The UK Prudential Regulation Authority (PRA) ordered globally systemically important banks (G-SIB) to commission skilled persons reviews of their governance and individual accountability regimes, as well as control and risk management frameworks in its financial year 2020/21. This activity underscores the continuing serious problems that the world’s largest and most-complex banks have had with risk


The Financial Conduct Authority (FCA) will consult on a review of the UK European Markets Infrastructure Regulation (UK EMIR) reporting standards in the second half of this year, a spokeswoman for the regulator said. It has “the aim of improving overall data quality and to align the standards with the global guidelines on critical data


UK financial services regulators have asked bank chief executives to sign up to and largely pay for work to improve regulatory data collection. The Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) last week wrote to bank chief executives explaining their plans for transforming data collection, which regulators expect will deliver integrated reporting,


The latest episode of RegCast is available now! RegCast 2 covers the UK’s fast moving political and regulatory review process, the key questions they are addressing, and what they are likely to mean for regulators, regulated and their customers. The group discusses past choices and explores the implications of digitizing the future regulatory framework including


As we summarized in our latest Beacon, JWG’s surveillance community has covered quite a patchwork of regulatory obligations over the past 2. In all that time, nothing has pulled all into focus like GameStop. JWG has been digging beyond the broadsheet news to examine what roars from Reddit chat groups will mean to wholesale and


JWG RegTech Beacon 27 published

RegTech Beacon – Guiding your way through global regulatory storms. 2021 is off to a fast start with regulators redoubling their efforts to police a more digitally enabled market. In this Members newsletter we provide an overview of what JWG has been up to and what lies ahead. Topics covered: New themes for RegCast. We summarize our research on emerging global digital regulatory themes and


The number of cyber incidents at UK banks, asset managers, wholesale brokers and exchanges rose from 21 in 2019 to 55 in 2020, a 161.9% increase, according to the Financial Conduct Authority (FCA). The disclosure was made in response to a request under the Freedom of Information (FoI) Act. Asset managers, wholesale brokers, platforms and


It has been a very busy 2021 and it is a very noisy financial services regulatory marketplace. JWG is pleased to be helping to contextualise the strategic issues in play with a new podcast series called RegCast which you can access here.   So what is RegCast? RegCast is an industry spotlight on the business


Digital regulatory reporting – tipping point 2021

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Digital regulatory reporting – tipping point 2021 By PJ Di Giammarino, CEO JWG Group New JWG research has found supervisors to be focused on creating new standards for interpreting complex data needs in 2021 as the industry hits a tipping point for in its quest for digital standards that simplify complex regulatory reporting obligations. Global


A UK Government-led forum in its third year. A dynamic and engaging event bringing together the leading public and private sector actors from the UK, China and Southeast Asia to exchange knowledge and innovative practical techniques and solutions to tackle financial crime and related issues. A vibrant and vital interaction between policymakers, regulatory bodies, law


Collaboration to finally realize GFC reforms via digitalization The good news about compliance is that financial firms are finally getting the last generation of G20 Global Financial Crisis (GFC) regulations under control, said PJ Di Giammarino, CEO of JWG, a financial regulation think-tank based in London. The not so good news is that the industry


Know your 2021 Cloud Compliance Strategy – Survey open

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JWG’s 2020 research has found that the financial services market exhibits an ever-growing blind spot from technology risk which lurks off balance sheet. High profile outages like Google and Microsoft have underlined the issue for both the regulator and regulated this month. This point has not been lost on regulators who in the middle of


L’Autorité des Marchés Financiers (AMF), France’s financial markets regulator, has created a Data and Surveillance Directorate as part of a wider reorganisation announced earlier this month. Its establishment comes as a handful of regulators pursue digital realignment programmes, but the AMF appears to be ahead of the pack in establishing a new division, building data


   Donna Bales, Co-Founder and Member of the Board of the Canadian RegTech Association and PJ Di Giammarino, Founder and CEO of JWG Group were honoured to participate in the Canadian Institute’s 26th Annual Flagship Conference on Regulatory Compliance for Financial Institutions. The trans-Atlantic debate, ‘Assessing 10 Opportunities in the RegTech, FinTech and the


The European Securities and Markets Authority’s (ESMA) extensive proposed guidance to the Market Abuse Regulation (MAR) could force the UK Financial Conduct Authority (FCA) to make some early decisions to diverge from the regime. “One of the questions is what does the FCA really think about the MAR review? This is where the rubber begins


