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Sebastian Barling on Muck Rack

Sebastian Barling

As seen in: Law360, JD Supra, Lexology, Westlaw Today, Law360 UK
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Articles

FCA’s Mills Review Charts a Course for AI-Enabled Retail Financial Services

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By Sebastian Barling, Deborah Kirk
| JD Supra
Executive Summary What’s new: On 6 July 2026, the FCA published the Mills Review, examining how advances in AI could transform retail financial services by 2030 and making seven recommendations to the FCA Board. Why it matters: The Mills Review identifies four systemic shifts by 2030 and concludes the UK’s principles-based framework is a credible foundation for an AI-enabled financial system, but supervision cannot remain firm-by-firm as shared AI dependencies generate ecosystem-level risks.
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Turning AMLR Into Practice: Draft Regulatory Technical Standards on Groupwide Requirements

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By Sebastian Barling, Elsa Benchemhoun
| JD Supra
Executive Summary What’s new: On 16 April 2026, AMLA published a consultation paper setting out draft regulatory technical standards that will in particular require certain EU entities of third-country groups to take responsibility for the wider group’s AML/CFT compliance framework. Why it matters: The draft standards will operationalise key Anti-Money Laundering Regulation groupwide requirements for groups and certain group-equivalent structures across the financial and nonfinancial sectors.
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CRD VI: What US Banks Need to Know

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By Sebastian Barling, Harry A. Ferris
| JD Supra
Executive Summary What’s new: New Article 21c of CRD VI prohibits cross-border provision of “core banking services” into the EU absent an authorised local presence, subject to limited exemptions. Why it matters: The restriction reaches routine wholesale cross-border activity of US banks in Europe, including syndicated facilities, corporate lending, fund finance and guarantees.
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