RegTech IntelligenceJWG analysis. Fees and costs currently present themselves as the top controversial issues within the investment industry. The key challenges on this topic, bearing MiFID II in mind, were discussed by Aisha Dudhia (JWG Group), Steven Charlton (Vanguard Asset Management) and Bart Heenk (Avida International) at Professional Investor’s latest roundtable. This article offers answers to
JWG analysis. The ousting of Martin Wheatley from the Financial Conduct Authority during the summer is a sign that the UK Government wants to take a stand on ‘bank bashing’, sending a global message that London is a bank friendly capital, and that there will be more emphasis on individual responsibility. During this year, there
The MiFID framework is venturing into unchartered territory as European legislators aim to place new restrictions on commodity markets. This element of MiFID II has been one of the most contentious parts of a highly controversial process. In light of the recent publication of the Regulatory Technical Standards (RTS) by ESMA, we look at five
PRESS RELEASE: Think-tank deploys RegDelta to help train MiFID II workforce JWG, the financial services regulation think-tank, are offering a ground-breaking new face-to-face training course on 3 November 2015 in London. Ground-breaking, because it is supported by the complete library of MiFID II documentation now loaded in RegDelta. The clock is ticking for the thousands
JWG analysis. As financial regulations keep piling up in the post-crisis world, it becomes increasingly difficult to recognise the similarities and differences between them. The interdependencies on the Know Your Customer (KYC) front are present, but somewhat tangled. Here we provide an overview of the current and upcoming client classification requirements under prominent regulations, and
JWG analysis. The European Banking Authority (EBA) have been particularly busy this year, publishing over 30 key documents (5 consultations, 5 guidelines, 7 technical standards, 4 opinions and 11 reports and other notable publications) between June and August. Keeping up this pace, according to the EBA’s September newsletter, we can expect 25 deliverables covering 16
JWG analysis. A new dawn began for the wholesale energy market on Wednesday, as the trade reporting obligations under the Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) came into force. The Agency for the Cooperation of Energy Regulators (ACER) issued this notice on Monday to inform market participants that the Agency’s REMIT information
JWG analysis. Since the 2008 global financial crisis, there have been multiple bones of contention and areas of tussle between the regulators and members of the financial industry. One example is the issue of remuneration, because of its reputation as a key driver for instilling particular behaviours within the financial industry. Used correctly, it can
With the MiFID II technical standards finally being published, the time is right to give our successful MiFID II implementation training its latest run on 3 November in London. We suspect that, soon, regulators will be asking tough questions about how you plan to be ready for system integration testing in a mere nine months
JWG analysis. According to an article by Rachel Wolcott of Thomson Reuters, the FCA have now elucidated that they will operate a zero-tolerance policy with firms not giving their all on the approaching MiFID II deadline. Hopes have been dashed that the sheer size and complexity of the regulation would either push back the deadline
JWG analysis. Reporting systems are already buckling under the weight and complexity of new compliance demands, and yet more requirements are on the way. Trade and transaction reporting regimes are set to expand significantly in 2017 when the Markets in Financial Instruments Directive II (MiFID II) and the Markets in Financial Instruments Regulation (MiFIR) come
JWG analysis. Over the course of the year, JWG’s Customer Data Management Group (CDMG) has covered in-depth customer due diligence and KYC requirements under global tax, reporting and anti-money laundering regulation, and market monitoring under MAR/MAD2. For the ninth CDMG meeting, JWG took a different direction and covered fund management regulation and the regulatory interdependencies
JWG analysis. … at least, not much! This week is a significant one for compliance and legal professionals in the financial services industry. ESMA has finally released 1,500 pages of draft regulatory standards covering trading, market abuse and the settlement of securities. In the past few months, JWG has spent considerable time covering MiFID II,
Today, ESMA has published the long-awaited MiFID II Technical Standards, leaving implementation teams across the industry with hundreds of pages to get to grips with. The publication confirms that MiFID II will represent the biggest change to the regulatory framework in living memory. It represents an extremely complex puzzle, but at least now we have
By Sam Tyfield and JWG. Following on from our previous article, the devil is in the definitions, where we unravelled the definitions for High Frequency Trading (HFT) and Direct Electronic Access (DEA) provided within the MiFID II texts, now we explain how these definitions will apply in practice. What is HFT? Well, that’s a question
