Posts by Nathan Tse

Regulatory Updates April 2026

Our regulatory newsletter aims to provide insight into the changes and updates which may have an impact on your firm. At Objectivus we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: FCA sets out next phase of smarter and more effective regulation FCA…

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Litigation risk is moving through the transaction chain

  Focus is shifting beyond trading desks into custody, settlement and intermediary roles Recent financial litigation has focused on trading activity but that focus is beginning to shift. Much of the attention in recent cases has been on trading desks and transaction origination. As matters develop, scrutiny is beginning to move further along the transaction…

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Synthetic Exposure and the Next Regulatory Phase – Total Return Swaps and the Technical Evolution of Dividend Equivalents

Executive Summary: While the primary focus of regulators has historically been on cash shares and physical distributions, the landscape of market oversight is evolving. This article examines how derivatives, such as Total Return Swaps (TRS), are becoming a focal point for withholding tax (WHT) scrutiny and what this means for the technical oversight and reporting…

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The Challenge of Historical Data Reconstruction – Regulatory Retrospection and the Technical Reality of Legacy Systems

Executive Summary: As the timeline for investigations into historical market practices stretches back over a decade, the primary obstacle for institutions has become the degradation of institutional data. This article explores the technical difficulties of reconstructing historical settlement logic within a modern regulatory framework and the importance of objective forensic analysis when examining systems from…

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An Operational Perspective on Post-Trade Infrastructure

  Technical Architecture and the Attribution of Post-Trade Liability Executive Summary: As regulatory scrutiny of historical dividend arbitrage continues in 2026, the focus has increasingly moved to the post-trade environment. For clearing houses and custodian banks, the challenge lies in providing a technical explanation of how legacy settlement systems functioned during periods of high volume…

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2026 Reform of the Appointed Representatives Regime: A Complete SEO‑Optimised Guide for GRC Leaders

  In February 2026, HM Treasury released a consultation proposing significant reforms to the UK’s Appointed Representatives (AR) regime, a framework currently used by around 34,000 ARs operating under approximately 2,400 authorised principal firms. Although these reforms are not yet in force, the consultation signals the clearest regulatory direction of travel since the Financial Services…

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Regulatory Updates January 2026

Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: FCA publishes consultation on remaining cryptoasset perimeter and broader regulatory…

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AI Accountability – Why “I Didn’t Understand It” Is No Defence

UK regulators are sending a clear message to senior managers. If artificial intelligence causes harm on your watch, you will still be held accountable. In January, Parliament’s Treasury Committee warned that the FCA expects senior managers to understand any AI systems used within their area of responsibility. The difficulty is that many AI tools are…

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FCA CP26/4: Application of the FCA Handbook for Regulated Cryptoasset Activities

  The Financial Conduct Authority has published Consultation Paper CP26/4 setting out how key parts of the FCA Handbook will apply to firms undertaking newly regulated cryptoasset activities in the UK. This is a key step towards the UK’s future cryptoasset regulatory regime and confirms that crypto firms will be subject to the same governance,…

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Expert Evidence in Financial Services Enforcement

  Why cases are increasingly shaped before they are ever heard In financial services enforcement and contested supervisory action, the landscape is shifting. Increasingly, outcomes are being shaped not by disputed facts alone, but by the framing, methodology and influence of expert evidence at a much earlier stage than many firms and advisers expect. This…

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Operational Resilience Is Now Being Read Backwards

  This paper shows how regulatory supervisors assess harm, evidence and governance after a disruption.   Operational resilience has moved into a new supervisory phase where the focus is no longer on whether firms have completed mapping, impact tolerances and scenario testing but on whether those materials are fit for purpose when read after an…

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Regulatory Updates December 2025

Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: FCA simplifies complaints reporting process FCA consults on reducing late…

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Regulatory Year in Review 2025

Over the past year, UK financial services regulation has increasingly focused on promoting economic growth, reducing unnecessary regulatory burden and upholding strong standards in financial crime, market integrity and governance. Objectivus is well placed to provide context and support to firms seeking to understand how these developments affect their regulatory obligations.   In this review…

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Regulatory Updates November 2025

  Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: FCA publishes consultation on UK transaction reporting regime FCA…

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FCA highlights gaps in financial crime oversight for corporate finance firms