Gentrifying The Wild West

Can suptech take DeFi to the next level? As technology-driven decentralised finance (or DeFi) grows in popularity and market value, it appears that a battle is brewing between DeFi protocols and regulators. But can technological tools in the hands of regulators head this off at the pass? A reasoned, transitional approach to compliance, along with


The global regulatory community has put its support behind digital regulatory reporting (DRR) initiatives acknowledging supervisors require the ability to collect better quality data more efficiently. The Bank of International Settlements (BIS), the European Commission, the European Banking Authority (EBA), the European System of Central Banks (ESCB), the Financial Stability Board (FSB), the U.S.’s Federal


Remember, Remember, the 5th of November… FCA, conduct and Ops

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On Thursday last week, 5th November, the FCA published three Decision Notices, all prohibiting individuals from performing “any function in relation to any regulated activity carried on by any authorised or exempt persons or exempt professional persons” as each lacked “the necessary integrity and reputation required to work in the regulated financial services sector”. The offences


JWG urges sector to address systemic technology risk blind spot

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JWG is proud to announce the publication of a ground-breaking research report ‘Risk control for a digitized financial sector.’    The analysis identifies a large systemic technology risk blind spot which regulators must take the lead in addressing. JWG urges Financial Services regulators and firms to collaborate with technology firms on new RegTech standards in advance of cloud and data crises.    The paper, which incorporates findings from JWG’s RegTech 2.0 conference and dozens of discussions with regulators, regulated and academia, builds on 10 years


How a firm manages data is now intrinsic to its value, yet the FS risk management framework provides no way to account for IT obsolescence, cloud concentration and data risks on the balance sheet. An explosion of advanced computing capability facilitated by cloud technology has provided massive benefits to both regulated financial institutions and their


The UK’s Prudential Regulation Authority (PRA) has commissioned 11 skilled persons reviews under Section 166 of the Financial Services and Markets Act 2000 into firms’ regulatory reporting in the last two quarters. The PRA commissioned nine prudential s166 reviews of deposit takers in the fourth quarter 2019/20 (December through February), according to publicly available information.


FS Compliance officers have been hit with an unprecedented deluge of 3,021 COVID-19 alerts 2 months into the pandemic, which JWG forecasts to be a total of 15,695 documents by year end.   Regulators expect firms to be able to navigate these difficult circumstances while delivering fair outcomes for customers and complying with existing rules. That’s one of the clear messages in these 3,000 plus regulatory updates.  Better RegTech tooling is


Firms’ 2020 compliance workplans and risk management strategies have been rendered redundant as the regulatory response to COVID-19 has usurped everyone’s agenda. Regtech companies tracking COVID-19-related regulatory publications say more than 1,300 announcements have been made internationally as regulators roll out pandemic-specific guidelines and relax some rules to help financial institutions manage their businesses. “If


The State of Holistic Trade Surveillance – JWG research published 

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By PJ Di Giammarino Over the past few years, financial services firms have been investigating how to improve trade-related surveillance capabilities and techniques. Expectations from regulators and senior management have been placed under the microscope, mainly due to high surveillance noise levels across all communication channels and asset classes. In tracking this evolution of technologies


RegTech: the new lifeblood of compliance

By PJ Di Giammarino, CEO JWG Group and Chair of the RegTech Council In the aftermath of the global crisis, financial regulators rushed to implement complex rules without having a complete view of their consolidated impact and how the technical infrastructure of the industry would have to respond to their new demands for data. After


JWG RegTech 2.0 conference – Regulators, regulated and leading technologists to explore winning strategies for top 2020-2021 issues   London, 6 December 2019 – JWG is pleased to announce that its 5th annual RegTech Conference will be held on 7 February 2020 at the Gouman Tower Hotel in the City of London.    At a crucial point of inflection post financial crisis the Financial Services sector faces 374 new legal challenges. New JWG research has revealed low levels of awareness to key shifts in the regulator’s RegTech framework. Specifically:    Enabling market ecosystems. New global RegTech/ SupTech policy initiatives    Infrastructure risk. FSB, FRB, BoE focus on cloud


Your Board’s RegTech agenda

5 quarters ago I was pleased to report that the industry had taken an important step out of base camp.   On the eve of our 2019 conference it is clear that regulators, firms and the vendors which support them have all continued up the RegTech mountain, but we are at a crossroads.  New demand mounts from all


2019: Getting real about RegTech?

