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Articles by Ciara McBrien
ESAs and UK Regulators Sign Memorandum of Understanding on Cross Border Oversight of Critical ICT Providers under DORA | JD Supra
The European Supervisory Authorities (ESAs) and the UK’s Bank of England, Prudential Regulation Authority and Financial Conduct Authority (together, the UK Regulators) have signed a Memorandum of Understanding (MoU) to coordinate the cross‑border oversight of critical information communication and technology (ICT) third‑party service providers (under the EU regime, CTPPs, and under the UK regime, CTPs) serving EU and UK financial entities.
UK Financial Insights from Katten | Issue 29 | JD Supra
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here. As a sponsor of TOK26: The London Tokenisation Summit, Katten is proud to offer a 30 percent discount on your registration.
FCA Finalises Simplified UK Ancillary Activities Test | JD Supra
[co-author: James Wells] On 19 December 2025, the Financial Conduct Authority (FCA) published a policy statement (PS25/24) finalising the rules and guidance for the Ancillary Activities Test (AAT) under the Ancillary Activities Exemption (AAE). The revised AAT aims to reduce compliance costs and support the competitiveness of the UK commodity derivatives markets.
FCA Finalises Simplified UK Ancillary Activities Test
Carolyn H. Jackson’s articles from Katten Muchin Rosenman LLP are most popular: with readers working within the Oil & Gas industries On 19 December 2025, the Financial Conduct Authority (FCA) published a policy statement (PS25/24) finalising the rules and guidance for the Ancillary Activities Test (AAT) under the Ancillary Activities Exemption (AAE). The revised AAT aims to reduce compliance costs and support the competitiveness of the UK commodity derivatives markets.
FCA Publishes Final Rules on Systematic Internaliser Regime for Bonds and Derivatives and Matched Principal Trading by MTF Operators
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On 28 November 2025, the Financial Conduct Authority (FCA) published a policy statement (PS25/17) finalising rules proposed in its July 2025 consultation paper (CP25/20). The reforms remove the Systematic Internaliser (SI) regime for bonds and derivatives, lift restrictions on matched principal trading by multilateral trading facility (MTF) operators, and reform the reference price waiver (RPW) for equity instruments.
By Christopher Collins, Carolyn Jackson Verified, Nathaniel W. Lalone, Neil Robson, Ciara McBrien, James Wells
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UK Financial Insights from Katten | Issue 29
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here. As a sponsor of TOK26: The London Tokenisation Summit, Katten is proud to offer a 30 percent discount on your registration.
ESAs Publish List of Critical ICT Third Party Service Providers under EU DORA | JD Supra
On 18 November 2025, the European Supervisory Authorities (ESAs) published the first list of designated critical information and communication technology (ICT) thirdparty service providers (CTPPs) under the EU Digital Operational Resilience Act (DORA). The designations mark a major step in operationalising DORA’s thirdparty risk regime, bringing key ICT service providers within a new, EU‑level system of direct oversight.
UK Financial Insights from Katten | Issue 28 | JD Supra
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here. Woodford's appeal against a multimillion-pound fine and ban by the FCA is under scrutiny.
UK EMIR Update: Intragroup Exemption Consultations and Additional Q&As | JD Supra
[co-author: James Wells] On 5 November 2025, HM Treasury (HMT) published a draft statutory instrument, the Over-the Counter-Derivatives (Intragroup Transactions) Regulations 2026 (draft SI), together with a policy note, and the UK Financial Conduct Authority (FCA) published a consultation paper (CP25/30), each proposing significant reforms to the UK European Market Infrastructure Regulation(EMIR) intragroup exemption framework for clearing and bilateral margin.
UK Financial Insights from Katten | Issue 28
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here. Woodford's appeal against a multimillion-pound fine and ban by the FCA is under scrutiny.
