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AML & Financial Services Regulatory

United Kingdom: Operationalizing the new financial promotions gateway

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In brief

Following the Treasury’s confirmation that it intends to introduce a new “regulatory gateway” for authorised firms approving financial promotions, the FCA has launched a consultation (CP22/27) on proposals to operationalise this new gateway. Complementing a wider programme of reform to the financial promotions regime, the proposals will affect both authorised firms approving financial promotions as well as unauthorised firms communicating approved financial promotions. In this alert we provide an overview of the gateway structure, explain the FCA’s proposals in more detail, and set out the wider context of reform to the regime.

View the full article here.

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Mark heads the Financial Services & Regulatory (FSR) practice group in London and co-leads the FinTech group. He also acts as Chair of the FSR practice for the EMEA region and sits on the Global FSR Steering Committee. Mark is ranked as a Leading Individual in Legal 500 2022 for Financial Services (Non-Contentious Regulatory) and is individually ranked in Chambers 2022 for FinTech. He is described in these publications as being "very knowledgeable" and "very approachable" with "a wonderful range of FinTech experience" and as someone who is "clear, commercial and pragmatic and understands all the issues in detail." He has authored a number of articles and contributions for leading journals and other publications, most notably the Journal of International Banking and Financial Law, the International Guide to Money Laundering Law and Practice, and A Practitioner's Guide to the Law and Regulation of Financial Crime.

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Philip Annett is a partner based in Baker McKenzie’s London office focussing on complex investigations, litigation and compliance matters. He has an in-depth knowledge of working with UK and international regulators and enforcement agencies, having previously been a senior lawyer in the Enforcement Division at the Financial Conduct Authority (FCA) where he led some of the regulator's highest-profile enforcement cases. He also previously worked in the Bribery and Corruption Division at the Serious Fraud Office.

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Caitlin is a partner in Baker McKenzie’s Financial Services Regulatory practice group, based in the London office.
Caitlin's practice focuses on advising a range of global financial institutions on complex and high value regulatory matters. She advises banks, asset managers, major corporates and payment institutions on navigating UK and EU financial services regulation. She has particular experience in advising clients on regulatory implementation projects, day-to-day compliance issues, and regulatory issues arising in the context of acquisitions, restructurings, and divestments within the financial services sector. Caitlin also advises market infrastructure providers on markets regulation and the provision of cross-border trading solutions.
Caitlin leads our London office’s ESG regulatory work for financial institutions, and advises a range of clients on the drafting and implementation of ESG policies and structuring ESG-focused investment products. Caitlin is an authority on regulatory reforms in the sustainability space and sits on a number of trade association working groups.
Caitlin has been recognised as a "Leading Partner" by The Legal 500 UK, where she is cited by clients as "a great lawyer [who] has a photographic recollection of regulations which makes her an amazing resource for any tricky topic." She is ranked by Chambers for financial services regulation, where clients describe her as "an expert in her field", a "phenomenal regulatory lawyer" and "a highly responsive and excellent communicator" who "consistently provides pragmatic solutions that are within the regulatory framework". Caitlin is also acknowledged by Legal 500 as a Next Generation Partner in Real Estate Funds.

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Kimberly Everitt is Baker McKenzie's knowledge lawyer for Financial Services Regulation & Enforcement, covering the EMEA region, and brings over a decade of experience to the team in both knowledge and fee-earning roles. Prior to joining Baker McKenzie, Kim held roles specializing in contentious financial services regulation knowledge, and her fee-earning roles covered non-contentious regulation in the private equity and general financial services sectors.

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Sarah Williams is an associate in the financial services practice in London. Sarah advises a broad range of clients on financial services legal and regulatory issues. Sarah's practice includes advising on the regulation of payment services and electronic money, investment firms and consumer credit providers and anti-money laundering compliance issues.

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