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The Financial Conduct Authority (FCA) has published a policy statement (PS25/9: New rules for the public offers and admissions to trading regime) under which it sets out the rules for the new regime that will apply in respect of prospectuses. This follows the consultation process the FCA undertook via the previous publication of consultation papers CP 25/2 and CP 24/12. The Public Offers and Admissions to Trading Regulations 2024 (POATRs) will replace the UK Prospectus Regulation (UKPR). The POATRs are generally in line with the proposals consulted on, with some modifications to reflect feedback from market participants. The new rules will come into effect on 19 January 2026.

At the Annual Compliance conference recently held in London, the session on ‘Supply chains – Navigating ESG and Trade-related Risks’ examined the intensifying ESG and trade-related risks facing global supply chains, shaped by shifting political priorities and evolving regulatory frameworks.

At the Annual Compliance conference recently held in London, we were honoured to hear from Baroness Hodge at our Annual Compliance Conference. Baroness Hodge offered a candid and comprehensive overview of the UK’s ongoing challenges and opportunities in tackling economic crime, tax avoidance, and illicit finance.

At the Annual Compliance conference recently held in London, the session on ‘US and UK Enforcement in the Current Climate: Strategic Shifts and Global Implications’ explored the evolving enforcement landscape across the UK, US, and Latin America, with a particular focus on strategic priorities, inter-agency cooperation, and the practical implications of recent policy shifts.

The Court of Appeal has held that dismissing an employee for a social media post expressing gender critical beliefs and beliefs on same sex marriage was disproportionate, and therefore discriminatory. This decision confirms the legal tests for balancing conflicting protected beliefs, underscoring the basic principle that employees have the right to manifest their religious or philosophical beliefs, subject only to limited, objectively justifiable exceptions. While the post was arguably offensive to some gay and/or trans people, expressing a protected belief that is offensive to others does not by itself justify disciplinary action; there must be something objectively objectionable in the manner of expression. This is a high threshold; merely “intemperate” language is not sufficient.

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.