ESAs Publish List Of Critical ICT Third Party Service Providers Under EU DORA
Nathaniel W. Lalone’s articles from Katten Muchin Rosenman LLP are most popular: with readers working within the Securities & Investment industries On 18 November 2025, the European Supervisory Authorities (ESAs) published the first list of designated critical information and communication technology (ICT) third party service providers (CTPPs) under the EU Digital Operational Resilience Act (DORA).
FCA Publishes Market Watch Issue 84 on UK EMIR Refit Implementation | JD Supra
[co-author: James Wells] On 30 September 2025, the Financial Conduct Authority (FCA) published issue 84 of Market Watch (Issue 84), providing a one-year review of the UK European Market Infrastructure Regulation (UK EMIR) Refit implementation and its impact on derivatives reporting, data quality and compliance across the UK market. Market Watch is the FCA’s regular newsletter on market conduct and transaction reporting matters.
FCA Publishes Market Watch Issue 84 On UK EMIR Refit Implementation
On 30 September 2025, the Financial Conduct Authority (FCA) published issue 84 of Market Watch (Issue 84), providing a one-year review of the UK European Market Infrastructure Regulation (UK EMIR) Refit implementation and its impact on derivatives reporting, data quality and compliance across the UK market. Market Watch is the FCA's regular newsletter on market conduct and transaction reporting matters.
Privacy, Data and Cybersecurity Quick Clicks | Issue 32
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here.
ESAs Publish Guide on Oversight of Critical ICT Third-Party Service Providers under DORA | JD Supra
The European Supervisory Authorities (ESAs) recently published a comprehensive guide (Guide) on the oversight of critical information and communications technology (ICT) third-party service providers (CTPPs) under the EU Digital Operational Resilience Act (DORA). This Guide marks another step in the implementation of DORA, which aims to strengthen the digital operational resilience of the EU financial sector.
UK Financial Insights from Katten | Issue 25 | JD Supra
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here.
ESAs Publish Guide On Oversight Of Critical ICT Third-Party Service Providers Under DORA
The European Supervisory Authorities (ESAs) recently published a comprehensive guide (Guide) on the oversight of critical information and communications technology (ICT) third-party service providers (CTPPs) under the EU Digital Operational Resilience Act (DORA). This Guide marks another step in the implementation of DORA, which aims to strengthen the digital operational resilience of the EU financial sector.
Navigating Jury Selection Ethics: ABA Opinion 517 Addresses AI Technology, Jury Consultants, and Client Directives
The American Bar Association’s Formal Opinion 517 provides guidance on when attorneys’ use of peremptory challenges may violate Model Rule of Professional Conduct 8.4(g), which prohibits harassment or discrimination based on protected characteristics in conduct related to the practice of law.
Bank Of England Consults On Regulatory Framework For CCPs
The Bank of England (BoE) has published a consultation (Consultation) on the UK's future regulatory framework for central counterparties (CCPs). This initiative forms part of the UK's post-Brexit financial regulatory reform, aiming to restate and, where necessary, enhance the requirements currently set out in the UK European Market Infrastructure Regulation (UK EMIR) within the BoE's own rulebook.
UK Financial Insights from Katten | Issue 25
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here.
Recent Developments to UK EMIR Reporting Requirements | JD Supra
The regulatory landscape for derivatives reporting in the United Kingdom continues to evolve, with the Bank of England (BoE) and the Financial Conduct Authority (FCA) (together, the Regulators) actively refining the UK European Market Infrastructure Regulation (UK EMIR) framework.
Recent Developments To UK EMIR Reporting Requirements
KM Katten Muchin Rosenman LLP More Katten is a firm of first choice for clients seeking sophisticated, high-value legal services globally. Our nationally and internationally recognized practices include corporate, financial markets and funds, insolvency and restructuring, intellectual property, litigation, real estate, structured finance and securitization, transactional tax planning, private credit and private wealth.
