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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.

On 8 January 2025, the EU Platform on Sustainable Finance (PSF) published a draft report and launched a call for feedback on proposed updates to the EU taxonomy. This includes revisions to the Climate Delegated Act and new technical screening criteria. Stakeholders are invited to submit feedback by 5 February 2025.

Key areas sought for

Welcome to the UK Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation.

Key developments in December 2024:

20 December:

FCA Handbook: The Financial Conduct Authority (‘‘FCA’’) published Handbook Notice 125, setting out changes to the FCA Handbook made by the FCA board on

On 17 December 2024, the EU Platform on Sustainable Finance (the “Platform”), an advisory body to the European Commission (the “Commission”), has published a briefing note to the Commission, outlining their proposals for a new categorization system for sustainable finance products (the “Proposal”).  This is intended to be in replacement of the current regime under

On 12 December 2024, the European Securities and Markets Authority (“ESMA”) published a consultation paper (“Consultation”) on draft regulatory technical standards relating to open-ended loan originating AIFs under the revised Alternative Investment Fund Managers Directive (EU/2024/927) (“AIFMD 2”).

Purpose of the Consultation

AIFMD 2 stipulates that loan-originating AIFs should

On 13 December 2024, the European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published Q&As with further details on three specific aspects of the practical application of their Guidelines on funds’ names using ESG or sustainability-related terms (the Guidelines). 

The Q&As cover:

  • meaningfully investing in sustainable investments

Welcome to the Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation.

Key developments in November 2024:

29 November

Financial Crime: The Financial Conduct Authority (“FCA”) published a policy statement (PS24/17) setting out changes to its Financial Crime Guide.

FCA Handbook: The FCA published Handbook

On 15 October 2024, the Luxembourg Commission de Surveillance du Secteur Financier (the “CSSF”) imposed a fine of EUR 56,500 against a fund manager, Aviva Investors Luxembourg S.A. (the “Manager”), with regards to the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (the “SFDR”). This marked the CSSF’s first ever sanction

Background

In the United Kingdom, prior approval must be obtained from the Financial Conduct Authority (the “FCA”) or the Prudential Regulation Authority (the “PRA”) prior to becoming a “controller” of an FCA or PRA authorised firm (an “Authorised Firm”).

Such approval is obtained via a “change in control” filing