: House of Lords committee report on the UK regulators’ secondary international competitiveness and growth objective
On 13 June 2025, the House of Lords Financial Services Regulation Committee published its report on the secondary international competitiveness and growth objective for the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) (the Report).
Apr 11 2025
German Election #6: The coalition agreement of the new German government - what’s in it for financial services?
On April 9, 2025, the CDU, CSU, and SPD parties unveiled their coalition agreement, setting out the plans of the new government for the...
Mar 31 2025
The FCA’s plans for the next 5 years: rebalancing risk, supporting growth
On 25 March 2025, the FCA published its new strategy for the next five years, with the stated goals of “deepening trust, rebalancing...
Mar 20 2025
UK Government goes full throttle on its growth agenda: New action plan targets financial services regulators
On 17 March 2025, the UK Government published a policy paper and accompanying press release outlining a new approach to ensure regulators...
Feb 13 2025
Freshfields' geopolitical monitor
Geopolitical risks are a significant concern for businesses and investors in the current global landscape. Understanding these risks is...
Jul 17 2025
The FCA and HM Treasury proposals for targeted support: Navigating the opportunities and challenges of the new regime
Mar 10 2025
Risen from the Ashes: FIDA trilogue set to move forward
The EU is committed to bringing the wider financial sector into the digital age. To this end, it has proposed a new framework for secure...
Mar 10 2025
FCA sets out supervision priorities for asset managers and alternatives firms
On 26 February 2025, the Financial Conduct Authority (FCA) published a portfolio letter addressed to CEOs of firms in the asset...
Mar 7 2025
FCA review of ongoing advice services
On 24 February, the Financial Conduct Authority (FCA) published the findings from its review of ongoing advice services provided by 22 of...
Feb 25 2025
The rise of audits as a regulatory tool for tech
As technology evolves, so do challenges in effectively regulating it. In an era where there is increasing focus on effective oversight of...
Feb 25 2025
The FCA reports on climate change adaptation challenges for UK financial services firms
The FCA identifies climate adaptation challenges for financial services firms Every five years, the UK government produces an assessment...
Feb 17 2025
Data Act: Commission issues updated FAQ
To aid in the implementation of the EU Data Act, the European Commission has released a set of frequently asked questions (FAQ). For a...
Feb 13 2025
The UK Government’s Strategic Steer to the CMA: Impact on UK M&A (Part 2)
Today, the UK government issued its draft strategic steer to the Competition & Markets Authority (CMA) for consultation. Our separate...
Feb 13 2025
The UK Government’s Strategic Steer to the CMA: Resetting the priorities (Part 1)
Today, the UK government issued its draft strategic steer to the Competition & Markets Authority (CMA) for consultation. Why does the...
Feb 13 2025
Freshfields' geopolitical monitor
Geopolitical risks are a significant concern for businesses and investors in the current global landscape. Understanding these risks is...
Feb 7 2025
The new UK regime for public offer platforms: the FCA consults on further proposals
An important element of the UK’s new public offers and admissions to trading regime is the introduction of the public offer platform...
Jan 28 2025
10 Key MedTech Themes for 2025
Note: this article originally ran in MedCity News The MedTech industry is accelerating at an unprecedented pace. As AI reshapes the...
Jan 27 2025
Life sciences – what to watch in 2025
We asked more than 200 Freshfields lawyers – across geographies and practice areas: what are the 1-2 issues top of mind for you and your...
Jan 21 2025
The first significant overhaul of the UK clinical trials regime in two decades begins to take shape
In brief: On 12 December 2024, draft legislation to amend the Medicines for Human Use (Clinical Trials) Regulations 2004 was laid before...
Jan 14 2025
The year ahead in financial services: 10 trends to watch in 2025
2024 was a momentous year for the financial services industry. Financial institutions had to deal with geopolitical risks arising from...
Jan 13 2025
“Regulating for growth” – the UK’s vision for financial services in 2025 and beyond
The new Labour government has placed financial services at the centre of its plans to grow the UK economy, and UK regulators have an...
Jan 2 2025
MiCAR perimeter issues – tokenized deposits and payment services
As far as MiCAR is concerned, December 2024 was a busy month for both market participants and competent authorities. On 17 December 2024,...
Dec 20 2024
FCA publishes discussion paper on admissions and disclosures and the market abuse regime for cryptoassets
On 16 December 2024 the FCA published its much-anticipated Discussion Paper on (i) cryptoasset admissions and disclosures and (ii) the...
Dec 18 2024
Harnessing Smart Data in the UK as a National Asset: What businesses need to know
On 23 October 2024 the UK government introduced the Data (Use and Access) Bill to Parliament (the DUAB). The DUAB is a wide-ranging and...
Dec 2 2024
Regulating cryptoassets in the UK: a guide to the road ahead
Finally! Avid readers of Freshfields blogs might remember from our post last autumn that the UK government and financial regulators in...
Nov 25 2024
The FCA/FOS Consultation – “Modernising the Redress System” A Chance for Reform?
At a Glance On 15 November 2024, the FCA and FOS jointly published a call for input as to how the FOS might improve its redress...
