Publication
Global Asset Management Review: Issue 4
Welcome to the third issue of Global Asset Management Review.
The new Investment Firm Prudential Regime introduces an internal capital and risk assessment (ICARA) process for both small and non-interconnected investment firms (SNI firms) and non-SNI firms. The Financial Conduct Authority (FCA) has highlighted that the introduction of this new regime is an opportunity to re-establish the expectations for firms' internal governance and risk management that reflects and builds upon the framework previously established in FCA guidance.
The intention is that the ICARA process will be the centrepiece of MIFID investment firms' risk management processes. The process will incorporate business model assessment, forecasting and stress testing, recovery planning and wind-down planning. The new regime also introduces the Overall Financial Adequacy Rule (OFAR), which establishes the standard the FCA will apply to determine if an FCA investment firm has adequate financial resources.
As part of the ICARA process, firms will also be expected to identify whether they comply with the OFAR.
Publication
Welcome to the third issue of Global Asset Management Review.
Publication
On 13 November 2025, the European Parliament adopted (subject to certain amendments) the substantive Omnibus Directive which was proposed by the European Commission on 26 February 2025 (see our previous briefing here). On 16 December 2025, the European Parliament adopted further proposed amendments.
Publication
In today’s fast-evolving legal landscape, litigation is becoming more complex, more international, and more strategic than ever before. Understanding the challenges, trends and lessons learned is critical for businesses and their litigation strategy and risk management.
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