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

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, 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.
UK Change in Control Regime – New Guidance published by the FCA and PRA
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…
European Commission publishes FAQs on CSRD and SFDR
On 13 November 2024, the European Commission published 90 frequently asked questions (‘‘FAQs’’) with the aim of enhancing stakeholders’ understanding and compliance with the sustainability reporting requirements under the Corporate Sustainability Reporting Directive ((EU) 2022/2464) (‘‘CSRD’’) and the Sustainable Finance Disclosure Regulation ((EU) 2019/2088) (‘‘SFDR’’).…
UK Doubles-Down on Sustainable Finance
On 14 November 2024, Rachel Reeves set out in her first Mansion House Speech that “sustainable finance” was to be one of the UK’s five priorities in the government’s Financial Services Growth and Competitiveness Strategy (the “Strategy”).
On the same day, representing HM Treasury at COP29, Growth Minister Lord Spencer Livermore laid out…
FCA’s ‘Co-Manufacturer’ Classification and Its Impact on Financial Services
In the evolving landscape of financial services, there have been reports that the Financial Conduct Authority (FCA) has recently classified FNZ, a prominent wealth management platform provider, as a ‘co-manufacturer’ of financial products. This designation carries significant regulatory implications, underscoring the critical role of product governance in ensuring consumer protection and market integrity.
Understanding the
…Mansion House Speech 2024 – Growth and Competitiveness
Background
On 14 November 2024, the United Kingdom’s Chancellor of the Exchequer delivered a speech setting out the UK Government’s vision to grow and enhance the competitiveness of the financial services sector (the “Speech”).
The key measures discussed in the Speech are summarised below, broadly split into two categories – investment and reform.
FRC Launches Consultation on UK Stewardship Code
On 11 November 2024, the Financial Reporting Council (“FRC”) launched a consultation with significant updates proposed to the UK Stewardship Code (the “Code”). The aims of the consultation are to streamline reporting requirements and reduce burdens for signatories whilst ensuring there is a clearer purpose of the Code and the outcomes…
ESMA’s 2024 Enforcement Priorities: Spotlight on Sustainability and EU Taxonomy Compliance
On 24 October 2024, the European Securities and Markets Authority (“ESMA“) released its 2024 European Common Enforcement Priorities (“ECEP“) for corporate reporting, drawing particular attention to sustainability and taxonomy-related disclosures. With the backdrop of Europe’s ambitious climate objectives and the growing impact of environmental, social, and governance (“ESG“) factors…
ESG Ratings Regulation progresses – asset managers to keep watch
UPDATE: On 19 November 2024, the Council of the EU issued a press release confirming it had adopted the EU Ratings Regulation. The next step is that the Regulation will be published in the Official Journal of the EU and enter into force 20 days later – applying 18 months after is entry into force.…
FCA publishes paper on nature-related risk for financial institutions
The FCA’s Climate Financial Risk Forum has published a paper on “Nature-related Risk: Technical Data Guidance for Financial Institutions” (the ‘‘Paper’’).
What does the FCA’s Paper cover?
The Paper serves as a useful summary of the potential relevance of nature on financial institutions and covers the following fundamental concepts:
- The nature data landscape;