Welcome to the FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK and EU financial services regulation.

Key developments in September 2025:

30 September

FCA Priorities: The United Kingdom Financial Authority (“FCA”) published a speech given by Lucy Castledine, FCA Director of Consumer Investments, providing an update on the FCA’s five-year strategy and its four priorities.

Consumer Duty: The FCA published a number of updates on its future plans for the Consumer Duty: a webpage on how it is streamlining its rules and reducing complexity for businesses; a webpage setting out its areas of focus for 2025/26; and a letter sent to HM Treasury relating to the application to firms primarily engaged in wholesale activity. Please refer to our dedicated article on this topic here.

UK EMIR: The FCA published issue 84 of Market Watch, in which it sets out recent observations from its supervision of the reporting requirements under UK EMIR (648/2012).

26 September

ESG: The European Insurance and Occupational Pensions Authority published a speech given by Petra Hielkema, EIOPA Chair, on the challenges of climate risks and sustainability. Please refer to our dedicated article on this topic here.

23 September

UK/Swiss Regulatory Co-operation: The FCA, together with the Prudential Regulatory Authority (“PRA”) and the Bank of England, has signed a memorandum of understanding with the Swiss Financial Markets Supervisory Authority under the Berne Financial Services Agreement (“BFSA”) that sets out details of the market access arrangements available under the BFSA.

18 September

UK Growth/Competitiveness: The FCA published a speech given by Jessica Rusu, FCA Chief Data, Information and Intelligence Officer, on the importance of innovation and technology to the FCA’s strategy to support growth and competitiveness.

17 September

Cryptoassets: The FCA published a consultation paper (CP25/25) on the application of the FCA Handbook to regulated cryptoasset activities.

12 September

ESG: The European Union’s (the “EU”) General Court has dismissed two legal challenges against the European Commission’s delegated legislation under the Taxonomy Regulation ((EU) 2020/852) (the “Taxonomy Regulation”) (here and here). These rulings confirm the European Commission’s discretion in setting technical screening criteria for sustainable economic activities. Please refer to our dedicated article on this topic here.

11 September

FCA Authorisation: The FCA published an article providing examples of good practice and potential areas for improvement for firms applying to become FCA authorised or registered.

10 September

FCA Quarterly Consultation: The FCA published its 49th quarterly consultation paper (CP25/24).

EU Competitiveness: The European Parliament published a press release announcing it has voted to adopt a report on facilitating the financing of investments and reforms to boost European competitiveness and creating a Capital Markets Union.

9 September

ESG: The Joint Committee of European Supervisory Authorities published its annual report (JC 2025 26) on principal adverse impact (“PAI”) disclosures under the Sustainable Finance Disclosure Regulation (EU/2019/2088) (“SFDR”).

8 September

Market Abuse: The FCA published Market Watch 83 which sets out its observations on corporate finance firms’ systems and controls for handling inside information about their corporate clients.

Payments: HM Treasury published a consultation paper on a streamlined approach to payment systems regulation, focusing on its proposed approach to consolidating the Payment Systems Regulator’s functions within the FCA.

5 September

UK Growth/Competitiveness: The House of Lords Financial Services Regulation Committee published letters from the FCA, PRA and HM Treasury (here, here and here) in relation to its second report on the FCA and PRA’s secondary objective of facilitating the UK economy’s growth and international competitiveness.

3 September

Financial Crime: HM Treasury published a draft statutory instrument and policy note on amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) (“MLRs”) and also opened a technical consultation.

Payments: The Bank of England published a speech by Sarah Breeden, Deputy Governor, Financial Stability, on innovation in money and payments, including stablecoins and real time gross settlement.

2 September

IFPR: the FCA published its IFPR newsletter, which sets out its current expectations on issues relating to the Investment Firms Prudential Regime (“IFPR”).

Financial Crime: HM Treasury and the Home Office have published the Economic Crime Plan 2 outcomes progress report. The report sets out how public and private sectors should work to cut economic crime, protect national security and support the UK’s legitimate economic growth and competitiveness.