Nov 20 2024
Your 3-month trial: Consultation on new UK rules for consumer subscriptions
For the next three months, the UK Government will consult on new rules for consumer subscription contracts, which are due to come into...
Oct 29 2024
Government set to bring Buy-Now, Pay-Later firms under FCA regulation
On 17 October 2024, HM Treasury launched its third consultation on the proposed regulation of Buy-Now, Pay-Later (BNPL) credit...
Oct 25 2024
UK announces data reforms: what businesses need to know
On 23 October 2024 the UK government introduced the Data (Use and Access) Bill to Parliament (the DUAB). The DUAB is a wide-ranging and...
Oct 24 2024
Leading the Change: 2025 Data Law Trends report
We’re excited to share our latest report, Leading the Change: 2025 Data Law Trends. Data now impacts all aspects of businesses, from...
Oct 21 2024
Out of the shadows: the growing regulatory spotlight on private capital
In recent months, there has been significant media coverage on the growing regulatory scrutiny of the private capital sector. In this...
Oct 21 2024
The worldwide focus on operational resilience in financial services: what firms and service providers need to know
Regulators around the world have long been concerned about the operational resilience of banks and other financial institutions, and the...
Oct 4 2024
Consumers at the core of the new European Commission mandate: paving the way for a new ‘Digital Fairness Act’
On 3 October the European Commission published its long-awaited Digital Fairness Fitness Check report (see link here). Based on the...
Oct 3 2024
Next steps for UK product regulation – the new Product Regulation and Metrology Bill
The OPSS (Office for Product Safety and Standards - the UK’s product safety regulator) proposed an overhaul of the UK’s current product...
Oct 1 2024
EU Commission publishes practical guide on an evolving EU digital economy
Aiming to encourage voluntary data sharing for business and citizen benefits through secure and trustworthy exchanges, the Data...
Prudential requirements
Prudential requirements
May 30 2025
Responsible Openness Revisited: The PRA's Evolving Framework for International Bank Supervision
On 20 May 2025, the Prudential Regulation Authority (PRA) published a Policy Statement (PS6/25) and updated Supervisory Statement...
May 15 2025
FCA's new consultation on the definition of capital for FCA investment firms
On 24 April 2025, the FCA released a consultation paper CP 25/10 on the definition of capital for FCA investment firms. The FCA says it...
May 22 2024
The PRA’s thematic review of private equity related financing activities in the UK
Late last month, the PRA published a Dear CRO letter which sets out the main findings of its thematic review into UK regulated banks’...
Mar 15 2024
Failing to prepare or preparing to fail – PRA policy statement on solvent exit planning for non-systemic banks and building societies
In a 2021 speech, Sam Woods, the CEO of the UK’s Prudential Regulation Authority (PRA), stated that one of the regulator’s focuses for...
Nov 1 2023
Regulatory capital, liquidity and resolution planning for banks: recent developments and cross-border perspectives
Following the failure of Silicon Valley Bank (SVB) and several other U.S. small and mid-sized banks in March 2023, U.S. regulators have...
Jul 24 2023
Investment funds: an evolving front line in macroprudential regulation
Regulators and standard-setters, domestic and international, are worrying about the potential for investment funds to pose risks to...
Apr 27 2023
TPR and FCA publish guidance following 2022 LDI crisis
On Monday 24 April 2023 both the Pensions Regulator (TPR) and the Financial Conduct Authority (FCA) issued new guidance on leveraged...
Apr 27 2023
Lessons from the TSB IT Migration on Senior Management Responsibility
The recent Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) reform of regulations applying to operational...
Mar 8 2023
PRA consultation on Phase 1 of a “simpler regime” – A further step on the road to graduated prudential regulation in the UK
Following its previous work on a new “strong and simple” prudential framework for non-systemic UK banks and building societies (see our...
Oct 5 2022
ESG and more - BaFin updates its MaRisk
On 26 September 2022, the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin)...
Oct 3 2022
ESG in EU prudential regulation: is the framework ready for environmental risks?
The European Banking Authority (EBA) published an insightful discussion paper in May 2022 on the role of environmental risks in the EU...
Jun 23 2022
How to manage and supervise climate-related financial risks – a view from the Basel Committee
The Basel Committee on Banking Supervision (BCBS) has published its “Principles for the effective management and supervision of...
May 19 2022
Financial Services exclusion from the OECD pillar one proposals
The OECD has published a consultation on the exclusion of certain Financial Services entities from pillar one of its two-pillar solution...
Governance
Governance
Jul 15 2025
UK Government and regulators announce reforms to the Senior Managers and Certification Regime
In 2023, the Financial Conduct Authority (the FCA) and the Prudential Regulation Authority (the PRA) published a joint discussion paper...
Dec 16 2024
Financial rewards for whistleblowers in the UK - the calls for reform grow louder
The drumbeat of calls for the UK to introduce a programme of whistleblower incentivisation continues to grow louder. In our view, a...
Jul 31 2024
Changes to the UK Stewardship Code seek to ease the burdens on signatories and support the growth of UK capital markets
On 22 July 2024, the Financial Reporting Council (FRC) announced several immediate revisions to the UK Stewardship Code 2020 in order to...
