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

Key developments in January 2026:

Asset Management / Wealth Management

2 February – Client Categorisation: The United Kingdom Financial Conduct Authority’s (“FCA”) consultation paper (CP25/36) on its proposals to amend the client categorisation and conflicts of interest rules closed to comments. Please refer to our dedicated article on this topic here.

15 January – Venture Capital: The European Commission published a targeted consultation on reform of the regulatory frameworks for venture and growth capital funds under its savings and investments union strategy.

9 January – Private Markets: The House of Lords (Financial Services Regulation Committee) published a report on its inquiry into the growth of private markets in the UK following the reforms introduced after 2008.

6 January – Cross‑border Funds Regulation: The European Securities and Markets Authority (“ESMA”) published its third report on marketing requirements and marketing communications under the Regulation on the cross‑border distribution of collective investment undertakings ((EU) 2019/1156).

Sustainable Finance / ESG

30 January – Corporate Reporting: The FCA’s published a consultation seeking views on replacing current sustainability disclosure rules for in‑scope listed companies with UK Sustainability Reporting Standards.

14 January – Sustainability‑Related Claims: ESMA published a thematic note on clear, fair and not misleading sustainability‑related claims that focuses on ESG strategies.

14 January – ESG / Defence: A European Commission notice on the application of the EU sustainable finance framework to the defence sector has been published in the Official Journal of the European Union.

9 January – EU Taxonomy: Commission Delegated Regulation (EU) 2026/73 was published in the Official Journal of the European Union, seeking to simplify certain technical screening criteria for determining whether economic activities cause no significant harm to environmental objectives under the EU Taxonomy.

Financial Crime / Conduct / Sanctions

30 January – UK Sanctions Enforcement: The Office of Financial Sanctions Implementation (“OFSI”) published a response to the consultation paper on improving civil enforcement processes for financial sanctions.

26 January – UK Sanctions Enforcement: OFSI published its latest enforcement data, detailing the actions taken as part of its enforcement of financial sanctions (decisions and monetary penalties imposed).

Cryptoassets / Payments

29 January – Stablecoin Regulation: The House of Lords (Financial Services Regulation Committee) launched an inquiry into the growth and proposed regulation of stablecoins in the UK.

29 January – Cryptoasset Service Providers: ESMA published a webpage of its guidelines for the criteria to assess knowledge and competence of the staff at cryptoasset service providers under the Regulation on markets in cryptoassets ((EU) 2023/1114) (“MiCA”).

28 January – Cryptoassets / Money‑Laundering: OFSI published a blog on its work with UK law enforcement agencies and regulators to tackle the abuse of cryptoassets and associated money laundering activities.

23 January – UK Regulated Cryptoasset Activities: The FCA published a second consultation paper setting out proposals on the application of the FCA Handbook for regulated cryptoasset activities (CP26/4). The paper includes a guidance consultation on the application of the consumer duty to cryptoasset firms (GC26/2).

Artificial Intelligence / Digital Regulation

29 January – UK Digital Financial future: The Bank of England published a speech by Sasha Mills, Executive Director, Financial Market Infrastructure (FMI), given at the Tokenisation Summit, on shaping the UK’s digital financial future.

27 January – AI / Retail Financial Services: The FCA published a press release announcing the launch of a review into the implications of advanced AI on retail financial services, together with a call for input.

20 January – AI / Financial Services: The House of Commons Treasury Committee published a report following its inquiry into AI in financial services.

Banking

22 January – Financial Stability Board: The Financial Stability Board (“FSB”) published its resolution report for 2025, which considers work undertaken by the FSB and its members concerning resolution reforms and sets out the FSB’s 2026 priorities for resolution.

20 January – Basel 3.1: The Prudential Regulation Authority (“PRA”) published a policy statement on its final rules on the implementation of the Basel 3.1 standards (PS1/26).

20 January – UK CRR: The PRA published a policy statement (PS3/26) on its final rules on the restatement of the remaining provisions of the UK Capital Requirements Regulation (575/2013) (“UK CRR”).

15 January – PRA Priorities: The PRA published Dear CEO letters sent to UK deposit‑takers and to international banks setting out its 2026 supervisory priorities and expectations.

9 January – CRD VI: The European Banking Authority (“EBA”) published its final report on draft regulatory technical standards (“RTS”) specifying the booking arrangements third‑country branches must apply for the purposes of Article 48h of the CRD IV Directive (2013/36/EU) (as amended by the CRD VI Directive ((EU) 2024/1619)).

Insurance

29 January – Pure Protection Products: The FCA published the interim findings from its market study into the distribution of pure protection products to retail customers.

20 January – IAIS Roadmap: The International Association of Insurance Supervisors (“IAIS”) published its roadmap for 2026‑27.

19 January – EIOPA Work Programme: The European Insurance and Occupational Pensions Authority (“EIOPA”) published a revised version of its single programming document for 2026 to 2028, which includes its annual work programme for 2026.

16 January – Mutual Life Insurers / Consumer Duty: The FCA published the findings from a multi‑firm review focused on how smaller mutual life insurers meet its Consumer Duty requirements and deliver good customer outcomes.

15 January – PRA Priorities: The PRA published the Dear CEO letter it has sent to insurance firms setting out its supervisory priorities for 2026.

15 January – EIOPA Strategy: EIOPA published a document setting out its areas of strategic activity for the period up to 2030.