JWG analysis. Following the introduction of the new ringfencing law, due to come into force 1 January 2019, the biggest UK banks strongly voiced their concerns. Although this new law will be difficult (and expensive!) for all banks involved to implement, firms with more global and diversified business models are facing additional complexities. In particular,
JWG analysis. On 7 September, the EU published a statistic showing that, according to the EBA, the percentage of high income earners that have a material impact on an institution’s risk profile has increased from 53.68% to 59.00%. They stated, though, that this trend is likely to change in the future following the adoption of
JWG analysis. One of the key themes of MiFID II has been to enhance regulation in order to better protect investors within the financial services industry, and regulators continue to propose more and more stringent regulations for financial institutions. Following on from part 1, this article explores five more significant characteristics of best execution under
JWG analysis. The Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) was introduced in 2011 to stem insider trading and market abuse in European wholesale energy markets, under the realisation that market abuse conducted anywhere within interlinked markets would have a significantly wide impact. With this new regulation – and its corresponding fines –
JWG analysis. Whilst the most eye-catching changes to the MiFID regime tend to have fallen within the market infrastructure bucket, there have also been many small amendments to the investor protection area (consequently representing a significant regulatory reform). Overall, the EU has proposed additional layers of regulation to protect investors, in the hope that this
JWG analysis. Regulators have given a huge boost to the small and medium enterprise (SME) markets under EuVECA, which aims to support the harmonisation and growth of the EU’s venture capital funds. Venture capital funds are investment funds that specifically focus on pooling funding from other financial institutions (such as pension funds) in order to
JWG analysis. The minutes of the latest MiFID II implementation roundtable, on 17 July, were published in August. At the meeting, the FCA spoke with a number of industry trade bodies, including the Association for Financial Markets in Europe (AFME), the International Swaps and Derivatives Association (ISDA) and the International Capital Markets Association (ICMA), to
JWG analysis. Last week we wrote about thwarting financial crime through suspicious transaction reports (STRs) in the UK, and the Financial Conduct Authority’s (FCA) concern over the integrity, accuracy and coverage of STRs. On the other side of the Atlantic, FinCEN is proposing to extend their anti-money laundering (AML) regime to investment advisers. Closing
JWG analysis. Derivative contracts are not a financial innovation of recent decades, allegedly coming into use around 1700 BC in ancient Mesopotamia. On 16 August 2012, a new chapter in derivatives’ history was written when the European Market Infrastructure Regulation (EMIR) entered into force, as part of a global initiative to reduce counterparty and operational
JWG analysis. “This regulation has the possibility to create a strong ecosystem for social enterprises across the union” In December 2011, the European Commission issued a press release highlighting the problems that businesses face when seeking conventional sources of funding due to the confusion surrounding their mix of social goals and business techniques. Responses from
JWG analysis. With almost a 400% increase in the number of suspicious transaction reports received by the Financial Conduct Authority (FCA) since 2007, you may assume that the monitoring and reporting procedures put in place by firms have increased in quality. However, although this may be a logical conclusion to draw, a recent FCA newsletter
JWG analysis. Amongst a number of themes and issues that are raised on a regular basis at our monthly Customer Data Management Group (CDMG) meetings, data protection and the need for harmonisation are consistently top contenders. Recently, CDMG has covered the OECD Common Reporting Standard, MiFID II and the new Market Abuse Regulation, and will
JWG analysis. At the 8th Customer Data Management Group (CDMG) meeting of 2015, on 18 August, over 20 members from 10 firms came together to discuss the new Market Abuse Regulation (MAR) and the potential challenges it holds. With less than 11 months until particular sections of MAR will apply to the financial services industry,
JWG analysis. This month, ESMA published four reports in which they outlined the modifications that they believe are needed to the EMIR legal framework. JWG have had a look and, below, we pick out five key changes that are being proposed. Clearing obligation. ESMA is recommending two minor changes to the clearing obligation. These are
JWG analysis. Last year’s Central Securities Depositories Regulation (CSDR) saw fresh demand from regulators for a more transparent and efficient framework for EU CSD services and operations. The main aims of CSDR are to increase the safety and efficiency of the post-trade environment, primarily through the harmonisation of settlement cycles and settlement discipline for CSDs.