Jul 18 2024
EU Elections Unpacked: Ursula von der Leyen re-elected for second term
Germany's Ursula von der Leyen has been elected President of the European Commission for a second mandate, with 401 votes in favour, 284...
Oct 6 2023
PRA and FCA proposals on diversity & inclusion and non-financial misconduct seek to drive change in the UK financial sector
PRA and FCA proposals on diversity & inclusion and non-financial misconduct seek to drive change in the UK financial sector On 25...
May 2 2023
Review of the UK Senior Managers & Certification Regime: the increasing focus on international competitiveness
On 30 March 2023, the Financial Conduct Authority (the FCA) and the Prudential Regulation Authority (the PRA) published a joint...
Apr 27 2023
Lessons from the TSB IT Migration on Senior Management Responsibility
The recent Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) reform of regulations applying to operational...
Jun 23 2022
How to manage and supervise climate-related financial risks – a view from the Basel Committee
The Basel Committee on Banking Supervision (BCBS) has published its “Principles for the effective management and supervision of...
Jun 14 2022
HMT proposals on critical third parties
On the critical list HM Treasury’s (HMT) policy statement on critical third parties (CTPs) to the finance sector e.g. cloud services...
Investment trading and markets
Investment trading and markets
Jan 19 2026
The new UK public offers and admissions to trading regime: some top tips for capital market participants
The long-awaited moment has finally arrived… the UK’s new public offers and admissions to trading regime is now in place. The Public...
Feb 13 2025
Freshfields' geopolitical monitor
Geopolitical risks are a significant concern for businesses and investors in the current global landscape. Understanding these risks is...
Aug 7 2024
FCA consults on derivatives trading obligation and post-trade risk reduction services
On 26 July 2024, the Financial Conduct Authority (FCA) published a consultation paper (CP24/14) with proposals on three different but...
Jul 18 2024
EU Elections Unpacked: Ursula von der Leyen re-elected for second term
Germany's Ursula von der Leyen has been elected President of the European Commission for a second mandate, with 401 votes in favour, 284...
Dec 8 2023
Maintaining ‘orderly’ markets in disorderly times: the English High Court finds in the LME’s favour in relation to the nickel crisis
In a judgment that will be of interest to exchanges and those who trade on them, the English High Court dismissed judicial review...
Nov 9 2023
UK FCA’s Market Watch 75 – potential market abuse in market soundings
On 31 October 2023, the Financial Conduct Authority (FCA) issued Market Watch 75, in which it raised concerns over possible abuses of the...
Jul 21 2023
Understanding the definition of investment advice under MiFID – ESMA revises 13-year-old guidance
It has been a while since the CESR guidelines on “Understanding the definition of advice under MiFID” were published. To be precise, 13...
Jul 7 2023
Feels like MiFID III? - The Commission Proposal on the EU Retail Investment Strategy and what it means for firms
In the heated discussion around the ban on payment for order flow, the proposal on the Retail Investment Package (the Proposal), adopted...
Aug 2 2022
Building a more permanent sandcastle in the FMI sandbox
In April 2022, in the response to its consultation on regulatory approach to, among other things, distributed ledger technology (DLT) in...
Jun 8 2022
Does history repeat itself in market misconduct?
The Financial Markets Standards Board (FMSB) believes so. Or at least the recent FMSB report indicates that there are common broad...
Markets and clearing (CCPs)
Markets and clearing (CCPs)
Apr 3 2025
Regulating regulators – The UK FCA’s first fine imposed on a Recognised Investment Exchange
In its first enforcement decision relating to a Recognised Investment Exchange, the FCA has published a final notice and imposed a...
Feb 13 2025
Freshfields' geopolitical monitor
Geopolitical risks are a significant concern for businesses and investors in the current global landscape. Understanding these risks is...
Aug 7 2024
FCA consults on derivatives trading obligation and post-trade risk reduction services
On 26 July 2024, the Financial Conduct Authority (FCA) published a consultation paper (CP24/14) with proposals on three different but...
Dec 8 2023
Maintaining ‘orderly’ markets in disorderly times: the English High Court finds in the LME’s favour in relation to the nickel crisis
In a judgment that will be of interest to exchanges and those who trade on them, the English High Court dismissed judicial review...
Aug 2 2022
Building a more permanent sandcastle in the FMI sandbox
In April 2022, in the response to its consultation on regulatory approach to, among other things, distributed ledger technology (DLT) in...
Retail markets
Retail markets
Jan 5 2026
FCA unveils near-final rules for targeted support in pensions and retail investments
On 11 December 2025, the Financial Conduct Authority (FCA) published a policy statement (PS25/22), outlining near-final rules for a new...
Oct 20 2025
FCA refines Consumer Duty
On 30 September 2025, the FCA released a series of important updates on the Consumer Duty: A letter to the Chancellor of the Exchequer,...
Sep 17 2025
Further developments on the retrieval duty in the context of APP fraud
The retrieval duty has resurfaced in the High Court’s recent judgment in Barclay-Ross v Starling Bank Limited. The possibility of banks...
Aug 4 2025
Motor finance: what now?
The UK Supreme Court’s decision on 1 August created general relief in the financial services industry, particularly for car dealers who...
