Investment Management Update - January 2024

HM Treasury has published a consultation proposing a significant overhaul of the UK's payment services and electronic money regulatory framework, aiming to create a more agile regime that accommodates tokenised payments, open banking innovations, and agentic AI while maintaining consumer protections and addressing financial crime risks.

The UK's Financial Conduct Authority has finalized comprehensive perimeter guidance for its cryptoasset regime, opening a five-month authorization window for firms, while the US Senate's procedural rejection of the CLARITY Act leaves American digital asset regulation to continue through agency action. This divergence highlights fundamentally different regulatory approaches: a legislatively anchored UK implementation path versus US reliance on existing statutory authorities as Congress debates market structu

The Financial Conduct Authority has released comprehensive perimeter guidance for the UK's new regulated cryptoasset activities regime, clarifying when firms will need authorization and how the regulatory framework applies to qualifying cryptoassets and stablecoins. The guidance addresses critical questions about scope, territorial application, and the narrower "by way of business" test that determines which entities fall under the new regulatory requirements.

Islamic finance is experiencing rapid global expansion, with assets approaching US$6tn and record sukuk issuance attracting non-traditional investors. The convergence of Shariah-compliant and sustainable investing is creating new opportunities, while AAOIFI Standard No. 62 and tokenisation developments are reshaping how Islamic finance structures are designed and implemented across international markets.

The London Stock Exchange has implemented sweeping reforms to the AIM Rules, fundamentally reshaping admission requirements, transaction thresholds, and governance obligations for companies on the Alternative Investment Market. These changes eliminate longstanding requirements like working capital statements and corporate governance codes while introducing new features such as capital access windows and special voting shares, marking the most significant overhaul of AIM regulations in recent years.

The Financial Conduct Authority has released a comprehensive package of regulatory updates and findings covering investment management, wealth management, and consumer protection. Key developments include reforms to MiFID costs and charges disclosures, remuneration code changes, AIFM regime overhauls, and detailed reviews of firms' Consumer Duty compliance, financial crime controls, and governance frameworks.

Cryptoasset firms face a rapidly evolving regulatory landscape as the FCA's authorisation gateway opens on 30 September 2026. With the Financial Services and Markets Act 2000 (Cryptoassets) (Miscellaneous Amendments) Regulations 2026 laid before Parliament and the FCA's finalised PERG 18 guidance published within 24 hours, firms must navigate significant perimeter changes including new stablecoin payment exclusions.

On 14 July 2026, HM Treasury published its long-awaited consultation on modernising the UK’s payment services and electronic money regulatory framework. The consultation is part of the Government’s National Payments Vision agenda, which aims to ensure that the UK has a trusted, world-leading payments ecosystem delivered on next generation technology, while preserving choice for consumers and businesses.

The FCA has published Policy Statement PS26/15, “Improving the UK transaction reporting regime,” confirming its final rules following last year’s consultation CP25/32.

From 2 August 2026, the EU AI Act introduces mandatory transparency obligations requiring anyone using AI professionally in the EU market to disclose AI-generated or manipulated audio, video, images, and certain text content. These obligations apply to both AI providers and deployers, with non-compliance potentially resulting in fines of up to €15 million or 3% of global turnover.

The autumn 2026 edition of the Reward update examines significant proposals to reform directors' remuneration reporting requirements, including changes to the DRR and removal of the annual shareholder advisory vote. It also covers FCA consultation on solo-regulated firms' remuneration, the impact of Employment Rights Act changes on share plans, equal pay reform proposals, and updates to AIM rules affecting corporate governance and remuneration disclosure.

Google has launched appeals against the European Commission's Digital Markets Act enforcement, challenging binding specification decisions that require it to open Android features to competing...

The European Commission's broad information-gathering powers under EU competition law have been reinforced by the General Court's dismissal of Broadcom's challenge to document production requests. The case raises critical questions about the extent to which the Commission can compel production of documents held overseas that are subject to legal professional privilege in other jurisdictions, particularly communications with non-EU qualified external counsel.

The Financial Conduct Authority has released a comprehensive package of regulatory updates and findings covering investment management, wealth management, and consumer protection. Key developments include reforms to MiFID costs and charges disclosures, remuneration code changes, AIFM regime overhauls, and detailed reviews of firms' Consumer Duty compliance, financial crime controls, and governance frameworks.

Governments across the UK and Europe have announced ambitious infrastructure programmes they cannot fund alone, creating significant opportunities for private capital. As public authorities shift from subsidy-based models to regulatory reform, investors must navigate an increasingly complex web of concurrent regulatory regimes - from merger control and national security screening to data protection and PFI handback obligations - to successfully deploy capital in this evolving landscape.

The UK Government's decision not to include a new investor visa route in the upcoming Budget may appear to be a setback for wealthy individuals seeking UK residence, but the reality suggests otherwise.

On 26 February 2026, the European Securities and Markets Authority (ESMA) published a supervisory briefing to aid national competent authorities (NCAs) with their supervision of algorithmic trading in the EU...

The October 2026 edition examines significant competition law developments across the UK and EU, including the European Commission's final guidelines on exclusionary abuses of dominance...

The US Treasury repo market faces a fundamental transformation as SEC rules mandate central clearing for most Treasury repurchase transactions by June 2027. This regulatory shift is accelerating buy-side adoption of "sponsored repo" arrangements, requiring firms to navigate new operational frameworks, documentation requirements, and clearing relationships. Understanding the mechanics of sponsored membership and preparing for compliance will be critical for buy-side participants seeking to maintain efficient