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Recent Articles

  •  
    17/04/2025
    United Kingdom

    FCA’s Second Consultation on Consumer Composite Investments

    IntroductionThe Financial Conduct Authority (“FCA”) launched a second consultation on the Consumer Composite Investments (“CCI”) regime on 16 April 2025 (the “Second Consultation”) with further proposals to support the CCI regime including changes to cost information and rules for the transitional period.This follows on from an earlier consultation from December 2024. The proposed CCI regime aims to replace the Packaged Retail and Insurance-based Investment Products (“PRIIPs”) regime and certain Undertakings for Collective Investment...
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    15/04/2025
    Europe

    ESMA’s Final Reports on Order Execution Policies, New SI ITS and RTS Amendments

    On 10 April 2025, the European Securities and Markets Authority (“ESMA”) published two final reports on firm’s order execution policies under MiFID II and rules on systematic internalisers, volume cap and circuit breakers.The initial consultations were launched in July 2024 (see Consultation Paper on Order Execution Policies and Third Consultation Package of MiFIR Review) following the MiFID and MiFIR reviews.Key HighlightsKey highlights of the final reports are set out below:Criteria for Establishing and Assessing the Effectiveness of Investment...
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    14/04/2025
    England and Wales

    Securities litigation: Court refuses to strike out "common reliance" and "dishonest delay" claims

    In a significant development for securities litigation, the High Court has refused to strike out claims based on "common reliance" (or "price/market reliance") and "dishonest delay" in Various Claimants v Standard Chartered plc [2025] EWHC 698 (Ch). This decision marks a notable departure from last year's ruling in another securities litigation decision (you can find our analysis of that decision here). Background and applicationThe case involves claims brought by 217 claimants (representing approximately 1,391 funds) claiming around £1.5 billion from Standard Chartered PLC. The claimants...
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    14/04/2025
    Luxembourg

    New provisions for payment and e-money institutions to protect user funds and access designated payment systems

    On 7 April 2025, the law of 4 April 2025 on instant payments (the “Law”) was published in the Official Journal of Luxembourg to (i) introduce into Luxembourg law some provisions of Regulation (EU) 2024/886, which amends i.a. Regulation (EU) 260/2012 (SEPA), Directive (UE) 2015/2366 (PSD 2) and Directive 98/26/CE (SFD) and (ii) amend the law of 10 November 2009 on payment services.To protect the funds received from users or other payment service providers for the execution of payments, payment institutions (“PIs”) must deposit them in a separate account with a credit institution....
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  •  
    11/04/2025
    Europe

    Agentic AI and the EU AI Act

    Agentic AI systems are designed to act autonomously, sense their environment, make decisions, and take actions without constant human oversight. However, their autonomy and potential to operate with minimal human intervention raise unique challenges in terms of regulation, particularly under the EU AI Act.What Is Agentic AI?The functioning of agentic AI is rooted in Large Language Models (“LLMs”) and other advanced machine learning algorithms. These models are trained on vast datasets to understand human language and respond intelligently to various inputs. What sets agentic AI...
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    11/04/2025
    Europe

    The Cyber Resilience Act: Consultation on the Technical Description Opens

    Agentic AI systems are designed to act autonomously, sense their environment, make decisions, and take actions without constant human oversight. However, their autonomy and potential to operate with minimal human intervention raise unique challenges in terms of regulation, particularly under the EU AI Act.What Is Agentic [CMS1] AI?The functioning of agentic AI is rooted in Large Language Models (“LLMs”) and other advanced machine learning algorithms. These models are trained on vast datasets to understand human language and respond intelligently to various inputs. What sets agentic...
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