Jul 28 2025
The DPC Frontier: FCA Charges Ahead on Regulating Buy Now, Pay Later
In our previous blog post (here) on Buy Now, Pay Later (BNPL), we examined the UK Government’s proposals to bring interest-free BNPL...
Jul 17 2025
The FCA and HM Treasury proposals for targeted support: Navigating the opportunities and challenges of the new regime
Apr 7 2025
Consumer protection provisions of the UK DMCCA and the CMA’s new enforcement powers are now in force
The majority of the consumer protection provisions of the landmark Digital Markets, Competition and Consumers Act (the DMCCA) went live...
Mar 28 2025
The FCA’s Consumer Duty rule review: a spring clean, but no overhaul
One oft-criticised feature of the UK financial services regime is the complexity and the volume of the FCA’s handbook of rules and...
Mar 27 2025
Retrieval duty rejected: Court dismisses new duty for receiving banks in APP fraud
The High Court’s recent judgment in Santander UK PLC v CCP Graduate School Ltd provides an important clarification of the duties owed by...
Mar 20 2025
The CMA announces enforcement priorities with weeks to go before the DMCCA’s new consumer regime comes into force
With just over two weeks to go until most of the Digital Markets Competition and Consumers Act 2024’s (DMCCA) consumer protection...
Feb 5 2025
UK FCA sets out key expectations of payments firms in “Dear CEO” letter
On 3 February 2025, the UK’s Financial Conduct Authority (FCA) published a Dear CEO letter to payments firms that are supervised by the...
Nov 13 2024
FCA reviews implementation of Consumer Duty in payments firms
Last month, the Financial Conduct Authority (FCA) published its key findings from a review of 23 payments firms’ implementation of the...
Jul 4 2024
Digital or printed? Navigating liability and evidence in product instruction and safety information
I. Introduction Manufacturers of consumer-facing products in the increasingly integrated European market operate in a complex...
Mar 26 2024
Trends in fintech: our EU predictions for 2024
As we did in 2021, 2022, 2023 we have crowdsourced some fintech predictions for the year ahead from the EU Freshfields Fintech team,...
Jan 3 2024
Mind the UK ‘advice gap’: Considering the Advice Guidance Boundary Review
On 8 December 2023, HM Treasury (HMT) and the FCA published a joint policy paper (DP23/5) on the Advice Guidance Boundary Review (the...
Nov 19 2023
Investing like the pros – indirect investments by retail investors in investment funds for (semi-)professionals under BaFin’s scrutiny
Both the desire for higher yields and the low interest rate environment of the past years has seen retail investors’ focus increasingly...
Aug 9 2023
The FCA publishes its Action Plan on Cash Savings
On 31 July 2023, the FCA published its Cash Savings Market Review 2023. In order to combat high inflation in the UK (currently at 7.9%)...
Jul 21 2023
Understanding the definition of investment advice under MiFID – ESMA revises 13-year-old guidance
It has been a while since the CESR guidelines on “Understanding the definition of advice under MiFID” were published. To be precise, 13...
Jul 7 2023
Feels like MiFID III? - The Commission Proposal on the EU Retail Investment Strategy and what it means for firms
In the heated discussion around the ban on payment for order flow, the proposal on the Retail Investment Package (the Proposal), adopted...
May 25 2023
The UK FCA’s latest Financial Lives Survey spotlights the rise in vulnerable customers
The FCA’s focus on vulnerable customers is longstanding. In the aftermath of the Covid-19 pandemic, the ongoing cost of living crisis,...
May 11 2023
Are UK retail banks capitalising on customer inertia on savings rates? The FCA makes its approach known in advance of the consumer duty
Although the FCA’s new Consumer Duty is not yet in force, the regulatory environment is already shifting. For example, the FCA has stated...
Jan 10 2023
Retail Financial Services: Five Key Themes on the FCA’s Agenda
The issue front and centre of the Financial Conduct Authority’s (FCA) 2022 Annual Public Meeting was the cost of living crisis. At that...
Sep 30 2022
The UK FCA’s latest ‘Dear CEO’ letter: insurers, consumers, SMEs and the cost of living crisis
The anticipated cost of living crisis is here, and yesterday’s ‘Dear CEO’ letter to insurers confirms the FCA’s return to a theme it...
Financial crime
Financial crime
Nov 19 2025
FCA flags weaknesses in financial crime & client categorisation
On 20 October 2025, the FCA published key observations from a multi-firm review and survey responses, focusing on: financial crime...
Nov 17 2025
FCA highlights shortcomings in UK firms’ financial crime risk assessments
The FCA has published the findings of a thematic review into how firms manage financial crime risk. The review focused on business-wide...
Oct 17 2025
OFSI Publishes Annual Review 2024-25
On 15 October 2025, the Office of Financial Sanctions Implementation (OFSI) published, alongside guidance on who is subject to financial...
Jun 11 2025
Navigating AML Risks in M&A: Implications of the New EU AML Package
Anti-money laundering (AML) risk is no longer a peripheral concern in M&A – it’s a central deal issue. As enforcement ramps up across...
Aug 5 2025
Financial crime reforms: Creating new risks and challenges for firms
Mar 24 2025
New sanctions legislation targeting sanctions circumvention – what does this mean for financial institutions?
