The case involves substantive litigation that could yield important legal principles for the treatment of decentralised projects.

By Dominic Geiser, Simon Hawkins, Sam Maxson, and Truman Mak

Decentralised autonomous organisations (DAO) are unique structures that operate autonomously in accordance with preset rules, utilising a blockchain and coordinated through a distributed consensus model. Whilst numerous DAOs are operating in the blockchain industry, these organisations are still new in legal terms and their precise legal status (including ownership and

Despite some adjustments to the proposed guardrails, the FCA has largely retained its original approach.

By Rob Moulton, Nicola Higgs, Sean Wells, and Charlotte Collins

On 26 July 2024, the FCA published its final rules on payment optionality for investment research (PS24/9). The FCA consulted on these changes in April 2024 (see this Latham blog post), proposing to introduce additional optionality for buy-side firms by permitting them to use bundled payments for research and

The SFC exercises its powers to order the suspension of trading in shares in a listed company to protect investors’ interests.

By Dominic Geiser, Truman Mak, Evangeline Tsui, and Charlotte Wong

On 15 April 2024, The Stock Exchange of Hong Kong Limited (SEHK) suspended trading in the shares of Tianyun International Holdings Limited (Company) pursuant to directions from the Securities and Futures Commission of Hong Kong (SFC). In ordering the suspension, the SFC exercised its powers under section 8(1) of the Securities and Futures (Stock Market Listing) Rules (SMLR), which empowers the SFC to make such directions to maintain an orderly and fair market and protect the investing public’s interests.

The FCA is proposing to allow asset managers to rebundle payments for third-party research and trade execution.

By Rob Moulton, Nicola Higgs, and Charlotte Collins

On 10 April 2024, the FCA published its much-anticipated Consultation Paper on payment optionality for investment research (CP24/7). The Investment Research Review made a series of recommendations in the summer of 2023 to help boost the UK investment research market, which the government committed to taking forward (see this Latham blog post).

Fighting financial crime, protecting consumers’ needs, and bolstering wholesale markets are the regulator’s key priorities for the year ahead.

By Rob Moulton, Nicola Higgs, Becky Critchley, and Charlotte Collins

On 19 March 2024, the FCA published its Business Plan for 2024/25, setting out its priorities for the year ahead. While the Business Plan now takes on less significance than it did historically given other publications in circulation such as the FCA’s 3-year Strategy and the Regulatory

The FCA found that wholesale data markets can be improved, but has ruled out a significant intervention.

By David Little, Becky Critchley, Oscar Hayward, and Effie Stathaki

The FCA has published the findings of its wholesale data market study (MS23/1.5), which examined competition in the markets for credit ratings data, benchmarks, and market data vendor services. It follows the publication of an Update Report in August 2023, which outlined the FCA’s provisional findings regarding potential

This annual publication explores some of the core focus areas for UK-regulated financial services firms in the year ahead. 2023 saw significant progress on the regulatory reform agenda, and many measures consulted on or reviewed as part of the Edinburgh Reforms will be finalised and/or implemented in the course of 2024.

We also saw the passing of the Financial Services and Markets Act 2023, many provisions of which have already come into effect and have made important changes to the

As the pace of reform increases, we take a look at key developments and the timeline ahead.

Significant progress has been made on the Edinburgh Reforms since they were announced in December 2022, with developments gathering pace before the summer break. Given the breadth and speed of the reforms, now is a good time to take stock of where things stand and what we can expect in the months ahead. In this publication, we highlight some of the key developments and set out expected dates for future progress.

The Review recommends scrapping research unbundling, but also proposes a range of other changes to the UK research landscape.

By Rob Moulton, Chris Horton, Sean Wells, Charlotte Collins, and Johannes Poon

On 10 July 2023, HM Treasury published the final report produced by the independent UK Investment Research Review (Review). The Review was launched on 9 March 2023 to examine the link between levels of research and the UK’s attractiveness as a destination for companies to access capital (please see Latham’s previous blog post for the background to the Review).

The report makes seven recommendations which the government has committed to taking forward. While the recommendation to remove the research unbundling requirements was expected, the Review has taken a more holistic approach and the report puts forward wide-ranging suggestions for improving the UK investment research landscape. The recommendations are summarised below.

UK regulator follows the European Securities and Markets Authority in clarifying the scope of the trading venue perimeter.

By Nicola Higgs and Sidhartha Lal

On 5 July 2023, the FCA published its Policy Statement (PS23/11) containing final guidance on the trading venue perimeter, following its September 2022 consultation on the same matter.

The new guidance will sit in the Perimeter Guidance manual (PERG) of the FCA Handbook, using a Q&A format, and is intended to clarify the regulator’s interpretation of the different elements within the definition of a multilateral system and how it applies to specific types of arrangements in financial markets. The Policy Statement represents the conclusion of the FCA’s assessment of the trading venue perimeter. ESMA conducted an analogous review and published its Final Report in February 2023.