With six months to go, fund managers should be ramping up their preparations for complying with the legislative changes to EU Alternative Investment Fund Managers Directive (“AIFMD”), commonly referred to as “AIFMD 2.0”, which will come into effect on 16 April 2026. The majority of the changes will apply to EU authorised alternative investment fund
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.
Time to Switch: UK Moves to a Single Sanctions List by January 2026
On October 13, 2025, the Foreign, Commonwealth & Development Office (“FCDO”), the Office of Financial Sanctions Implementation (“OFSI”) and His Majesty’s Treasury (“HM Treasury”) confirmed that from January 28, 2026, the UK Sanctions List (“UKSL”) will be the single official source of United Kingdom (UK) sanctions designations.
European Parliament Takes Next Step to Reduce Scope of CSRD
On 8 October 2025, the European Parliament’s Socialists and Democrats (S&D) group ultimately accepted the European People’s Party (EPP)’s position on the Omnibus Directive, which revises the scope of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
Trilogue Negotiations
The next step is for the…
FCA Starts Consultation on UK Motor Finance Consumer Redress Scheme
On 7 October 2025, the FCA published a consultation paper (the “Consultation”) on an industry-wide scheme to compensate motor finance customers who were treated unfairly between 2007 and 2024 (the “Motor Finance Consumer Redress Scheme”). The FCA has also set out steps and its expectations before finalisation of the Motor Finance…
Sustainable Finance Disclosure Regulation: CSSF Turns the ESMA SFDR “Reality Check” into Concrete Expectations with Illustrative Good‑Practice Samples
On 30 September 2025, the Luxembourg regulator, the Commission de Surveillance du Secteur Financier (the “CSSF”), published its feedback report (the “Report”) on the European Supervisory and Markets Authority’s (“ESMA”) 2023–2024 Common Supervisory Action (“CSA”) on sustainability risks and disclosures.
The Report notes generally satisfactory compliance for…
FinReg Monthly Update
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…
Streamlining Consumer Duty – A Welcome Update from the FCA
In recent years, implementation of the FCA Consumer Duty regime has been a significant challenge for most financial services firms. The cross-cutting rules, by their nature, are difficult to interpret and apply especially in a wholesale context, such as in the case of alternative asset managers that use private wealth distribution channels. The FCA has…
Application of the FCA Handbook to Regulated Cryptoasset Activities: FCA CP25/25
Introduction & Summary
On 17 September 2025, the Financial Conduct Authority published CP25/25, proposing how various cross-cutting sections of the FCA Handbook will apply to firms engaging in cryptoasset activities that will become regulated under HM Treasury’s draft Regulatory Activities Order (RAO SI, 29 April 2025).
At present, the FCA’s oversight of crypto…
EIOPA Raises Concerns Over Proposed European Union Climate-Reporting Scope Reduction
At the recent Sustainable Finance Conference, EIOPA Chair Petra Hielkema cautioned against the European Commission’s Omnibus proposal to scale back mandatory sustainability disclosures.
Under the proposal, only about 20% of market participants would be required to report, with the remainder left to disclose voluntarily. Hielkema noted that such an approach risks generating incomplete and inconsistent…
UK Financial Crime Reform: What Firms Need to Know
Overview
The private wealth management sector is uniquely susceptible to financial crime risks, such as fraud, money laundering and sanctions breaches, as highlighted in the FCA’s Dear CEO letter.
Fraud volumes remain at record highs. Private wealth customers have lost significant sums to scams and fraud, and the regulators continue to focus their enforcement…