Following Russia’s invasion of Ukraine in 2022, the EU has drastically tightened sanctions against Russia. Preventing the circumvention...
Feb 26 2025
UK Publishes Financial Services Sector Threat Assessment for Financial Sanctions
The UK’s Office of Financial Sanctions Implementation (OFSI) has published a financial services sector threat assessment, to help UK...
Feb 5 2025
UK FCA sets out key expectations of payments firms in “Dear CEO” letter
On 3 February 2025, the UK’s Financial Conduct Authority (FCA) published a Dear CEO letter to payments firms that are supervised by the...
Jan 21 2025
Freshfields Fintech: Our Predictions for 2025
As we did in 2021, 2022, 2023 and 2024, we have crowdsourced predictions for the year ahead from the Freshfields global fintech team....
Dec 16 2024
Financial rewards for whistleblowers in the UK - the calls for reform grow louder
The drumbeat of calls for the UK to introduce a programme of whistleblower incentivisation continues to grow louder. In our view, a...
Nov 7 2024
Time is ticking for the Failure to Prevent Fraud offence coming into force
On 6 November 2024, the UK Government published final guidance on what constitute reasonable prevention procedures (the “Guidance”), on...
Oct 31 2024
Penny for your thoughts? A US and UK take on incentivising financial crime reporting
On both sides of the Atlantic, law enforcement agencies are showing increasing interest in using incentivisation as a means to detect...
Sep 25 2024
FCA consultation on publicising investigations: Talks to resume
After a few months of silence (the FCA’s promise to listen to the “extensive feedback” it had received at the consultation’s close in...
Aug 22 2024
The new European AML package - a comprehensive overview
Few areas of regulatory law are evolving as rapidly as European money laundering law. Over the past few years these requirements have...
Jul 10 2024
AML compliance in the UK: Court of Appeal Decision throws a spotlight on the adequate consideration exemption
A recent Court of Appeal decision [1] on the UK Proceeds of Crime Act (POCA) has provoked significant interest given its focus on the...
Jul 5 2024
Global enforcement trends to tackle money laundering
Legislators, regulators and law enforcement authorities are increasing their efforts to detect and combat money laundering. Although this...
May 29 2024
Federal Agencies Propose Customer Identification Program Requirements for Investment Advisers: Another Step Toward Comprehensive AML/CFT Regulation
On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN) and the US Securities and Exchange Commission (the SEC) took another...
May 13 2024
Update: The EU keeps the ball rolling in its battle against money laundering – next on the agenda: professional football
Professional football is not just an entertaining happening for millions of fans around the world; it is also a big money game. During...
Apr 24 2024
From PSD2 to PSD3 and PSR – European Parliament sets out its vision on the future of payments
The payments landscape has undergone significant changes over the past decade, changes driven by fast-paced technological advancements...
Apr 12 2024
The UK FCA’S Business Plan 2024/25: Five Takeaways for Financial Institutions
At a Glance The UK’s Financial Conduct Authority (the FCA) has recently published its Business Plan for 2024/25, setting out its...
Mar 6 2024
'De-banking’ claim against Revolut struck out as an abuse of process
In the recent case of Uzbekov v Revolut, the English High Court struck out a breach of contract claim brought by Mr Uzbekov following...
Nov 29 2023
Fund transfers, crypto-assets and AML/CTF – the European Banking Authority’s take on the ‘Travel Rule’
Fund transfers, crypto-assets and AML/CTF – the European Banking Authority’s take on the ‘Travel Rule’ The fight against money laundering...
Nov 7 2023
Economic crime and corporate transparency: Significant company law changes and new offences
The Economic Crime and Corporate Transparency Act 2023 which received Royal Assent on 26 October is aimed at preventing the abuse of UK...
Sep 15 2023
The cost of a £250 withdrawal: latest UK sanctions developments
The UK Office of Financial Sanctions Implementation (OFSI) recently issued its first “disclosure notice” and, on the same day, updated...
Jun 21 2023
A further expansion of the UK corporate crime enforcement toolkit
In a nutshell Recent amendments to the UK's Economic Crime and Corporate Transparency Bill (the Bill), announced on 15 June, could...
May 30 2023
Works council remuneration remains in spotlight in Germany
In January of this year, the German Federal Court of Justice (Bundesgerichtshof – BGH) ruled in on the unduly high remuneration granted...
Apr 6 2023
A Speedboat for AML enforcement
In August 2022, Germany’s finance minister, Christian Lindner, announced a new federal agency, the Higher Federal Authority for Combating...
Oct 11 2022
AML update: Germany needs to pick up speed
It is said to have been one of the hottest summers in Germany since weather records were kept - the heated atmosphere in the money...
Jul 29 2022
FCA enforcement action on Russian sanctions
Given the exceptional scale and speed with which sanctions were implemented against Russia by the UK Government, the FCA and the Office...
Jun 8 2022
Does history repeat itself in market misconduct?
The Financial Markets Standards Board (FMSB) believes so. Or at least the recent FMSB report indicates that there are common broad...
May 11 2022
The Queen’s Speech – what next for UK financial services?
The 2022 Queen’s Speech contained details of two proposed Bills that will impact the financial services community. The Financial Services...