For more information, please contact us at ukreg@proskauer.com.

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Photo of John Verwey John Verwey

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge…

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge fund managers as well as institutional managers and advisers, on all aspects of the UK and EU regulatory regimes.

Another key area of focus is advising clients in the financial services sector on mergers and acquisitions, re-organisations and associated regulatory approvals.

John represents a variety of clients that range from small start-up fund managers to established global fund advisers and managers. In The Legal 500, John is noted as “an all-rounder who gets into the details and manages client expectations on navigating tricky regulatory requirements”.

Photo of Anna Maleva-Otto Anna Maleva-Otto

Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in…

Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in the UK, as well as trading on UK and EU markets.

Anna also often assists clients with the design of their compliance policies and procedures, internal investigations and staff training. She frequently participates in industry working groups in connection with new and emerging regulatory initiatives and has advised asset managers on several key pieces of recent EU legislation, including General Data Protection Regulation (GDPR), Short Selling Regulation, Alternative Investment Fund Managers Directive (AIFMD), the second Markets in Financial Instruments Directive (MiFID II), Market Abuse Regulation (MAR), the Securities Financing Transactions Regulation (SFTR), European Market Infrastructure Regulation (EMIR) and Securitization Regulation.

Anna has been named among the world’s 50 Leading Women in Hedge Funds by The Hedge Fund Journal and frequently speaks and writes on topics related to her areas of experience. She has previously co-authored the UK chapter in the Chambers Alternative Funds Guide – a guide examining key industry trends and regulatory and tax matters impacting funds, managers and investors.

Photo of Andrew Wingfield Andrew Wingfield

Andrew Wingfield is an M&A partner and member of the Private Capital Team.

Andrew undertakes a broad range of domestic and cross-border corporate and commercial work for both corporate and private equity clients, advising on acquisitions and disposals, joint ventures, mergers and public…

Andrew Wingfield is an M&A partner and member of the Private Capital Team.

Andrew undertakes a broad range of domestic and cross-border corporate and commercial work for both corporate and private equity clients, advising on acquisitions and disposals, joint ventures, mergers and public takeovers, flotations and equity capital markets and private equity investment.

Andrew is called upon by financial institutions, private equity houses, management and corporates to lead on complex and high-value transactions. Andrew has a very strong financial institutions practice and has been recognized by Chambers UK and Legal 500 in recent years as the “go-to regulatory M&A lawyer” for regulated institutions such as banks, lenders, payment providers, insurance companies, wealth managers or other financial institutions transactions.

In addition, Andrew is widely recognized as a leading M&A and private equity lawyer. In Chambers UK, Andrew has been noted as “dynamic and commercial” and for providing “tailored, practical advice.” A client told Legal 500, “Andrew Wingfield – best lawyer I ever worked with. Super helpful, goes extra mile where needed.”

Photo of Richard Bull Richard Bull

Richard Bull is a partner in the Corporate Department and a member of our Private Equity and Mergers & Acquisitions Groups.

Richard advises on a wide range of corporate work, including M&A, private investments, corporate venturing, joint ventures and corporate restructurings. Richard has…

Richard Bull is a partner in the Corporate Department and a member of our Private Equity and Mergers & Acquisitions Groups.

Richard advises on a wide range of corporate work, including M&A, private investments, corporate venturing, joint ventures and corporate restructurings. Richard has extensive experience of acting on private equity, growth and expansion capital transactions of all types and sizes for sponsors and management teams, both of a domestic and international nature, with a particular focus in the financial services and technology industries.

Richard is described by Legal 500 “as one of the most capable PE lawyers in the market” and “truly excellent.” Richard was also identified by a survey of private equity sponsors undertaken by The Lawyer as one of the top private equity lawyers based in London, and as a highly regarded private equity and M&A lawyer by IFLR 1000.

