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The AFB is acting as a conduit for feedback and dialogue between member banks and regulators in the policy areas listed below. In some of these areas a member working group (WG) has been formed.

If you are interested in participating in any of our working groups, please contact the Policy and Regulatory Affairs Team.

You can read the latest updates on our Policy and Regulatory Affairs Projects in our monthly CEO roundup and find all of our consultation responses in the resource library.

The terms of reference for our policy working groups can be found here.

Current Policy Initiatives

The AFB has been interacting with policymakers and stakeholders including the PRA and Climate Financial Risk Forum on this topic.

An AFB working group has been formed to feed into discussions and policy matters relating to climate-related risk.

The AFB will continue as an observer member of the Climate Financial Risk Forum for its third year in 2022.

Following the publication of the European Commissions’ proposals on Third Country Branches in October 2021, the AFB met with interested members and submitted a paper to the European Commission in February 2022.

In H1 2021, 25 AFB members were interviewed about their cyber risk governance practices for an AFB report, produced with Marsh.

The AFB continues to feed into discussions and matters relating to cyber risk governance with the FCA, PRA and Bank of England.

In March 2021 the AFB formed a working group to discuss the Bank of England’s transformation plan. The AFB continues to engage with the BoE and members on this topic.

The Diversity and Inclusion Working Group was formed following the joint PRA/FCA Discussion Paper 21/2 on Diversity and Inclusion in the financial sector. You can read the AFB response, based on a member survey, here.

The WG will continue throughout 2022, with the Consultation Paper on Diversity and Inclusion expected in H2.

In 2020 the AFB became a partner member of the Financial Services Skills Commission (FSSC), which aims to ensure that the financial services sector has the talent and skills it needs for the future. This working group also receives quarterly updates on the work of FSSC.

An AFB working group responded to HM Treasury’s Future Regulatory Framework Review, which considers how the UK regulatory framework for financial services needs to adapt to be fit for the future.

The AFB also submitted a response to the further consultation on the FRF Review in February 2022.

A new Financial Services and Markets Bill was announced in the Queen’s Speech on 10 May 2022 (briefing note here).

An AFB working group has been formed to feed into discussions and policy matters relating to Money Laundering Reporting in the UK, as well as (since February 2022) the implementation of sanctions against Russia. The AFB is interacting with policy makers and stakeholders, including the FCA, HMT and OFSI, on this topic.

The working group has submitted responses to HMT Consultations on ‘Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017’ (here) and on the review of the UK’s AML/CTF regulatory and supervisory regime (here), as well as to the Home Office Draft Economic Crime Legislative Proposals (here).

Following FCA Consultation Paper 21/36 on a New Consumer Duty, the AFB consulted with members and submitted a response in February 2022.

The AFB will continue to engage with the FCA on the topic, with the final proposals expected in July 2022.

The working group was initially formed in response to PRA and FCA consultation papers on operational resilience and outsourcing. The WG continues to feed into discussions and policy matters on these topics.

Following interest from members, the AFB undertook a survey on the operational impact of the points-based immigration system. The AFB is currently analysing the results and intends to produce a report on the topic.

Past Policy Initiatives

Below is a selection of policy initiatives and working groups which were previously active.


In advance of Phase 5 of the European Market Infrastructure Regulation (EMIR) implementation of margin requirements, the AFB interacted with both the PRA and FCA to assist firms with the implementation.

An AFB working group responded to FCA CP20/20, which set out the FCA’s proposed approach to international firms providing or seeking to provide financial services that require authorisation. The FCA published their final rules in February 2021 and the AFB continued to liaise with members and the FCA on this topic.

The AFB supported the City of London Law Society in their submission on the FCA’s Consultation Paper 21/25 (here).

The AFB LIBOR Transition Working Group was formed to discuss and feed into policy matters relating to LIBOR Transition.

An AFB working group was formed to respond to PRA CP2/21, which discussed the PRA’s approach to the future supervision of international banks. Supervisory Statement 5/21 took effect from 26 July 2021.

An AFB working group, formed in late 2019, led the work to update Part II/Sector 15 (Trade Finance) of the JMLSG guidance, which was approved in October 2021.

The AFB formed a working group to respond to the Discussion Paper (here), with a Consultation Paper expected in H1 2022.

The AFB conducted a survey on the transition to the office post-COVID 19, as well as seeking clarity for members on the FCA’s Remote/hybrid working guidance (here).

Contact the Policy & Regulatory Affairs Team

To find out more about the work of the Policy and Regulatory Affairs team,  or to discuss how you can provide input, please contact us.

Contact Policy & Regulatory Affairs Team