Expertise
Paul has specialised in financial services law and regulation for over 25 years. Clients range from wholesale to retail and include banks, fund managers, investment managers, advisory, discretionary services, platform services, regulated funds, insurance, payment and e-money products and intermediary activities across the full remit of FSMA. Paul engages with firms across board, senior management, legal, risk and compliance and has lead projects including new authorisations, variations of permission, change in control, responses to regulatory information request, s166 (both acting for the FCA and for firms) and regulatory and compliance review projects.
During the life of the regulated firm, a multitude of issues can arise from day-to-day operations through to major strategic and risk decisions. Paul’s experienced support can help firms through the myriad of issues to get the right outcomes. His rare experience seeing both the regulator side and industry side provides valued and pragmatic support for clients.
Paul trains and qualified in the City, worked at a magic circle firm and in-house at a wealth manager / private bank and has been seconded to a fund platform.
- Experience
Relevant experience includes:
- Authorisations: supporting applicants successfully achieve first time authorisation approval from various regulators, including firm authorisations, new fund authorisations (UCITS/non-UCITS/COLL), sensitive business names, Variation of Permission. .
- Advising UK and overseas clients on the regulatory perimeter, exclusions and structures.
- Advising fund and wealth management sector clients on custody and administration and reflecting disclosures in client agreements (e.g. models A/B).
- Advising on MiFID activities and exclusions, including in relation to energy, commodities and exclusions.
- Supporting an EU regulator in the assessment of the fitness and propriety of a licensed bank.
- Advising deposit takers in relation to joining deposit taking platforms, including under ISA structures.
- Advising a fund platform in relation to regulatory obligations including, transaction reporting, execution arrangements and contractual implications.
- Advising on the Principal and AR relationship for both Principal and AR firms, including supporting a Principal firm in discussions with the regulator. Completing a Principal firm due diligence exercise to ensure oversight and control of the ARs was compliant.
- Advising on disclosure and transparency rules applicable to a market participant, close periods and RNS disclosure.
- s166 and shadow s166 reviews: Acting as s166 expert for the FCA and on shadow s166 relating to financial crime, suitability and systems and controls issues.
- Advising on the nature of insurance contracts across various sectors, including tick cover under CLIP arrangements, performance bonds and insurance law and group cover arrangements.
- Advising on insurance mediation regulation.
- Publications
- Paul has acted as editor of the Virtual Currency Law Review (2002-25)
- Paul is a contributing editor to three chapters for Butterworths Financial Regulation Service