Feb 9 2022
Global Enforcement Outlook: Anti-money laundering trends to watch
Given the opportunities for money laundering, fraud and other financial crime that government responses to the pandemic presented, it is...
Investigations and enforcement
Investigations and enforcement
Nov 6 2025
UK Court of Appeal requires FOS to reduce award in successful JR challenge
In Linear Investments Ltd v Financial Ombudsman Service Ltd [2025] EWCA Civ 1369, the Court of Appeal considered a judicial review...
Jun 11 2025
Navigating AML Risks in M&A: Implications of the New EU AML Package
Anti-money laundering (AML) risk is no longer a peripheral concern in M&A – it’s a central deal issue. As enforcement ramps up across...
Apr 3 2025
Regulating regulators – The UK FCA’s first fine imposed on a Recognised Investment Exchange
In its first enforcement decision relating to a Recognised Investment Exchange, the FCA has published a final notice and imposed a...
Mar 21 2025
The High Court affirms the FCA’s wide discretion in exercising its powers of redress
At a Glance On 7 March 2025, the High Court dismissed an application for judicial review by the All-Party Parliamentary Group on Fair...
Mar 20 2025
The CMA announces enforcement priorities with weeks to go before the DMCCA’s new consumer regime comes into force
With just over two weeks to go until most of the Digital Markets Competition and Consumers Act 2024’s (DMCCA) consumer protection...
Mar 13 2025
FCA publicity consultation: Back to where we started?
The FCA yesterday announced that it will not be pursuing much of its controversial proposed policy on publicising investigations (which...
Feb 24 2025
SUPPLY CHAINS AND LABOUR EXPLOITATION: THE NEW INVESTIGATIVE AND LITIGATION TREND?
Introduction Supply chains are under the radar of public prosecutor offices, other governmental authorities, including the competition...
Feb 6 2025
FCA publicity consultation: ‘How not to regulate’
The House of Lord’s Financial Services Regulation Committee has today published its report on the FCA’s publicity consultation, Naming...
Jan 22 2025
UK financial services enforcement themes and looking ahead
Although 2024 has not seen a return to the levels of fines and outcomes of the pre-financial crisis era, there has been a notable uptick...
Dec 19 2024
Secret Commissions – Supreme Court to hear appeal
The Court of Appeal’s decision On 25 October 2024, the Court of Appeal handed down its judgment in three linked appeals – Johnson v...
Nov 29 2024
FCA publicity consultation – take 2: A solution to one of the FCA’s problems?
The FCA yesterday published its revised proposals to publicise enforcement investigations. Reactions to the original proposals both from...
Nov 21 2024
When is it Wise to report non work-related conduct issues to the UK FCA?
A recent UK FCA decision highlights the FCA’s expectation that, in certain circumstances, issues relating to the conduct of senior...
Nov 7 2024
Time is ticking for the Failure to Prevent Fraud offence coming into force
On 6 November 2024, the UK Government published final guidance on what constitute reasonable prevention procedures (the “Guidance”), on...
Oct 14 2024
Redressing the UK FCA’s power to impose consumer redress schemes
In a recent decision, the UK Court of Appeal confirmed that the FCA can impose a redress requirement on an FCA-regulated firm without...
Sep 20 2024
Business Judgement Rule Decisions – A How-To Guide
In today’s dynamic business environment, decision-making frequently entails venturing into unknown territory. It is often challenging to...
Aug 22 2024
The new European AML package - a comprehensive overview
Few areas of regulatory law are evolving as rapidly as European money laundering law. Over the past few years these requirements have...
Aug 19 2024
Strategic risk spotlight on EU-China investigations: How to reconcile EU investigations with Chinese law in light of recent EU General Court order
In an order dated 12 August 2024, the General Court of the European Union (‘General Court’) dismissed an application for interim measures...
Jun 11 2024
The UK’s digital roadmap: CMA consults on draft digital markets guidance
Within minutes of the UK Digital Markets, Competition and Consumers Act 2024 (the DMCC Act) receiving Royal Assent on the evening of 24...
May 24 2024
Across the finish line in the wash-up: the DMCC Act receives Royal Assent – what happens next?
In the final days of Parliament, the landmark UK Digital Markets, Competition and Consumers Act 2024 (the ‘Act’) has received Royal...
May 2 2024
FCA consultation on publicising investigations: The strength to let go – will the FCA reconsider ‘naming and shaming’?
The consultation period for CP24/2 closed on Tuesday, marking the end of (at least the first phase of) what has been widely perceived to...
Apr 12 2024
The UK FCA’S Business Plan 2024/25: Five Takeaways for Financial Institutions
At a Glance The UK’s Financial Conduct Authority (the FCA) has recently published its Business Plan for 2024/25, setting out its...
Feb 29 2024
FCA consultation on publicising investigations: Balancing transparency and collateral damage?
On 27 February 2024, the FCA announced a consultation on proposed amendments to its existing enforcement policy. These include proposals...
Feb 14 2024
Sexism in the City: the FCA's latest efforts to tackle non-financial misconduct in the workplace
The FCA has taken another notable step as part of its efforts to crack down on non-financial misconduct in the workplace. As we noted in...
