Summer, Summary 2021 - Part 1 Topics of Interest

These are just some of things we raised in our newsletter update earlier this summer and thought that some of our wider contacts might be interested in what we are/were looking at.


SFC Items of Interest

  • Conflicts of Interest, Expense and Fee Disclosures

  • Just to highlight as an area of continuing regulatory focus for Asset Managers

  • Cybersecurity (SolarWinds, Fortinet, Microsoft Exchange)

  • Check in with your security vendor if you have not done your annual review

  • Business Continuity - Vaccination Stance - What is yours? Have you wrote it down?

  • Data Protection - Data Leak management - Continued Focus

  • Electronic Data Service Providers - Are we there yet? What is next?

  • Bank Account Controls – Solutions if necessary being adapted

  • Market Misconduct – Of ongoing interest

  • Company Disclosures - Market Discipline

  • Ramp and Dump

  • Boiler Rooms

  • LIBOR -Deadlines are visible - What is your exposure?

  • Liquidity, Leverage and Counterparty Risk

  • Market Correction/Market Liquidity Impact

  • Just because you have survived does not mean your process is robust

  • OTC Derivatives - Continuing Global Developments

  • ESG Parts 1, 2, and 3

  • 1 - Firm Obligations - Environmental and Social Policy

  • 2 - Fund Obligations - All Funds

  • 3 - Funds with ESG Objective’s Obligations (Authorised, Registered, Listed)

  • OFC – If you are interested in launching HK domiciled funds there is support

  • FMCC Review – Probably time to review adequacy of your risk process

  • AML Oversight Process - Risk Assessment Process -Increasing depth

  • Continuing Professional Training– 2020/21 (2 Year Deadline approaches)/2022 - Double Time -See our update

SEC/US Items of Interest

  • Conflicts of Interest, Expense and Fee Disclosures - Same as SFC

  • Cybersecurity (SolarWinds,Fortinet, Microsoft Exchange)

  • Check in with your security vendor if you have not done your annual review

  • Market Misconduct

  • Company Disclosures

  • Pump and Dump

  • Medical MNPI

  • ESG

  • LIBOR

  • Advertising Rule Changes

  • Performance

  • Sanctions Management

  • Change of Guard at SEC/Change of Stance

  • Check in with US Consultant

EU and UK Relevant Matters

  • Cross Border Financial Services – Check out developing AIMA resources

  • Reverse Solicitation – ESMA

  • MiFID (Commission Unbundling)

China Relevant Matters

  • Sanctions Politics (US/China/EU and Vice Versa) – 2nd August Implementation

  • Cybersecurity/Data Privacy vs Rest of World

You will note that we did not mention SPACs or Crypto Assets. We are not ignoring them, we just find that not everyone is interested in speaking about them. We also spent a good bit of time looking at the quarantine exemptions but ultimately concluded that there is a high bar in terms of obtaining an exemption and a high risk of breaching the conditions.


Please speak to your consultant about any of the issues raised.






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Summer, Summary 2021 -Part 2 Deeper Dive

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