Photo of Oliver R. Howley Oliver R. Howley

Oliver Howley is a partner in Proskauer’s Technology, Media & Telecommunications Group. He is a trusted advisor to businesses in the technology, manufacturing, sports and financial services sectors, providing valued input on IP, technology and data-related strategies and transactions.

Oliver is a multi-specialist…

Oliver Howley is a partner in Proskauer’s Technology, Media & Telecommunications Group. He is a trusted advisor to businesses in the technology, manufacturing, sports and financial services sectors, providing valued input on IP, technology and data-related strategies and transactions.

Oliver is a multi-specialist, with a day-to-day practice covering commercial contracts, IP, technology and data protection work. He regularly advises on the structuring and terms of contracts relating to the creation, licensing and monetisation of technology and data products, with a particular focus on machine learning and artificial intelligence systems. He also has extensive experience in advising on the IP, technology, data and carve-out aspects of corporate transactions (including joint ventures, acquisitions, disposals and investments) and on sponsorship, image rights and endorsement deals in the sports sector.

Oliver has been recognized as a “Rising Star” in The Legal 500 for consecutive years. Recent professional directories note that “no matter how complex the landscape, no detail escapes [Oliver’s] attention” and that his “logical… and forensic analytical approach make him a force to be reckoned with”. He also receives praise for his commercial contracts work and “niche in robotics and artificial intelligence”.

Photo of Mary Wilks Mary Wilks

Mary Wilks is an Antitrust partner and a member of the Firm’s Private Capital industry group.

Mary advises on a broad range of EU and UK competition law issues, including multijurisdictional mergers, behavioral investigations, complex supply and distribution arrangements, and foreign investment controls…

Mary Wilks is an Antitrust partner and a member of the Firm’s Private Capital industry group.

Mary advises on a broad range of EU and UK competition law issues, including multijurisdictional mergers, behavioral investigations, complex supply and distribution arrangements, and foreign investment controls including, notably, the UK’s newly adopted National Security and Investment Act. She advises clients on the competition aspects of transactions including M&A, equity investments, consortium transactions and secondaries.

Mary works across all sectors, with particular experience in consumer products, healthcare, TMT and financial services.

Mary regularly counsels clients on their engagement with the Competition and Markets Authority, the European Commission, and other prominent international enforcement agencies and regulatory authorities.

Mary Wilks has a reputation as an “excellent lawyer” who “plays a leading role on a range of high-profile cases.” According to sources, “She is always fully on top of the detail but also able to pull out the most important points for the case.

Prior to joining Proskauer, Mary was a counsel in the antitrust, competition and trade department at another leading law firm in London.

Photo of Rachel Lowe Rachel Lowe

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on…

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation. Rachel has also supported with EU MiFID and AIFMD sustainability updates for clients, including from a governance and organizational perspective, as well as providing drafting and training support. She also advises on the Corporate Sustainability Reporting Directive (CSRD), including analysis of its applicability for large international group structures.

From a UK perspective, Rachel supports clients with the TCFD-related requirements in the Financial Conduct Authority’s ESG Sourcebook and is increasingly engaged on the UK’s Sustainability Disclosure Requirements (SDR).

More broadly, Rachel has worked with litigation colleagues to assist clients with understanding and mitigating greenwashing-related legal and regulatory risk.

Photo of Sulaiman Malik Sulaiman Malik

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers…

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers, as well as banks, FinTechs, broker-dealers and governments.

Prior to joining Proskauer, Sulaiman trained at Simmons & Simmons in London, where he was seconded to Brevan Howard. He has also spent time at the UK’s Ministry of Justice and as an adviser to the Mayor of Brisbane, in Australia.

Sulaiman is a passionate advocate for diversity and inclusion. He previously worked at Rare, a market-leading diversity consultancy, and provides pro bono legal advice to a range of community and civil rights organizations.

Photo of Michael Singh Michael Singh

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms…

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms, investment managers, FinTech companies and wealth management businesses.

He is dual-qualified as a German lawyer (“Rechtsanwalt”) and Solicitor of England and Wales and previously was in-house counsel at Deutsche Bank.