Feb 12 2024
New market investigation powers of the Italian Antitrust Authority - Council of State confirms they apply to all economic sectors
In its opinion of 29 January 2024, the Italian Council of State (CdS) published its views on the scope of application of the new market...
Feb 7 2024
FCA enforcement - Not the only show in town
We have published an article on recent UK financial services enforcement and emerging trends. There has been a decline in the number and...
Feb 6 2024
UK PRA updates its enforcement policies – but will this mean faster investigations and a change in penalty levels?
Following a consultation last year, the Bank of England policy statement (PS01/24) introduces changes to the Prudential Regulation...
Dec 11 2023
Compliance duties on German boards – 10 years on from the landmark decision in Siemens v. Neubürger
Introduction Yesterday (10 December 2023) was the tenth anniversary of what must be the most cited decision when it comes to board-level...
Sep 25 2023
A new toolkit for gender-inclusive competition law
Until recently, competition policy has been considered through a gender-neutral lens – focused on “average” consumers, characterised by...
Sep 15 2023
The cost of a £250 withdrawal: latest UK sanctions developments
The UK Office of Financial Sanctions Implementation (OFSI) recently issued its first “disclosure notice” and, on the same day, updated...
Sep 14 2023
Russia Sanctions: Forced administration of subsidiaries of Western groups in Russia
Over the course of the last months, the Russian government has ramped up its “countermeasures” intended to counteract the effect of...
Jul 11 2023
Germany Turning Up the Heat on Malfunctioning Markets (but which ones?)
Lawmaking in Germany can be turbulent at times but the German Bundestag – i.e., the parliamentary groups of the ‘traffic light coalition’...
Jun 21 2023
A further expansion of the UK corporate crime enforcement toolkit
In a nutshell Recent amendments to the UK's Economic Crime and Corporate Transparency Bill (the Bill), announced on 15 June, could...
May 30 2023
Works council remuneration remains in spotlight in Germany
In January of this year, the German Federal Court of Justice (Bundesgerichtshof – BGH) ruled in on the unduly high remuneration granted...
Apr 27 2023
Lessons from the TSB IT Migration on Senior Management Responsibility
The recent Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) reform of regulations applying to operational...
Apr 6 2023
A Speedboat for AML enforcement
In August 2022, Germany’s finance minister, Christian Lindner, announced a new federal agency, the Higher Federal Authority for Combating...
Mar 30 2023
Unexpected amendments to EU guidance on abuse of dominance: back to the future?
In a surprise move, the European Commission has published a revised version of its 2008 guidance on enforcement priorities for abusive...
Mar 20 2023
Antitrust enforcers’ attention on labor markets spreading across the globe: a new legal battlefield?
Antitrust enforcement in labor markets has gained momentum in recent months as agencies in the US, Europe and Asia signal tougher...
Jul 29 2022
FCA enforcement action on Russian sanctions
Given the exceptional scale and speed with which sanctions were implemented against Russia by the UK Government, the FCA and the Office...
Feb 9 2022
Global Enforcement Outlook: Anti-money laundering trends to watch
Given the opportunities for money laundering, fraud and other financial crime that government responses to the pandemic presented, it is...
Jan 25 2022
UK financial services enforcement – Themes and a landmark decision
The FCA’s first criminal prosecution of a bank, which was also its first prosecution for breaches of the UK’s Money Laundering...
Financial services litigation
Financial services litigation
Dec 17 2025
UK Banking litigation in focus: Navigating recent cases and trends
Over the past six months, we have seen a number of significant banking litigation cases before the English courts and other legal...
Aug 4 2025
Motor finance: what now?
The UK Supreme Court’s decision on 1 August created general relief in the financial services industry, particularly for car dealers who...
May 23 2025
UK Banking litigation in focus: Recent cases and emerging trends
In the last 6 months, we have seen a range of important cases and developments before the Courts in the UK affecting financial...
Mar 27 2025
Retrieval duty rejected: Court dismisses new duty for receiving banks in APP fraud
The High Court’s recent judgment in Santander UK PLC v CCP Graduate School Ltd provides an important clarification of the duties owed by...
Jan 28 2025
Bifurcated representative actions in shareholder claims rejected by the Court of Appeal
The English Court of Appeal has rejected the use of a bifurcated representative procedure to bring shareholder claims under section...
Nov 8 2024
UK Banking Litigation Update
So far this year we’ve seen a range of important cases and developments before the Courts in the UK affecting financial institutions. In...
Oct 23 2024
English High Court implies an alternative reference rate in post-LIBOR test case
The decision in Standard Chartered v Guaranty Nominees [2024] EWHC 2605 (Comm) considers how to interpret contractual provisions...
Oct 18 2024
The English Court of Appeal upholds dismissal of LME nickel crisis claims
The English Court of Appeal dismissed an appeal of the High Court’s judgment in favour of the London Metal Exchange (LME) and LME Clear,...
Oct 18 2024
The new leading decision procedure – a relief for the judiciary and an increase in efficiency in mass claims proceedings?
Today, the German Federal Council (Bundesrat) passed the law already adopted by the German Parliament (Bundestag) to introduce a new...