EU Financial Markets

15 January – Market Risk: The European Central Bank published its response to the European Commission’s November 2025 consultation on the application of the EU’s prudential framework for market risk.

9 January – ESMA Supervision: ESMA published a document setting out its principles for risk‑based supervision.

U.S. Matters – Private Funds

26 January – New CA Venture Capital Law: California’s Department of Financial Protection and Innovation (“DFPI”) published a survey which entities covered by its new Fair Investment Practices by Venture Capital Companies Law (“FIPVCC”) must submit on an annual basis. The FIPVCC requires certain firms to register with the DFPI and annually report demographic information about the businesses in which they invest. While the law technically only covers “venture capital companies,” this is a very broadly defined term and may pick up many managers that do not pursue a strictly venture capital strategy. The first registration deadline is March 1, 2026 and the first annual reporting deadline is April 1, 2026.

7 January – SEC: The SEC proposed amendments to the definitions of “small entity” it uses for investment advisers and investment companies when considering the impact of its rules as required by the Regulatory Flexibility Act. If adopted, the amendments could substantially impact the rules that the SEC adopts and the manner in which it implements any changes in policy.

2 January – AML Rule: The Department of the Treasury’s Financial Crime Enforcement Network (“FinCEN”) adopted a two‑year delay of the effective date for the investment adviser AML rule, to January 1, 2028. If allowed to go into effect, the investment adviser AML rule will require covered investment adviser firms to establish AML programs, file suspicious activity reports and maintain related records. FinCEN has stated its intent to reconsider and further tailor the rule during this two‑year delay.

2 January – SEC Partisan Composition: Caroline Crenshaw, the last remaining Democratic SEC Commissioner, departed the SEC after the end of her term and subsequent holdover period. The SEC currently has two vacant Commissioner seats on its five‑person Commission. While this has happened a small number of times in the agency’s history, such periods have usually been brief and because of unexpected departures rather than the expiration of a Commissioner’s term.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
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 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 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 Nathan Schuur Nathan Schuur

Nathan Schuur is a partner in the firm’s Private Funds Group and a member of the Corporate Department. He counsels clients on regulatory and compliance matters related to fund formation across all asset classes.

Nate’s practice focuses on regulatory issues arising under the…

Nathan Schuur is a partner in the firm’s Private Funds Group and a member of the Corporate Department. He counsels clients on regulatory and compliance matters related to fund formation across all asset classes.

Nate’s practice focuses on regulatory issues arising under the Advisers Act and Investment Company Act. He advises on regulations surrounding the structuring and operation of funds, including marketing issues, SEC exams, adviser M&A, GP stake sales, continuation funds and stapled transactions. Nate provides legal advice and guidance on a wide range of matters involving the regulation of investment companies, investment advisers, and related entities such as BDCs and ERAs.

Before joining Proskauer, Nate spent several years at the Securities and Exchange Commission. During his time at the SEC, he served as counsel to a Commissioner, where he provided legal and policy advice on rulemaking, enforcement, litigation, and other matters, with a special focus on investment management issues. He also served as senior counsel in the Division of Investment Management. Prior to his SEC tenure, Nate practiced in the funds and regulatory teams of two top law firms. This combination of experience in private practice and at the senior levels of a regulator provides him with valuable perspective in helping funds and advisers navigate complex regulatory requirements and assess risk.

Photo of Robert Sutton Robert Sutton

Robert Sutton is a partner of the Private Funds Group and a member of the Corporate Department. He is a seasoned practitioner with over 20 years of experience counseling managers and advisers of private funds on regulatory matters, as well as regulatory issues…

Robert Sutton is a partner of the Private Funds Group and a member of the Corporate Department. He is a seasoned practitioner with over 20 years of experience counseling managers and advisers of private funds on regulatory matters, as well as regulatory issues related to the formation and operation of private equity, credit, real estate, infrastructure, hedge and other private funds.

Rob has a deep knowledge of the market practice of asset managers and in particular, as it relates to Advisers Act-related issues. From some of the largest and most sophisticated firms in the global asset management industry to start-ups and mid-sized firms, Rob’s experience includes a wide spectrum of funds and asset classes across their life cycles. Rob regularly advises on matters in connection with: U.S. investment adviser registration and regulation; Advisers Act and other U.S. securities law issues relating to the formation, marketing and offering of private funds; Identifying and managing conflicts of interest, and addressing related Advisers Act risks, SEC examinations, and exam readiness preparation; Design and implementation of investment adviser compliance policies and procedures; U.S. regulatory issues relating to purchases and sales of investment advisory businesses (minority stake and control stake transactions, buy-side and sell-side representations); Advisers Act and other U.S. regulatory issues relating to private fund restructurings and recapitalizations, strip sales, continuation fund formations and similar transactions; Advisers Act issues relating to the formation of SPACs by investment advisers; and, Investment Company Act status analyses of private fund structures, investment transaction structures and other non-registered investment company structures.

Rob has been recognized by his clients and peers for his extraordinary work, gaining various accolades including mentions in preeminent directories such as The Legal 500.  He is also very active within the private funds industry, contributing to numerous publications and collaborating on several speaking engagements.

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.

Edward Lister

Edward Lister is a special regulatory counsel and a member of the Private Equity Transactions and Mergers & Acquisitions Groups.

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 Sasha Burger Sasha Burger

Sasha Burger is an associate in the Corporate Department and a member of the Private Investment Funds Group.

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.