Recent Developments to UK EMIR Reporting Requirements
The regulatory landscape for derivatives reporting in the United Kingdom continues to evolve, with the Bank of England (BoE) and the Financial Conduct Authority (FCA) (together, the Regulators) actively refining the UK European Market Infrastructure Regulation (UK EMIR) framework.
FCA Opens UK Retail Access to Crypto Exchange Traded Notes
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On 1 August 2025, the Financial Conduct Authority (FCA) issued a press release (the Press Release) announcing that UK retail consumers will soon be able to access crypto exchange traded notes (cETNs) admitted to trading on UK recognised investment exchanges (RIEs). The FCA’s decision follows a period of market evolution and regulatory engagement.
By Carolyn Jackson Verified, Nathaniel W. Lalone, Neil Robson, Christopher Collins Verified, Ciara McBrien, Sara Portillo
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Lexology
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UK Ancillary Activities Exemption Proposals Published For Commodity Derivatives And Emission Allowances
The Financial Conduct Authority (FCA) recently published a consultation (Consultation) setting out its proposed approach to revising the ancillary activities test (AAT), which forms part of the ancillary activities exemption (AAE) from investment firm authorisation under Markets in Financial Instruments Directive.
UK Financial Insights from Katten | Issue 24 | JD Supra
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here.
UK Ancillary Activities Exemption Proposals Published for Commodity Derivatives and Emission Allowances
The Financial Conduct Authority (FCA) recently published a consultation (Consultation) setting out its proposed approach to revising the ancillary activities test (AAT), which forms part of the ancillary activities exemption (AAE) from investment firm authorisation under Markets in Financial Instruments Directive.
DORA Delegated Regulation On Threat-Led Penetration Testing Published In Official Journal
The Delegated Regulation, which contains regulatory technical standards (RTS) on threat-led penetration testing (TLPT) requirements under the EU Digital Operational Resilience Act (DORA), was recently published in the Official Journal of the European Union.
DORA Delegated Regulation on Threat-Led Penetration Testing Published in Official Journal | JD Supra
The Delegated Regulation, which contains regulatory technical standards (RTS) on threat-led penetration testing (TLPT) requirements under the EU Digital Operational Resilience Act (DORA), was recently published in the Official Journal of the European Union.
WHO NEEDS THE FCC?: Court Holds Cell Numbers Are Residential Numbers for DNC Purposes in First Post-McKesson TCPA Ruling
That was fast. It has only been about a week since the Supreme Court destroyed everything we thought we knew about the TCPA, and we already have our first post-McKesson district court ruling on a critical TCPA issue. Are cell phones “residential” for purposes of DNC protections? That is the question the court answered in Wilson v. Hard Eight, 2025 WL 1784815 (D.
UK Financial Insights from Katten | Issue 22
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here.
Privacy, Data And Cybersecurity Quick Clicks | Issue 28
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here.
UK Financial Insights From Katten | Issue 21
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here.
UK Financial Insights from Katten | Issue 21 | JD Supra
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here.
Privacy, Data and Cybersecurity Quick Clicks | Issue 28 | JD Supra
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here.
HM Treasury And FCA Proposals To Reform Regulation Of UK AIFMs
On 7 April 2025, HM Treasury (HMT) published a consultation (Consultation) on the reform of the UK regulatory regime for alternative investment funds (AIFs) and their managers, alternative investment fund managers (AIFMs[CM1] ), and the Financial Conduct Authority (FCA) simultaneously published a call for input (Call for Input) on how to create a more proportionate, streamlined and simplified regime (the Call for Input and the Consultation together, the Proposals).
HM Treasury and FCA Proposals to Reform Regulation of UK AIFMs | JD Supra
On 7 April 2025, HM Treasury (HMT) published a consultation (Consultation) on the reform of the UK regulatory regime for alternative investment funds (AIFs) and their managers, alternative investment fund managers (AIFMs[CM1] ), and the Financial Conduct Authority (FCA) simultaneously published a call for input (Call for Input) on how to create a more proportionate, streamlined and simplified regime (the Call for Input and the Consultation together, the Proposals).
