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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.

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

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

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”). These rulings confirm the European Commission’s discretion in setting technical screening criteria for sustainable economic activities.

Nuclear and Gas: Austria v Commission (Case

Why this matters

The FCA has completed a major review of safeguarding for payment and e-money institutions. Its new rules are designed to reduce the risks seen in recent failures – where customers faced long delays and, on average, recovered only 35 per cent of the funds they were owed.

At the same time, the

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

Key developments in August 2025:

28 August

FCA Communications: The UK Financial Conduct Authority (“FCA”) published an update on its approach to simplifying supervisory communications, aiming to make its engagement with firms clearer

On 31 July 2025, the European Financial Reporting Advisory Group (EFRAG) launched its much anticipated 60-day consultation on the revised and simplified European Sustainability Reporting Standards (ESRS) for companies in scope of the Corporate Sustainability Reporting Directive (CSRD).

EFRAG’s mandate from the European Commission, received in March 2025, as part of the “Omnibus” initiative to

A Commission Transparency Reckoning for Financial Services

On 1 August 2025, the Supreme Court handed down its long-awaited judgment in Johnson v FirstRand Bank Ltd, Wrench v FirstRand Bank Ltd and Hopcraft & Anor v Close Brothers Ltd – reported together as [2025] UKSC 33.

The Court dismissed fiduciary duty and bribery claims but upheld