FCA on conduct regulation for authorised foreign banks

On 13 November, Clive Adamson, FCA director of supervision, delivered a speech on what conduct regulation means for authorised foreign banks (AFBs), and the FCA’s expectations of AFBs. Of particular interest are Adamson’s comments on the FCA’s regulatory approach to AFBs, its thoughts on the emerging business models of overseas banks operating in the UK, and the relevance of the increased risks of financial crime.

Along with the PRA, the FCA is considering the role of branches and subsidiaries. As the FCA’s remit as a conduct regulator applies whether or not a firm passports in or is based in the UK, non-UK firms should be mindful of UK and FCA requirements, particularly of preserving the integrity of the legal entity. The FCA is also striving towards greater clarity of responsibility and accountability in the supervision of international firms so as to avoid firms exploiting situations of regulatory arbitrage…

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