As we enter the year in which we will celebrate the 10th birthday of the G20 plan to make our financial services sector safe the agenda for compliance and how it leverages RegTech is being reset at a board level by many financial services actors in parallel. This article explores 5 drivers for RegTech 2019


Ready for digital regulation?

  JWG are pleased to announce new research in partnership with MarkLogic, which shows that financial institutions are ill-equipped to deal with the data demands of new regulation.   During Q4 2018, JWG conducted in-depth interviews with senior executives from 12 global financial institutions to develop the insight published in a subsequent paper titled ‘


Q1 19 RegBeacon published

As we enter the year in which we will celebrate the 10th birthday of the G20 plan to make our financial services sector safe we wonder whether we are making enough progress? Armies of compliance staff are now required to run the firm and the standing armies are brought on in to help with the


New JWG research has found 374 ‘legislative initiatives’ targeted at financial services due in the next three years globally and regulators are increasingly less tolerant of poor data quality which is ever more crucial in demonstrating compliance. Thanks to MarkLogic, we are pleased to be able to host a global discussion on our findings. Come


You may have noticed that we snuck out a complete refresh of our websites this week. The revamped pages bring our thought leadership and technology offerings together for the first time. After 1,000,000+ page views from 190 countries since 2012, this was a big migration. Why do it now? Well, as readers of these pages


HM Treasury has published a draft regulation outlining UK regulators’ plans to smooth the transition for inbound passporting firms in the event of a ‘no deal’ Brexit. The draft regulation outlines a temporary permissions regime that will enable EEA financial services firms operating in the UK via a passport to continue their UK operations for


Latest RegBeacon published

We are now 10 years on from the crisis which began the seemingly never-ending stack of regulation that we continue to plough through. As with any infrastructure project the post-crisis regulatory framework requires renewal and repair. Regulators are revisiting reporting regimes and data standards, and are looking at the emergence of new technology, whilst at


JWG are pleased to announce a partnership with BMO Capital Markets (BMO) where it will provide BMO access to its AI-powered, natural-language processing change management system — RegDelta. Ten years after the financial crisis, the financial services industry continues to face a changing and complex landscape, and this is particularly true for capital markets. RegDelta™


It is no secret that the City of London is a significant pillar of the UK economy. With financial services accounting for around 12% of the UK’s economic output, it generates more tax revenues than any other industry. It comes as no surprise then that the post-Brexit UK-EU relationship relating to financial services is a key


With the General Data Protection Regulation (GDPR) coming into force, it is time to reflect on such a huge overhaul of the data protection laws affecting every organization operating within the UK and the EU, from schools to large multinationals. To put things into perspective, in the UK alone, GDPR impacts over 500,000 data controllers


One of the key conclusions reached at our Capital Markets conference on 7 March  was that regulatory divergence as a potential consequence of Brexit is currently one of the main worries for financial firms. When polled, 53% of our audience indicated that Brexit will be their next significant regulatory challenge. This anxiety derives mainly from


The GDPR broadens and deepens the rules between data controllers and data processors for processing of personal data and for the first time, directly enforceable obligations are imposed on processors as well as controllers. The GDPR also requires that controllers and processors enter into written contracts (“C2P Clauses”). Practical Law recently published its data processing


This piece looks ahead to what we might expect as IT law developments in 2018. Unusually as we go into a new year, the main headlines of what IT lawyers can expect in 2018 are signposted at the outset: new financial services laws in January, the GDPR in May and looking ahead to Brexit in


A key focus of our RegTech Capital Markets conference this year was ‘the future of rule books and policy controls’. To discuss this topic, we assembled a panel of experts including Paul North, Head of Product Management EMEA at BNY Mellon, Alan Blanchard, Senior Associate and Handbook Publisher at the FCA, Mark Sweeting, Head of Strategic Change, Basel Measurement


At this year’s RegTech Capital Markets Conference a debate took place on the benefits of using RegTech for trade surveillance in the context of the evolving technical landscape, led by expert industry professionals on compliance and surveillance. Taking into consideration the volume and quality of data firms are expected to monitor, whether the current system