JWG analysis. Since the financial crisis, there has been an increased focus on tackling market abuse. As of March this year, the FCA had 49 cases market abuse cases open and, in 2014, 60+ market abuse cases were on their books. In terms of criminal convictions, three were secured for insider dealing and nine confiscation
JWG analysis. With many of the regulations that have come into force since the 2008 financial crash, the rules may appear simple enough, but the devil is very much in the detail. MiFID II is no exception. With MiFID II looking to enhance transparency within the industry, firms that currently provide RFQ services must consider
JWG analysis. With Australia and Canada having already adopted new rules to oversee trading within dark pools, it is now Europe’s turn to shed some light on this activity. Considering that only about 9% of European equities were traded within dark pools in 2014 (in comparison to about 40% in the US), it may seem
JWG analysis. It may have taken five years and five regulatory agencies to bring about, but the final version of the Volcker rule has officially landed. The Volcker Rule, also known as Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), was named after former Federal Reserve chair, Paul Volcker, who
JWG analysis. The commencement date (March 2016) of the Senior Managers Regime is fast approaching – but what does it mean for senior managers? And will anyone want to be a senior manager when the regime finally commences? Whilst the new regime will only affect new applicants directly, those who are certified under the existing
JWG analysis. With MiFID II looking set to radically change the financial trading environment as we know it, following on from part 1, in this article we explore 5 more key changes we are anticipating by 2017. 6. Increasing competition In line with the policy focus on competition, the European Commission (EC) proposed rules
JWG analysis. The removal of a number of financial practices has altered the regulatory environment in recent decades. With new landmark legislations coming in to play soon, regulators across Europe look set to bring down the curtain on another. Under the existing practice of bundled commissions, asset managers charge clients to manage their funds but
JWG analysis. By January 2017, European financial services legislation will have significantly changed the financial services sector. The sheer volume of transactions, products and firms affected by the new regulation means that we can say goodbye to the trading landscape we currently know. In part 1 of this article, we discuss five of the
JWG analysis. In an article earlier this week, we highlighted some of the key challenges for firms engaged in HFT activities under MiFID II. In this piece, we will focus in more detail on one particular area of change under MiFID II, namely algorithmic trading and the implications of regulators rewriting the dictionary for it.
JWG analysis. Just as firms are getting their heads round reporting for FATCA, the OECD’s Common Reporting Standard (CRS), together with its band of early adopters, pops up. Much has been written on comparing CRS with FATCA, highlighting that there is little to fear for there are synergies to be found. If you are one
JWG analysis. In part 1, we focused on the consultation paper published by the FCA on 7 July, CP 15/22, in which the UK’s financial regulator proposed that managers responsible for algorithmic trading should also be covered under the new Senior Managers and Certification Regime. But, as many readers will know, it is not only
JWG analysis. On 7 July, market experts at the City & Financial Global workshop on transaction reporting under MiFID II addressed an audience, setting out their main concerns regarding the new transaction reporting regime. In this article, we present some of the key issues that they highlighted. The European Securities and Markets Authority (ESMA) have
By Sam Tyfield and JWG. It has been widely rumoured that the level 2 MiFID II will define the high frequency algorithmic trading technique (HFATT) as one which has a high message intraday rate in which there is a minimum of four messages being sent per second for all instruments traded on a trading venue.