Oct 14 2024
Redressing the UK FCA’s power to impose consumer redress schemes
In a recent decision, the UK Court of Appeal confirmed that the FCA can impose a redress requirement on an FCA-regulated firm without...
Sep 25 2024
FCA consultation on publicising investigations: Talks to resume
After a few months of silence (the FCA’s promise to listen to the “extensive feedback” it had received at the consultation’s close in...
Apr 8 2024
High Court hands down its first judgment on the Quincecare duty since Philipp
The High Court’s recent judgment in CCP Graduate School Ltd v National Westminster Bank, [2024] EWHC 581 (KB) is the first decision...
Mar 21 2024
ESG dispute risk for financial institutions: A global picture
Climate litigation and other ESG risks are on the rise around the world for corporates and financial institutions. In the EU and UK a...
Mar 6 2024
'De-banking’ claim against Revolut struck out as an abuse of process
In the recent case of Uzbekov v Revolut, the English High Court struck out a breach of contract claim brought by Mr Uzbekov following...
Dec 8 2023
Maintaining ‘orderly’ markets in disorderly times: the English High Court finds in the LME’s favour in relation to the nickel crisis
In a judgment that will be of interest to exchanges and those who trade on them, the English High Court dismissed judicial review...
Jul 14 2023
UK Supreme Court rejects extension of Quincecare duty and clarifies its juridical basis
In the important judgment in Philipp v Barclays Bank plc handed down this week, the UK Supreme Court has rejected the extension of a...
May 2 2023
Lord Sumption delivers Judgment on the Quincecare duty
Lord Sumption recently delivered the lead judgment in proceedings before the Hong Kong Court of Final Appeal (CFA) which concerned the...
Apr 27 2023
Section 1782 Discovery and Russian Sanctions: Same as It Ever Was
One consequence of Russia’s invasion of Ukraine and the US, UK, and EU sanctions that it spawned is a spate of Russia-related litigation...
Jan 18 2022
What to expect from US enforcement agencies in 2022
In recent months, public statements by the Biden administration and senior officials from US enforcement agencies attest to a renewed...
Investment funds and fund managers
Investment funds and fund managers
Nov 13 2025
FCA multi-firm review into consolidation trends in the financial advice and wealth management sector prompts reassessment of acquisition and integration strategies
The Financial Conduct Authority (FCA) published findings from its recent multi-firm review into consolidation trends in the financial...
May 27 2025
Investment research payment optionality: New joint payment option increases flexibility in how fund managers pay for research
The FCA has introduced a “joint payment” option for research and execution services for UK fund managers. This is intended to address...
Apr 22 2025
Reforming fund regulation in the UK: HM Treasury and FCA proposals for regulating alternative investment fund managers
The future for alternative investment fund managers (AIFMs) in the UK became a little bit clearer on 7 April 2025 when HM Treasury...
Mar 19 2025
The FCA’s review of private market valuation practices: what it means for firms
On 5 March 2025, the FCA published the findings from its multi-firm review of valuation processes for private market assets. In this blog...
Blog
Feb 6 2025
Amendments to the Investment Ordinance (AnlV): more infrastructure, risk capital and flexibility
The German version of this article is available here. The government’s draft bill of the 2nd Company Pension Strengthening Act of 18...
Feb 6 2025
Änderung der Anlageverordnung: mehr Infrastruktur, Risikokapital und Flexibilität
Die englische Version dieses Artikels finden Sie hier. Der Regierungsentwurf zum 2. Betriebsrentenstärkungsgesetz vom 18. September 2024,...
Jul 31 2024
Changes to the UK Stewardship Code seek to ease the burdens on signatories and support the growth of UK capital markets
On 22 July 2024, the Financial Reporting Council (FRC) announced several immediate revisions to the UK Stewardship Code 2020 in order to...
Apr 19 2024
FCA Proposes an Option for Bundling Payments for Investment Research and Execution
On 10 April 2024, the Financial Conduct Authority (FCA) published a consultation paper (CP 24/7) on Payment Optionality for Investment...
Mar 8 2024
Spring Budget 2024: The Hunt for Blue October
In an unusually rowdy House of Commons, the Chancellor delivered what will be his last Spring Budget before a UK general election widely...
Nov 19 2023
Investing like the pros – indirect investments by retail investors in investment funds for (semi-)professionals under BaFin’s scrutiny
Both the desire for higher yields and the low interest rate environment of the past years has seen retail investors’ focus increasingly...
Sep 29 2023
The regulatory gateway for firms who approve financial promotions
Key message Existing authorised firms who want to be able to approve financial promotions for unauthorised firms after 7 February 2024...
Jul 24 2023
Investment funds: an evolving front line in macroprudential regulation
Regulators and standard-setters, domestic and international, are worrying about the potential for investment funds to pose risks to...
Jun 28 2023
Proposals to clarify and modernise the UK’s transfer pricing, diverted profits tax and permanent establishment rules
On 19 June 2023, the UK Government published a consultation on reforms intended to clarify and modernise the UK’s transfer pricing (TP),...
May 11 2023
Developments in Spanish taxation of dividends received by non-resident investment funds
The Spanish Supreme Court has recently confirmed that dividends paid by Spanish companies to non-resident open-ended alternative...
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