This Working Group was formed to feed into discussions and policy matters relating to climate-related risk.

The WG is Chaired by Bobby Charalambous, Climate Risk Director, Group Regulatory Compliance and Policy, ANZ, and meets quarterly.

AFB has been interacting with policymakers and stakeholders including the PRA and the Climate Financial Risk Forum on this topic. Members of this group informed the January 2024 AFB response (here) to the FCA’s guidance consultation 23/3 on its anti-greenwashing rule, which will come into force on 31 May 2024.

An AFB summary of the CFRF’s 3^rd year guides can be read here.

This Working Group was formed to feed into discussions and policy matters relating to Money Laundering Reporting in the UK, as well as the implementation of sanctions against Russia. AFB is interacting with policy makers and stakeholders, including the FCA, HMT and OFSI, on this topic.

The WG is Chaired by Jose Arevalo, Director – Financial Crime & Markets Regulatory Risk & Control, Commerzbank, and meets quarterly.

The working group has submitted responses to a number of consultations, for example the HM Treasury consultation on improving the effectiveness of the MLRs (here), which was submitted on 17 June 2024. Currently, the group is considering a response to FCA Guidance Consultation on proposed amendments to the Guidance on the treatment of Politically Exposed Persons (GC24/4).

The purpose of the PRN is to understand and represent the policy/regulatory concerns of AFB members and advocate on their behalf with regulators and policymakers.

During meetings, AFB members have the opportunity to discuss prevalent policy and regulatory topics. Topics discussed include, Basel 3.1, the Foreign Influence and Registration Scheme, the FCA’s approach to enforcement etc.

The Network also undertakes the following activities:

• Coordinates AFB members’ responses to policy and other consultations and, where appropriate, convenes directly with (mainly UK) regulators/policymakers in roundtable and other formats on specific areas of interest
• Provides regular updates (by email) on important policy/regulatory developments
• Scans the horizon for future issues and commissions research where appropriate
• Provides networking opportunities to members
• Provides input into the AFB’s programme of practice and events in relation to technical/policy matters, so that the need for educational and networking opportunities for regulatory personnel can be serviced.

The Network meets in-person every 6-8 weeks for a 90-minute session.

Following the collapse of Silicon Valley Bank UK, the PRA informed AFB that it is considering a review of its approach to branch and subsidiary supervision (including Supervisory Statement 5/21). AFB therefore created the Branch and Subsidiary Supervision Working Group in preparation for the review. This group informed AFB’s policy paper on the benefits of branches to the UK economy.

It will also inform AFB’s response to PRA CP11/24 – International firms: Updates to SS5/21 and branch reporting.

Ahead of the 31 October 2024 deadline for Group 2 PSPs to implement Confirmation of Payee (CoP), AFB created this working group. Members of the group have the opportunity to discuss the CoP requirements with peers. They also contributed to an AFB letter to the PSR, which sought an extension to the CoP implementation date as well as further guidance on the exemptions available (here).

This working group was formed following the FCA/PRA Discussion Paper 3/22 – ‘Operational resilience: Critical third parties to the UK financial sector’, as well as HMT’s June Policy Statement on critical third parties.

On July 26 2022, the working group met with the FCA, PRA and HM Treasury at a roundtable to discuss these items. Members can read a summary of the meeting here.

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.

This Working Group discusses the FCA and PRA proposals regarding D&I in financial services (FCA CP23/20 and PRA CP18/23). Members contributed to AFB’s responses responses to the consultation papers here and here.

This group also discusses the regulators’ proposals regarding non-financial misconduct.

AFB continues to monitor the regulators’ approach to D&I and non-financial misconduct – and will distribute relevant updates/information to this group.

This Working Group fed into AFB’s feedback to the European Commission on CRD VI in February 2022 (here). The final CRD VI has now been published in the Official Journal on 19 June 2024 (here). Members of the working group will have the opportunity to discuss the implementation of CRD VI with peers and increase their understanding of the requirements.

