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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 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.

With one month to go, fund managers should be ramping up their preparations for complying with the legislative changes to European Union (“EU”) Alternative Investment Fund Managers Directive (“AIFMD”), commonly referred to as “AIFMD 2.0”, which will come into effect in EU member countries on 16 April 2026.

The majority of the changes will apply

On 12 February 2026, HM Treasury published a Consultation Paper on reforming the Appointed Representatives regime (“ARs” and the “AR Regime”). The Consultation Paper builds on the Policy Statement published by HM Treasury on 11 August 2025, which contained the Government’s initial proposals for legislative changes designed to ensure continued confidence

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

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 December 2025:

Asset Management / Wealth Management

18 December – AIFMD 2.0 Liquidity Management Tools: European Securities and Markets Authority (“ESMA”) published an amended version of its guidelines on

On 15 December 2025, HM Treasury took a significant step towards establishing a UK regulatory regime for cryptoassets by laying the draft ‘Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2005’ (the “Draft Order”) before Parliament.

The Draft Order aims to set the statutory foundation for a new UK cryptoasset regulatory regime

On 9 December 2025, negotiators from the European Parliament (EP), the Council of the European Union (the Council) and the European Commission reached a provisional political agreement on the final text of their “Omnibus” package amending the Corporate Sustainability Reporting Directive (CSRD).

Though the final text is not yet published, the publicly-available press-releases confirm a

Background

On 8 December 2025, the United Kingdom’s Financial Conduct Authority (“FCA”) published a consultation paper (CP25/36) on amending its rules on client categorisation and conflicts of interest (the “Consultation Paper”).

The Consultation Paper is seeking to reset how firms distinguish between retail and professional clients, as the rules currently stem

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 November 2025:

Asset Management / Wealth Management

17 November – Liquidity Management RTS: The European Commission has adopted Delegated Regulations containing regulatory technical standards (RTS) on liquidity management tools under the Alternative