JWG analysis. Mark Carney recently declared the ‘age of irresponsibility’ within the fixed income, currency and commodities (FICC) markets to be over. Just over a year ago, the UK Government introduced the Fair and Effective Markets Review (FEMR) in response to the FX and LIBOR scandals. The large scale misconduct and collusion had damaged public
JWG analysis. Since 2008, regulators have been plugging the gaps revealed by the global financial crisis and have just put another brick in the financial services wall – the 4th Money Laundering Directive. Last month, the much anticipated ‘IV’ was published in the official journal and will become the law of the land in 2
JWG analysis. At CISI’s Annual Conference, Verena Ross presented the latest outlook on EU regulation, covering the Capital Markets Union (CMU), ongoing work in relation to investor protection and the digitalisation of financial services. Ross once more emphasised how a successful CMU, based on a single capital market in the EU, promotes the attractiveness of
JWG analysis. Today ESMA published a Q&A, aiming to clarify the status of investment-based crowdfunding platforms which are outside the scope of MiFID and, therefore, not automatically subject to rules designed to combat money laundering and terrorist financing under AMLD III. Investment-based crowdfunding platforms can have a different regulatory status. Some are within the scope
JWG analysis. With a number of regulatory deadlines looming, we thought we’d remind you of another one – mark January 2017 in your calendars (if you haven’t already) for MiFID II. The aftermath of the recent financial crisis exposed weaknesses within Europe’s current Economic and Monetary Union and highlighted the need to strengthen it. Although
By Sam Tyfield and JWG. While the latest chapter of the Greece tragedy plays out, today ESMA quietly released its final report on draft technical standards on the authorisations, passporting, registration of third country firms and cooperation between EU competent authorities. Compared to the Consultation Report published in December 2014, ESMA has clarified a number
JWG analysis. TheCityUK today published its research report on EU reform. In it, they outline proposals for a more competitive Europe, focusing on regulatory reform in section five. As TheCityUK emphasises, and we have previously mentioned in our publications, a spate of fresh regulation has been initiated within and beyond the G20 since the global
JWG analysis. Some of the areas in which firms are the keenest for greater clarity are transaction reporting, understanding where information on which instruments are traded on venues will come from and the overlap between MiFID and RDR. It was agreed that TAs would speak to their members and come back to the FCA with
JWG analysis. As we pointed out in our third piece on regulatory reporting, and at an Infoline conference for the buy-side this week in London, the overarching question is how will firms’ derivative activity be judged to be ‘good enough’ in 2017? There is no single answer, and we won’t really know until the results
We are now less than 400 work days away from MiFID II’s big bang and ‘implementation’ is now the name of the game. Yes, there will be a final version, but the vast majority of what is in the drafts is likely to remain the same. On 7 July, City & Financial Global will hold
JWG analysis. We are less than 115 days from the point when the first phase of new energy trading reporting obligations kicks in across the EU. Amidst a recent industry outcry to develop more consistent data reporting standards, the requirements introduced by the Regulation on Energy Market Integrity and Transparency (REMIT) are yet another example
JWG analysis. Eleven of the industry’s most high-profile trade associations and ISDA this week urged regulators to adopt consistent and harmonised trade reporting requirements across jurisdictions. However, reporting rules are already on the books and the consequences are high for firms. In part 1 of our analysis on reporting, published last week, we explored
By Sam Tyfield and JWG. As RegTech readers may recall, back in 2014, the prudential regulator in the UK released new rules for the firms it regulated – the ‘senior managers regime’ or SMR – and that the Bank of England was running a Fair and Effective Markets Review (FEMR) looking at what needed to change in
JWG analysis. In her speech at IDX 2015 this week, Verena Ross, Executive Director, European Securities and Markets Authority, addressed the two major EU legislative projects affecting derivatives trading: MiFID II and EMIR. Here we present some of the key issues she highlighted. 1. MiFID II timeframe and technical standards The decisive date for application of MiFID II
JWG analysis. Catch phrases, like ‘caveat emptor’, have been the rallying cry of the financial industry for millennia. In 2009, the G20 sought to change the status quo by introducing the notion of global transparency to all markets. After spending billions on the first wave of reporting, we are only now realising how difficult it