One of the hot topics at our Capital Markets Conference this year was how RegTech could help institutions with their Know Your Client (KYC) obligations. With an expert panel from a range of backgrounds presenting fascinating perspectives on this current issue, a issues were given fresh attention ranging from artificial intelligence (AI), blockchain, data architecture


RegTech 2018: beyond base camp

I was pleased to chair our third RegTech Capital Markets conference last week in London. Team JWG worked hard to get a global audience of over 350 senior individuals from more than 65 financial institutions as well as the vendor and regulatory community to frame a holistic perspective on where the industry is on its journey up


A paradigm shift for KYC/AML compliance

Several interconnected global trends have heightened the risk banks face when combating financial crime. First, regulators are continually revising rules as they expand their focus from organised crime to global terrorist networks, many of which have grown more sophisticated in recent years. Second, integrated networks and an increase in cross-border transactions have left gaps in


Building Bridges: Semantics in regulation

In financial services there is a chasm stretching out between key players when it comes to regulation. This chasm comes with a huge risk of plummeting, and what lies at the bottom? Hefty fines for non-compliance? Unmet policy goals? Unintended Consequences? All of the above, and what is causing this rift? Semantics. The language used


Waking up to the power of RegTech?

The past year has been illuminating for the RegTech market, the past twelve months has seen an increase in discussion on the application of technology to regulatory compliance. We have seen action from the regulators, including the FCA’s recent TechSprint in which we at JWG were involved, and major regulatory initiatives, most notably MiFID II,


Everywhere we turn these days, we find new opportunities to explore what RegTech is all about. New training courses, associations and of course conferences abound. With so much momentum now behind the RegTech agenda, the market needs to be on the same page about standards, collaboration and technological capabilities. This is why we are so


2017 saw significant developments in financial and regulatory technological innovation – and many regulators have been moving in parallel. What is going on? In a nutshell, the global collaborative fabric is coming together. Of course, the landscape for global collaboration is by its very nature a patchwork that reflects differing policy objectives across the globe.


JWG are delighted to be hosting the 3rd annual instalment of the RegTech Capital Markets Conference on 7 March 2018 in London. Over 300 people have already confirmed their attendance to hear thought leaders from both the regulatory and private sector. Overall, there will be 5 speakers from the regulatory community, over 25 from top


The state of RegTech

Thomson Reuters Regulatory Intelligence originally published this article on 21/12/2017. Thomson Reuters Regulatory Intelligence speaks to important figures in the compliance and financial arena to hear their thoughts and discuss wider issues related to their fields. Today we talk to PJ Di Giammarino founder and CEO of regulatory think-tank JWG–IT, trusted by the global financial


With the implementation date of GDPR just seven months away, firms will need to start getting to grips with the requirements soon to be ushered in under the EU’s flagship regulation for data protection.  As things stand, GDPR will kick in before the UK formally leaves the European Union, meaning that its implications will still


Technology collaboration reduces financial institutions regulatory gap analysis by 85% – linking regulatory obligations to internal policies in a cost effective, automated and auditable fashion. London, UK – 1 November 2017 – JWG, the trusted industry experts in regulatory change management, and ClauseMatch, a leading global provider of document collaboration for financial institutions, legal firms and


RegTech: strategic, automated solutions

Regulation is constantly changing and evolving, reflecting the turbulent and innovative nature of financial services, with hundreds of regulators in different regions and financial spheres formulating regimes and detailing the obligations firms must prove compliance with. The implication for any firm is that keeping track can be a drain on resources – and risky if


GDPR and data security by design

In exactly one year, the General Data Protection Regulation (GDPR) will apply across the European Union, yet firms are struggling to prepare for new data security obligations due to the sheer quantity of regulations due to be enforced in 2018. With the current date of MiFID II being 3 January 2018 and PSD2 due 10


What image is conjured up when you hear the term “cybercriminal”?  A Guy Fawkes mask partially concealed underneath a black hoodie to the accompaniment of sinister music? Whilst this image provides an excellent trope for Saturday night TV, it does not reflect the reality of cybercrime. At our second RegTech Capital Markets Conference, we held


SMCR: one year on…

7 March 2017 marked the first anniversary of the implementation of the Senior Managers and Certification Regime (SMCR). The rules set out by the Financial Conduct Authority and Prudential Regulation Authority seek to instil a culture of conduct and responsibility across the UK banking sector by focusing on individual accountability and placing explicit standards on