  In October, the Financial Conduct Authority (FCA) published a press release alerting to significant shortfalls among corporate finance firms in meeting their obligations under the Money Laundering Regulations 2017. These findings emphasise the growing regulatory emphasis on financial crime controls in the advisory and corporate finance sector, signalling that firms must act now to…

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UK’s Short-Selling Regime – Update November 2025

  Major shifts under CP25/29 and where this places the UK in global context On 28 October 2025 the Financial Conduct Authority (FCA) launched consultation paper CP 25/29, setting out its proposed rulebook for short-selling in the UK. The consultation is open until 16 December 2025. Changes since the 2018 (Brexit Withdrawal) regime Under the previous…

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Regulatory Updates October 2025

  Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: Denmark loses £1.4 billion tax-fraud claim in UK High…

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Regulatory Updates September 2025

  Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus, we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: FCA proposes easing of Consumer Duty for wholesale firms…

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Denmark Loses £1.4bn Tax Fraud Claim in UK High Court

  On Thursday 2nd October Mr Justice Andrew Baker handed down a landmark decision in the case SKAT v Solo Capital Partners LLP and others at the High Court, King’s Bench Division.  After 6 years of litigation, all claims against Sanjay Shah, Mrs Shah and the other defendants were dismissed, leaving SKAT liable for a…

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FCA Consults on Applying Existing Rules to Crypto asset Firms

  On 17 September 2025, the Financial Conduct Authority (FCA) published Consultation Paper CP25/25, seeking feedback on how existing Handbook rules should apply to crypto asset firms under the nearing crypto asset regime. The consultation proposes extending core requirements on governance, systems and controls, consumer protection and operational resilience to crypto asset firms, mirroring the…

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FCA Emphasises Risk-Based Approach in Fight Against Financial Crime

  On the 11th September 2025, the Financial Conduct Authority (FCA) reinforced its commitment to tackling financial crime, setting out a risk-based approach to enforcement and supervision. Speaking at a London conference, Steve Smart, Joint Head of Enforcement and Market Oversight at the FCA, highlighted that combating fraud is not a barrier to economic growth…

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Regulatory Updates August 2025

Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus, we are well positioned to provide context and support for firms working to understand such changes.   In this issue we cover: FCA warns of surge in impersonation scams FCA approves…

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FCA Reduces Reporting Burden for 36,000 Firms Under SMCR

  On the 28th August 2025, the Financial Conduct Authority (FCA) announced a reduction in data reporting requirements, easing the administrative burden on thousands of regulated firms. This change removes the need to submit nil returns under the Senior Managers and Certification Regime (SMCR), is effective immediately and impacts around 36,000 organisations, representing 95% of…

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FCA Review on Off-Channel Communications: Key Findings

On 7 August 2025 the Financial Conduct Authority (FCA) published the findings of its multi-firm review into off-channel communications. These are business-related discussions that take place outside approved monitored systems. The review highlights ongoing risks and control weaknesses across wholesale banking and other FCA-regulated firms. The FCA confirms that while all sampled firms have made notable…

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Regulatory Updates July 2025

  Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus, we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: FCA sets faster targets for authorisations Rachel Reeves’ Mansion…

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HMT’s 4th National Risk Assessment on Money Laundering and Terrorist Financing

  The UK government and HM Treasury have recently published the 2025 National Risk Assessment (NRA) on Money Laundering and Terrorist Financing, along with a formal response to the 2024 consultation on improving the Money Laundering Regulations (MLRs). These developments mark an evolution of the UK’s financial crime framework.   2025 National Risk Assessment (NRA)…

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Regulatory Updates June 2025

  Our regulatory newsletter aims to provide insight into the previous month’s changes and updates which may have an impact on your firm. At Objectivus, we are well positioned to provide context and support for firms working to understand such changes. In this issue we cover: Proposed cost cutting for fund managers Removal of further…

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Rachel Reeves Outlines Economic Reform Agenda in Mansion House Speech

  On 15 July 2025, Chancellor Rachel Reeves delivered her second Mansion House speech, outlining the new government’s economic priorities and plans for regulatory reform. The speech focused on enabling investment, supporting homeownership, and reviewing key financial regulations. Central to the speech was the Leeds Reforms, a package of financial regulatory proposals focused on investment…

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