JWG analysis. As we have been reporting for the past 18 months, MiFID II is massive and the delta between it and MiFID I is cavernous. JWG’s MiFID Implementation Group (MIG) weekly workshops have been actively delving into the ‘known unknowns’ of the sell-side all year and we are pleased to help promote City &
JWG analysis. Given the 5 year latency between flash crash and recent arrest, John Bates wondered whether the regulators were riding bicycles to try and catch up with the sporty cars driven by the Flash Boys, the high-frequency traders. Although HFT represents a large percentage of trading volume, what ‘it’ is and how it can
JWG analysis. European regulatory agencies were clear: firms may already be too late if they haven’t started their MiFIR implementations that need to be tested and ready in summer 2016. Speaking at a two day ‘MiFIR Reporting & Beyond’ conference attended by JWG last week, regulators, trade associations, consultants and industry practitioners we all on
JWG analysis. Since the turn of the year, we have not seen the pace of reform slow down. We could fill pages with acronyms describing the new requirements for financial institutions, but we will spare you that. We are aiming high and expanding our coverage beyond the G20 to track over 600 regulatory initiatives and
JWG analysis. JWG’s recent analysis report, the MiFID II KYC mountain, finds that financial institutions have a 12-item checklist to work through for their MiFID II KYC implementation due to the requirement for firms operating in the EU to acquire, document and agree much more information about their customer’s situation and their transacted business by
JWG analysis. We’re used to watching our document trackers spin out of control in so-called ‘quiet’ times. As we wrote in January, the last 2 weeks of 2014 year saw global FS regulators pump out over 4,000 pages. These Easter holidays were little better with 2,000 pages of regulatory text released in two weeks. It
JWG analysis. As MiFID programmes take off and top tier firms tackle MiFID II implementation, the banking sector is about to be hit by even more pressure to produce reports about trading activity. The proposed regulation, aimed at enhancing the transparency of securities financing transactions (SFTs), seeks to ‘balance the scales’ between the two sectors
JWG analysis. Firms have plenty of planes in the air right now. The regulatory pressure on firms to ‘get KYC right’ in the form of new financial crime regulation, such as FATCA or AMLD IV, and huge fines means they will need to juggle these changes amidst an ongoing regulatory implementation effort. How you need
JWG analysis. We attended an august gathering of 400+ buy-side professionals last week. Not only did regulatory drivers get a healthy hearing, but the group discussed how they will impact the way business is going to be handled in the future. Clearly, margins are under pressure, brokers are not giving it away like they once
By Sam Tyfield and JWG. Here algo again … Yesterday, ESMA published a notice stating that supervision of automated trading across the EU (in compliance with the ESMA guidelines from 2012) was converging. We found that interesting – a closer look at the BaFin’s rules versus those MiFID II/R creates would appear to show less
Regulation is coming thick and fast. With predicted document count of 200,000 by 2018, dealing with the deluge in a page-by-page, regulation-by-regulation approach is becoming impossible as G20 commitments spread across many rulebooks. Firms trying to tackle the changes one-by-one will end up with sky-high implementation costs and conflicting priorities – unless they take action
JWG analysis. Regulations like FATCA, EMIR and Dodd-Frank have asked us to collect more information on our customers than ever before – but now it’s clear that was just the start of the story. New regulation finds regulators even hungrier for information on the firm’s relationship with its customer, together with details of how information
With the second round of MiFID II consultation now officially over, the time is right to get our MiFID II implementation training ready to fly on 24 March in London. We suspect that, soon, regulators will be asking tough questions about how you plan to be ready for system integration testing in a mere 350
JWG analysis. The second round of MiFID II consultation has officially ended. As we have previously noted, the tone from the recent hearing was that, despite more consultation due on some of the fine print, we are largely done discussing the standards and can now begin to start thinking about how to implement them. On