In December 2022 the AFB sent a position paper ‘The Replacement of Retained EU Law and Changes to the UK Regulatory Framework’, prepared with Allen & Overy, to HM Treasury.

On 11 July 2023 HMT published ‘Building a Smarter Financial Services Regulatory Framework for the UK: HM Treasury’s Plan for Delivery’, which outlines the approach to the repeal/replacement of EU retained law, including the balance of responsibilities between HMT and the regulators, and the Government’s legislative approach.

AFB will continue to advocate on this topic with relevant stakeholders.

The AFB FCA Enforcement Working Group was created to inform AFB’s response to FCA CP24/2 ‘Our Enforcement Guide and publicising enforcement investigations – a new approach’ (here). AFB submitted its response to the consultation paper on 29 April (here). On 26 April 2024 AFB signed a joint trade association letter, sent to the Chancellor Jeremy Hunt MP, on the FCA’s proposals (here).

AFB will continue to monitor the FCA’s approach to its enforcement and engage the working group when the final policy is published.

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 (latest edition here). 

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.

On 25 May 2022, the PRA held a roundtable for working group members to discuss the implementation of the operational resilience and outsourcing requirements (summary here).

This Working Group was formed to consider the regulators’ (FCA/PRA DP1/23)and  HM Treasury’s (CfE) review of the SM&CR. AFB responded to both the HMT CfE (here) and FCA/PRA DP1/23 (here).

Individuals from this group received the opportunity to attend a May 2023, roundtable with HMT, the PRA and the FCA, to provide feedback on the SM&CR and suggestions for amendment.

Due to the overlap with the Conduct Rules, this group also considered the regulators’ proposals regarding non-financial misconduct.

This group will be engaged when the SM&CR FCA/PRA/HMT consultation papers are published later this year.

This Working Group was formed to consider the regulators’ (FCA/PRA DP1/23)and  HM Treasury’s (CfE) review of the SM&CR. AFB responded to both the HMT CfE (here) and FCA/PRA DP1/23 (here).

Individuals from this group received the opportunity to attend a May 2023, roundtable with HMT, the PRA and the FCA, to provide feedback on the SM&CR and suggestions for amendment.

Due to the overlap with the Conduct Rules, this group also considered the regulators’ proposals regarding non-financial misconduct.

This group will be engaged when the SM&CR FCA/PRA/HMT consultation papers are published later this year.

This Working Group provides feedback on the UK Immigration/Visa system. Members of the group contributed to a survey on the operational impact of the points-based immigration system. In May 2022, the AFB published its position paper ‘The Operational Impact of the UK’s Immigration System’ (here) based on this survey and follow-up interviews with members. In June 2022, AFB sent a two-page letter to the Home Office and HM Treasury regarding meaningful amendments to the UK’s immigration system (here).

Following AFB’s positive engagement, the Government amended the Standard Visitor route to remove the prohibition on working directly with clients for intra-corporate activities and expanded the Youth Mobility Scheme. The AFB Immigration/Visa Working Group held a virtual meeting on 12 January 2024 to discuss these updates, and on 26 January held a meeting with the Department for Business and Trade to provide feedback on the recent amendments.

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

The FCA published its final guidance on 27 July 2022, with an implementation deadline of 31 July 2023. 

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 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.

On 12 August 2022, FCA has now announced that all firms in the Temporary Permissions Regime that it is expecting to apply for full authorisation in the UK should now have received a formal direction confirming their ‘landing slot’ (here).

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 on the first layer of the new regime, CP5/22 – ‘The Strong and Simple Framework: A Definition of a Simpler-regime Firm’, published on 29 April 2022.

AFB responded to the CP, as well as to Appendix 10 of PRA CP16/22 (which updated the proposed criteria for Simpler-regime Firms). 

AFB continues to engage with the PRA and members on the topic.

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).

An AFB working group responded to HM Treasury’s Future Regulatory Framework Review and AFB also submitted a response to the further consultation on the FRF Review in February 2022.

AFB engaged HMT and the regulators throughout the progress of the Financial Services and Markets Bill, which became the FSM Act 2023 on 29 June 2023.