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Kimberly Everitt

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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.

On 27 January 2026 the Financial Conduct Authority (FCA) launched the Mills Review to examine the long-term impact of AI on financial services. Led by Sheldon Mills, this initiative invites industry feedback to help shape how AI might transform consumer experiences, market structures, and regulatory approaches in retail financial services. The call for input closes on 24 February, following which Mills will present recommendations to the FCA board in the summer, culminating in an external publication to foster informed debate.

On 4 February 2024, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 were made, establishing a comprehensive regulatory framework for cryptoassets in the UK. Under this new regime, cryptoasset firms falling within scope will be subject to regulatory requirements, including, where relevant, authorisation by the FCA. The Cryptoassets Regulations define the categories of cryptoassets and activities subject to regulation, expand the scope of the financial promotions regime to align with the new regulated activities, and make provision for rules relating to market abuse and public offers. The new regime will take effect on 25 October 2027, with the authorisation gateway opening in September 2026. UK cryptoasset firms should review their current and planned activities to determine if they fall within the scope of the new regime, and those seeking authorisation should start engaging with the process now to ensure they are prepared to move quickly once the gateway opens.

On 4 December 2025, the European Commission introduced the Market Integration & Supervision (MIS) Package to strengthen EU financial market integration.
Key points:
• Direct ESMA oversight of major financial entities and cryptoasset service providers.
• Harmonized rules by converting key directives into regulations for consistent application.
• Goal: Improve market integrity, investor protection, and reduce fragmentation.
Implementation will take several years, with no immediate changes expected.

On 18 July 2024, the UK Financial Conduct Authority (FCA) published the findings of its multi-firm review on firms’ treatment of politically exposed persons (PEPs). This review is likely to be of interest to family offices and their advisers for the following reasons:
• UBOs of family offices are often treated as being within the scope of the PEP categorization.
• An overly restrictive approach to KYC and AML controls on the part of financial institutions can create friction and delays for family offices and their UBOs, and the FCA’s findings may provide some basis to push back on or query the approach on this point (see below).
• Given the FCA’s strong public stance on the PEP issue, we may see other global regulators following the UK’s lead in the future.

On 26 July 2024, in response to the UK Government’s Investment Research Review on the effectiveness of the investment research market, the FCA published its final rules and guidance to permit the bundling of payments for investment research and trade execution by investment firms. The final rules, which took effect on 1 August 2024, adapt the FCA’s policy to evolving markets and better align with the regulatory position in the EU and US. The FCA has now proposed to extend reintroduction of the bundled payment model to managers of pooled funds – i.e., AIFMs and UCITS ManCos.

The new EU Capital Requirements Directive establishes a new harmonized and more restrictive framework for cross-border banking and lending into the EU. The new third country branch rules will prohibit the provision of certain banking services into the EU on a cross-border basis by firms outside the EU, unless done in accordance with limited exemptions.

On 13 February 2024, the FCA issued a Final Notice to Floris Jakobus Huisamen, the former director and compliance officer of London Capital & Finance plc (LCF), fining him GBP 31,800 and banning him from working in financial services in relation to misconduct connected to financial promotions issued by LCF. This Final Notice follows the FCA’s previous censure of LCF in October 2023 for connected behaviour. In this alert we draw out the key takeaways that compliance officers should bear in mind from the FCA’s enforcement action.

On 13 February 2024, the FCA issued a Final Notice to Floris Jakobus Huisamen, the former director and compliance officer of London Capital & Finance plc (LCF), fining him GBP 31,800 and banning him from working in financial services in relation to misconduct connected to financial promotions issued by LCF. This Final Notice follows the FCA’s previous censure of LCF in October 2023 for connected behaviour. In this alert we draw out the key takeaways that compliance officers should bear in mind from the FCA’s enforcement action.

We are pleased to share with you our annual briefing looking at financial services regulation and enforcement in 2024, “What does 2024 hold? Key upcoming developments and enforcement trends”.

With Brexit and the pandemic firmly in the rear-view mirror, and the geopolitical ebb-and-flow settling into a somewhat more stable – if preciously perched – pattern, regulators around the world have turned their attention to less reactive, more forward-looking actions. Our London Financial Institutions Regulatory and Enforcement experts explore the key developments and trends expected to dominate the regulatory landscape this year.