On 3 April 2017, ClauseMatch and JWG were pleased to announce the development of a unique solution to simplify and better structure how regulatory changes are driven through internal banking policies. The prototype, linking internal banking policies with constantly changing regulations, was created by senior developers from JWG and ClauseMatch during the autumnal session of


The UK’s departure from the European Union will be a seismic event for the financial sector, requiring extensive planning and transitioning from all corners of the industry.  To implement all of the necessary changes in time, many assumptions will need to be made.  In order to make this more efficient and lower the substantial costs


As the public cloud services market continues to mature and grow – up from $178bn in 2015 to $209bn in 2016, according to research company Gartner[1] – the concentration of computing resources into cloud data centres is increasingly attracting the attention of NPEs as a target for patent litigation.  At a time when data security


The financial services industry is nearing a regulatory crisis point; detailed rules are being written in huge volumes, by regulatory bodies struggling to keep up with their mandates. The result: requirements that are habitually not well contextualised or articulated and often look unlikely to achieve the desired outcomes, but at the same time coming with


Semantics: the key to finance’s food chain

The regulators that oversee the economy are drowning in oceans of data, but need better standards to make sense of it all. The struggle stemming from the lack of standardised data was clearly visible in 2012 when the Commodity Futures Trading Commission (CFTC) needed to trace the so-called ‘London whale’, a trader who accumulated Credit


Fintech, RegTech and operational disruptors

Looking at the FinTech and RegTech conversations in 2017 we find that there is considerable confusion about some basic terms, definitions and relationships amongst policy makers, academics and practitioners alike. The now much more popular term is being used to describe many things. When you say RegTech, do you mean it to be a subset


The common image of a cybercriminal is that of a slovenly, yet highly-skilled, individual sitting alone in a basement having not seen daylight in weeks.  The modern cybercriminal, however, is far removed from this. Cybercriminals are organised in large networks, often well-funded and highly talented which allows them to unleash devastating attacks.  According to online


Technology and the ascent to compliance

The rise of [insert-abbreviation-here]Tech companies signifies a pragmatic shift of business consciousness toward solutions that make use of advances in modern technology. In the banking sector, the magnitude and complexity of firms has immobilised the possibility for innovation. FinTech solutions attempt to combat this issue by producing new and intuitive services for banks and the


Big data and financial regulation share two striking resemblances: both are overwhelming and largely impenetrable to the uninitiated.  Although combining the two is pursued with noble intentions by regulators, the result is a concoction of stress, confusion and frustration for most firms.  This combination, however, is of paramount importance for firms’ and clients’ concerns about


Data reporting under MiFIR

Just before the Christmas break, as part of its quick-fire release of numerous important updates, ESMA published a new Questions and Answers document that covers MiFIR data reporting.  Broken down into two separate sections, the document looks specifically at (i) LEI of the issuer and (ii) date and time of the request of admission and


In our preceding article about ISINs, we explored the pursuit of a universal OTC identifier, and discussed what has occurred in Europe to fix this gap in the financial industry.  The Association of National Numbering Agencies (ANNA) created the ANNA Derivatives Service Bureau, which is based on an automated ISIN allocation engine and is scheduled


At JWG, through tracking key regulatory bodies including ESMA, FCA, FINRA and CFTC, we have picked up key documents for different legislative initiatives such as Dodd-Frank, EMIR, MiFID I, MiFID II and the Commodity Exchange Act. We have sourced over 1000 documents in relation to trade and transaction reporting. In the past month alone, we


ISIN: The quest for an OTC identifier

OTC derivatives, unlike other financial instruments, have never really had a product identifier. Since as early as 2014, regulators’ high expectations for a detailed product identifier for OTC derivatives have caused consternation amongst industry experts as retooling the current infrastructure to the new specifications is an enormous task that could result in hundreds of billions


The Financial Conduct Authority (FCA) published its third consultation paper (CP3) with regards to the implementation of the revised Markets in Financial Instruments Directive (MiFID II) on 29 September 2016. MiFID II, which comes into effect on 3 January 2018, is aimed at making markets more efficient, transparent and responsible.  Strengthening consumer protection is one


Brexit: is equivalence the answer?

