Welcome to Allen & Overy’s Investigations Insight blog, sharing with you our views and insights into the latest trends, risks and developments in financial services investigations

FCA and PRA confirm changes to their enforcement decision-making processes

Sarah Hitchins

Following a process that has lasted for more than two years, yesterday the UK Financial Conduct Authority (FCA) and the UK Prudential Regulation Authority (PRA) confirmed changes to their enforcement decision-making processes. These changes take the form of guidance, not formal rules. We set out below the key changes announced by the regulators, some of Read More

The U.S. SEC and Hong Kong SFC enter into a new cooperation agreement

Kurt Wolfe

This blog post was co-authored by Matt Bower, a litigation and regulatory investigations partner based in Hong Kong.  The U.S. Securities and Exchange Commission (SEC) and the Hong Kong Securities and Futures Commission (SFC) recently entered into a Memorandum of Understanding (MOU) regarding the supervision and oversight of regulated entities that operate in the United States and Read More

FCA: ‘We have not gone soft’

Sarah Hitchins

Bumper fines have become a mainstay of UK Financial Conduct Authority (FCA) enforcement action. However, last year we saw a significant drop in the financial penalties imposed by the FCA. It got people talking. Has the FCA gone soft? In a speech delivered earlier this month, Mark Steward gave a clear ‘no’ in response to Read More

SEC announces another large whistleblower award – with a twist

Kurt Wolfe

In 2016, the SEC announced 7 of its ‘Top 10’ whistleblower awards. And the Office of the Whistleblower has continued apace in 2017, recently announcing its sixth-largest whistleblower award – more than $5.5 million to a whistleblower ‘who provided critical information that helped the SEC uncover an ongoing scheme’. According to the Order Determining Whistleblower Read More

The Hong Kong “Manager In Charge” regime – a new approach?

Matt Bower

This blog post was co-authored by Charlotte Robins, a financial services and regulatory partner based in Hong Kong.  On 16 December 2016, the Securities and Futures Commission (SFC) published a ‘Circular to Licensed Corporations Regarding Measures for Augmenting the Accountability of Senior Management’ (Circular) together with associated Frequently Asked Questions. The SFC did so to Read More