JWG analysis. With 40+ regulations covering 500+ KYC data requirements due to be implemented over the next 3 years, meeting the requirements poses significant challenges to all firms in the market, not least client outreach, data management and multiple, iterative, implementation dates. Combined with record fines for AML failures, and new personal liability for senior
JWG analysis. This month, ESMA hosted a broad cross-section of market participants for a final ‘hearing’ on the MIFID II technical standards they will send to Brussels for approval this summer. Of course, many attendees were surprised to find that, while they were en route to Paris to sit for 10 hours with 350 of
JWG analysis. As we read the comments on our last article on the five tribes of regulatory reform, we were struck by the visceral reaction to the suggestion of sharing the agenda. “Hands-off, that’s my mortgage you’re messing with”, commented one lawyer. We wonder, can tribes achieve their overarching regulatory goals if they are NOT
By Robin Poynder, FMR advisory. Advancements in price distribution technologies and the advent of high frequency trading have forced firms’ IT departments to establish strict controls around best practice pricing for trades. CEO of FMR Advisory, Robin Poynder, explains the need for a standardised protection mechanism “last look”. “Some argue that last look is a
JWG analysis. It’s only February and we’ve laid out quite a programme of work for 2015. Digesting the 4,000-page Christmas gift, curing the KYC sickness, cutting a trail through MiFID II and taming your global trading troubles – and we’re not yet at the midpoint of the first quarter. Sadly, it is not a blip
JWG analysis. There is a war going on to ‘Know Your Customer’. As regulators continue to release new requirements for firms to collect and maintain information about their clients and counterparties, the struggle to comply has turned into trench warfare fought across many fronts, and new strategies are needed to avoid a long and uncertain
On the 22nd January, over 30 stakeholders from 12 firms met Customer Data Management Group (CDMG) meeting to discuss their 2015 priorities for regulatory KYC requirements. JWG presented a summary of 40+ new regulations that require firms to manage counterparty information over the next 3 years. Alec then presented summaries of the 11 regulations in scope
The need for better counterparty information sits at the centre of most regulatory reform agendas. Unfortunately, this means the period from 2015 to 2017 brings with it massive new documentation, workflow and vendor change for the hundreds of fields maintained for every subaccount in capital markets. Do you know what is about to hit your marketing,
By Sam Tyfield, Vedder Price. Back in 2009, the EU issued a Recommendation (which has no binding legal effect) on the use and application of RFIDs (which, for our purposes, means ID/swipe/access cards). The EU has just issued a review of the implementation of the Recommendation EU-wide and has found take-up by EU member States
JWG analysis. The chief of the CFTC pronounced from Japan this week that implementing regulatory reform means overcoming “legal traditions, regulatory philosophies, political processes, and market concerns”. Looking at the global trading regulatory climate that surrounds MiFID II, we couldn’t agree more. Those struggling to digest the MiFID II texts and get to Paris for
JWG analysis. The industry returned after the break knowing that it had fewer than 500 working days to implement MiFID II but found over 2,000 pages of new text to read. Even worse, the grapevine whispers that more is due out this month. As we’ve written before, organising and planning is the order of the
JWG analysis. 2015 will see a number of new regulatory requirements, long in the proposal or draft stage, crystallise into prescriptions for better customer data management. At a time when record fines for AML failures and new personal liability for senior managers have intensified the pressure to ‘get KYC right’, these ‘remedies’ pose significant challenges
Happy New Year! Many may have been disappointed by snowless mountains this year but here, in the FS sector, our regulators are making sure we’re covered. Far from a light dusting, this year’s ‘Christmas dump’ exceeded our expectations and all corners of the earth are now digging out from under the 4,000 pages that fell
JWG analysis. While most of us basked in the holiday spirit, the regulatory Grinches were hard at work. In the two-week period between 19 December and 2 January, regulatory bodies in the UK, EU and US alone published over 40 critical documents. JWG’s tracking revealed a broad range of subjects. CRD IV/CRR, BRRD, UCITS V,
JWG analysis. 60 attendees across the buy and sell-sides came together at Markit’s seminar in Stockholm last month to discuss today’s industry challenges. They concluded that a new focus on establishing a flexible banking operating model to meet both business and regulatory demands for data, processes and standards, is top on their wish list for 2015.