On Wednesday 14 September, the EU Financial Affairs Sub-Committee heard evidence from Mr. Simon Gleeson, Partner at Clifford Chance, and Mr. Peter Snowdon, Partner at Norton Rose Fulbright, for its Brexit Inquiry into financial services. Over the course of an hour, the discussion focused on how UK firms might hope to invoke rights of ‘equivalence’


On 18 July 2016, ESMA, the European Securities and Markets Authority, published its advice to the European Parliament, the Council and the Commission on extending the Alternative Investment Fund Managers Directive (AIFMD) passport to 12 non-EU countries: Australia, Bermuda, Canada, the Cayman Islands, Guernsey, Hong Kong, the Isle of Man, Japan, Singapore, Switzerland and the


The FCA have now officially published the findings from their consultation with the industry on the development of RegTech. This is a much awaited document for those seeking to understand the direction of the regulator with regards innovation, particularly in the context of all the recent uncertainty in the wider regulatory landscape. It is evident


Brexit and IT Law (II): Data Protection

This is the second in a series of occasional blogs we’ll be writing about what Brexit means for IT and IT Law in the coming weeks and months. Deirdre Moynihan reviews what Brexit is likely to mean for Data Protection, where the approach to implementing the General Data Protection Regulation could well turn out to


This is the first in a series of occasional blogs we’ll be writing about what Brexit means for IT and IT Law in the coming weeks and months. It looks at the choices facing the UK IT industry around Brexit and Article 50.  In the second, Deirdre Moynihan reviews what Brexit is likely to mean


With the upcoming presidential election on 8 November 2016 and Trump’s growing popularity in the polls over the past few months, it is becoming increasingly important for regulators, banks and other financial institutions to gain a greater understanding of his economic agenda.  Well before he launched his current campaign, Trump attacked increased regulation following the


Instilling a culture of compliance

On 5 July, JWG hosted their RegTech Capital Markets Conference in London, attracting over 150 attendees from top tier banks, buy-side firms, vendors, lawyers and academics from across the industry.  A speech from the FCA’s own Nick Cook at the start of the day told of the clear signs of progress being made and reiterated


Data standards was one of several key themes at the JWG RegTech Capital Markets Conference on 5 July 2016. Conversations about regulatory data standards centre on the need for alignment of data obligations and standards, data protection issues, infrastructure legacy issues and the acquisition and ownership of clean, valid and robust data that can be


Dismantling data standards barriers

The push for increased transparency following the financial crisis has had a visible impact on the financial services industry.  Many regulations have created similar, but slightly different, requirements, in particular across the Atlantic.  Increased – but uncoordinated – demand on data, and proof of process in different formats and languages, without proper impact assessments conducted


The RegTech domains

In our response to the FCA’s call for input on RegTech, we recommended framing the thinking via the RegTech domains to help enable the prioritisation of new technological solutions in the context of external regulatory circumstances. As we have stressed before, RegTech is about the application of technology to solve a specific regulatory problem, not


The first signs of rule automation

In November, the Financial Conduct Authority issued a call for input on facilitating the development and adoption of RegTech, or the use of technology to solve critical problems in compliance.  JWG argued that new and proven tools can be employed but, to do so, the industry must first collaborate in a ‘RegTech commons’ to set


The Fundamental Review of the Trading Book (FRTB) final text was published in January 2016 by the Basel Committee (BCBS).  The aims of the FRTB BCBS standards are to better factor market risk into trading book risk models, and to prevent banks moving instruments between the trading book and the banking book in order to


With JWG’s RegTech conference coming up on 5th July, we thought it wise to spell out a few of the most pressing issues up for discussion on the day. Our first panel – Unblocking the ecosystem* – will provide a comprehensive review of the barriers to RegTech development and adoption. On this topic, we have


In a week which has seen cyber-risk cement itself on the agendas of regulators across the world, we’ve witnessed action in the trading space with plenty of developments occurring in Europe’s markets in financial instruments’ overhaul, as well as a concerted effort to rethink the way in which regulations and regulators work in the financial services industry.


Q1 RegBeacon now available to members

We are pleased to publish the 14th edition of our members only newsletter, RegBeacon. RegBeacon, is now available here. In this quarter we look one of the most contentious periods since the G20 agreed the regulatory reform agenda seven years ago. As politicians, courts, regulators, and firms wrestle with the same issues, we see a