DORA Compliance: Navigating The Latest Developments
On 24 March 2025, the following two developments relating to the implementation of the EU Digital Operational Resilience Act (DORA) took place: the European Commission (Commission) adopted a Delegated Regulation supplementing DORA with regard to regulatory technical standards (RTS) on the subcontracting of information communication and technology (ICT) services that support critical or important functions (Subcontracting RTS); and the Delegated Regulation supplementing DORA regarding the RTS...
DORA Compliance: Navigating the Latest Developments | JD Supra
On 24 March 2025, the following two developments relating to the implementation of the EU Digital Operational Resilience Act (DORA) took place: the European Commission (Commission) adopted a Delegated Regulation supplementing DORA with regard to regulatory technical standards (RTS) on the subcontracting of information communication and technology (ICT) services that support critical or important functions (Subcontracting RTS); and the Delegated Regulation supplementing DORA regarding the RTS...
Privacy, Data And Cybersecurity Quick Clicks | Issue 27
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here. By Nathaniel Lalone and Ciara McBrien The EU Digital Operational Resilience Act (DORA) took effect on January 17 after a two-year implementation period.
Privacy, Data and Cybersecurity Quick Clicks | Issue 27 | JD Supra
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here. By Nathaniel Lalone and Ciara McBrien The EU Digital Operational Resilience Act (DORA) took effect on January 17 after a two-year implementation period.
Privacy, Data and Cybersecurity Quick Clicks | Issue 27
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here. By Nathaniel Lalone and Ciara McBrien The EU Digital Operational Resilience Act (DORA) took effect on January 17 after a two-year implementation period.
Navigating DORA Compliance: Recent Developments
The EU Digital Operational Resilience Act (DORA) took effect on 17 January 2025 after a two-year implementation period. DORA sets out new requirements for financial entities (FEs) and their information technology and communication (ICT) third-party service providers (TPPs). This note highlights recent developments in the EU's efforts to facilitate in-scope firms' compliance with DORA and authorities' attempts to avoid duplication of operational resilience requirements.
Navigating DORA Compliance: Recent Developments | JD Supra
The EU Digital Operational Resilience Act (DORA) took effect on 17 January 2025 after a two-year implementation period. DORA sets out new requirements for financial entities (FEs) and their information technology and communication (ICT) third-party service providers (TPPs). This note highlights recent developments in the EU’s efforts to facilitate in-scope firms’ compliance with DORA and authorities’ attempts to avoid duplication of operational resilience requirements.
UK Financial Insights From Katten | Issue 19
UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe. To read more issues of UK Financial Insights from Katten, please click here.
ILPA Publishes Updated Reporting Template and New Performance Template
The Institutional Limited Partners Association (ILPA) recently released its updated ILPA reporting template (Reporting Template) and a new ILPA performance template (Performance Template), together with corresponding guidance. The enhancements aim to promote greater standardisation, transparency and comparability in private fund reporting, reflecting the industry's evolving dynamics.
European Commission Rejects Draft DORA RTS On Sub-contracting
The European Commission (Commission) recently published a letter (Letter) that it sent to the European Supervisory Authorities (ESAs) rejecting certain draft regulatory technical standards (RTS) under the EU Digital Operational Resilience Act (DORA). The draft RTS specified the conditions and criteria to be considered by financial entities when sub-contracting information communication and technology (ICT) services supporting critical or important functions.
European Commission Rejects Draft DORA RTS on Sub-contracting | JD Supra
The European Commission (Commission) recently published a letter (Letter) that it sent to the European Supervisory Authorities (ESAs) rejecting certain draft regulatory technical standards (RTS) under the EU Digital Operational Resilience Act (DORA). The draft RTS specified the conditions and criteria to be considered by financial entities when sub-contracting information communication and technology (ICT) services supporting critical or important functions.
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