You better know deals You better not bribe Better not launder ESMA’s telling you why MiFID II is coming to town They‘re checking reports And transparency ESMA’s regulating Intermediaries MiFID II is coming to town They see your algorithms They know your HFTs They know if you’ve been market making So follow the
This summer, we found that the industry could face up to three Eiffel Towers high worth of paper from the G20. Curious about the risks inherent in managing that many documents, we asked Meredith Gibson, Head of Legal Risk at Santander UK, and Helen Pykhova, Director of The Op Risk Company and Chair, Operational Risk
As published in ‘The Trade’. Europe’s financial regulator has revised the current framework for the reporting of derivatives trades under the European Markets Infrastructure Regulation (EMIR). The European Securities and Markets Authority (ESMA) is now seeking feedback on its changes which aim to resolve the widespread issues which have arisen in the reporting process. The
JWG analysis. In our last article on this topic, we spelt out our views on regulatory implementation standards. And the first standard that needs to be defined is how you’re going to organise your work programmes. The shape of your MiFID II programme MiFID II is far beyond just a few ‘tweaks’ to MiFID I. So much
JWG analysis. This summer, we took a look at the emerging MiFID II/MiFIR technical standards and concluded that the ‘hearing’ that they were getting would result in a war of many parts. Since the summer, over 700 MiFID II/MiFIR responses have been submitted, the FCA has run a conference crying for action and JWG is
JWG analysis. Conduct risk continues to be a hot topic. There is a number of reasons for this: everybody’s being fined for it, there is a continuous stream of regulatory requirements demanding it and -probably most importantly – no-one knows exactly what it is. The FSA provided a definition in 2011 in their Retail Conduct
Darragh O’Grady and JWG. There has been much written lately on the potentially disruptive impact that digital currencies may have. However, the blockchain architecture that underlies them has also been a recent subject of a CFTC meeting to discuss the potentially disruptive impact of this new technology. We asked an architecture expert with a background
Huge fines and complex KYC rules are causing banks to ‘de-risk’ their client portfolios leading to many without access to banking. Now both consumers and politicians are unhappy. For years, the industry has struggled without real standards in the AML arena. So what happens next? SIBOS news was full of more KYC claims again this
JWG analysis. The challenges of gaining oversight over the financial system are not going unnoticed. We come back from the summer holidays with 5 leading indicators that suggest we are on the brink of bad news. Bad news that is likely to spread far and wide. Firstly, in a new report, the US Government Accountability
In our previous articles we’ve explored the expanding requirements for robust systems and risk controls under MiFID II, the nature of proportionality as it relates to algorithmic trading and the new accountability implications for senior managers. This article, written by Meredith Gibson, Head of Legal Risk, Santander UK plc and Helen Pykhova, Director, The Op
JWG analysis. As the sun slips back into hibernation, schools reopen and autumn looms, regulators, lawyers, risk specialists, change managers and compliance professionals are returning to their desks. Here at JWG we have been busy tabulating the enormous level of movement in the regulatory space during the summer. For those of you lucky enough to
JWG analysis. “When providing investment advice or portfolio management the investment firm shall obtain the necessary information regarding the client’s or potential client’s knowledge and experience in the investment field relevant to the specific type of product or service … so as to enable the investment firm to recommend to the client or potential client the
Are you enjoying your summer? Ready for some holiday reading? Our latest members-only newsletter, RegBeacon, is now available here (after logging in, you can find RegBeacon on the publications page). We’ve highlighted the key issues and trends to be aware of as we head into what is sure to be a very rocky Q3 –