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Welcome to The MPAC Group, the UK's leading corporate compliance and regulatory advisory firm.


We have achieved this respect by working closely with our clients to meet their corporate regulatory, financial or legal obligations.


We believe client satisfaction is a function of people, solutions and delivery. At MPAC, our team of experts is comprised of experienced compliance officers, money laundering reporting officers (MLROs), senior regulators, qualified actuaries, lawyers and accountants from the financial sector delivering a wide array of services targeted to help our clients navigate through various corporate landscapes. Please take a look at how MPAC can help your business grow.


Attend our "Roles of Compliance Officer,
and Money Laundering Reporting Officer Workshop".

Attend our "Client Money and Assets Workshop"





The FCA has Introduced Some Temporary Measures for Firms Submitting Regulatory Returns.

Considering the pressure Covid-19 has placed on many firms, the FCA has attempted to alleviate regulatory pressure by extending submission deadlines for regulatory returns either by one or two months (see list below) for reporting up to 30 June 2020. This means that, for example, if you have a return due on 22 May 2020, but a two month extension applies, the submission will need to be completed by 22 July 2020. However, if the extended deadline falls on a weekend, the submission should be made by the next working day.

For small or medium-size businesses (paying less than £10,000 in fees and levies in 2020/2021) the administrative fee for late returns has been waived until 30 June 2020 (this also applies to any returns not listed below).

You are still expected to submit your return as soon as possible and should you miss a deadline (in the period up to 30 June), the FCA will send a reminder letter to you.

Please note: returns not mentioned below do not have an extension and firms are expected to submit their data in the usual timeframe.

SUP 16 handbook returns:
1-month extension applies for the following returns:

  • COR001A (Own funds)
  • COR001B (COREP Leverage Ratio)
  • COR002 (COREP LE)
  • COR003 (COREP NSFR)
  • COR005 (Asset Encumbrance)
  • FRP001 (FINREP)
  • FSA004 (Breakdown of Credit Risk Data)
  • FSA005 (Market Risk)
  • FSA007 (Operational Risk)
  • FSA008 (Large Exposures)
  • FSA014 (Forecast Data from Firms)
  • FSA017 (Interest rate gap report)
  • FSA018 (UK integrated group - Large Exposures (UK integrated group))
  • FSA019 (Pillar 2 Information)
  • FSA055 (Systems and Controls Questionnaire)
  • REP005 (High Earners Report)
  • RMA-D2 (Financial Resources)

2-month extension applies for the following return:

  • FIN-A (annual report and accounts)

You are not required to submit the following return for 2020:

  • Employers' Liability Register compliance return

Other Handbook returns:
2-month extension applies for the following returns:

  • Annual financial reports (as required under Disclosure Guidance and Transparency Rules)
  • Credit union complaints return (CREDS 9 Annex 1R)
  • Complaints return (DISP Annex 1R)
  • Claims management companies complaints return (DISP 1 Annex 1AB)

Should you require more detailed guidance or assistance with your firm's requirements involving regulatory returns don't hesitate to get in contact with us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk

FCA Bands Marketing of Mini-Bonds to Retail Customers

The FCA announced on 26th November 2019 that they will be implementing a ban on the promotion of mini-bonds to retail customers. The Temporary Intervention, implemented without consultation, is expected to tighten firm's obligations with regards to their treatment of retail clients, and provide greater protections for them in the wake of fraud within the mini bond industry.

The following measures will last for 12 months, coming into force on 1st January 2020:

  • Any promotions targeting retail investors will be restricted to sophisticated or high net worth investors. Firms will need to carry out a preliminary assessment of the suitability of the mini bond investment to ensure that they do fall into the hands of retail clients
  • Marketing materials must also include specific and prominent disclosures including: a standardised risk warning, costs and charges associated with the minibond, any third-party payments made by the issuer that is deducted from capital raised and the date of approval of the marketing material

If you have any questions about your firm's compliance with these measures, please do not hesitate to contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk

Solo Regulated Firms Have Until 9th December to Prepare for SMCR

The Senior Managers and Certification Regime ("SM&CR") will apply to all solo-regulated firms from the 9th December. If you're currently regulated under the Financial Services and Markets Act 2000, under the Approved Persons Regime, then this includes your firm.

The main focus of the SM&CR is to encourage staff of financial firms to take personal responsibility for their actions. All senior managers will need to complete a Statement of Responsibilities that clearly sets out what specific tasks they are responsible for. Then when there is a serious failing as a result of poor conduct, the individuals responsible can be held to account.

All firms fall into one of three categories, Limited Scope, Core or Enhanced, which determine how the SM&CR will apply to them. It is important you correctly categorise your firm as the required responsibilities and roles differ greatly.

The FCA has published a number of guides, advice pages and checklists in order to assist firms in their preparations: -

Further information, including podcasts and videos can be found on the FCA website, via the homepage link above.


MPAC can assist you in understanding how SM&CR will impact your firm and in making preparations for a seamless transition to the new regime. To avoid disruption, it is crucial that you are ready prior to the 9th December deadline, with any necessary submissions or approvals already completed with the FCA. Please do not hesitate to contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk

Crypto Ban

The FCA is launching a consultation (CP 19/22) on whether to ban the sale of all crypto derivatives and exchange-traded notes to retail consumers, which brings them into line with ESMA's growing crackdown on retail CFDs. According to the FCA's research, it will apparently save consumers between £75m-£234.3million of lost investments a year. However, even the FCA acknowledges that the ban will push consumers to use unregulated firms which may well be in overseas jurisdictions where their investments will be utterly unprotected; so the supposed savings are likely an overestimate as any such monies remitted to the bogus brokers, funds etc will be lost but, in these cases, the FCA won't be seen to be responsible. . The crypto industry has criticised the FCA's their unnecessarily heavy- handed approach and their early dismissal of any alternative methods of regulating the new asset classes. MPAC Group will be responding to the consultation on our own behalf and on behalf of certain clients


Should you need any additional information, advice or assistance, please do not hesitate to contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk

SMCR - is your firm ready?

The Senior Managers and Certification Regime ("SMCR") will replace the Approved Persons Regime on 9th December 2019 for all firms regulated solely by the FCA under FSMA. It has already been rolled out to banking firms and insurers. It is all part of the FCA's drive to increase the accountability of the individuals working in these firms following the various conduct scandals that rocked the UK banking sector after the 2008 financial crisis (such as LIBOR manipulation and PPI mis-selling). SMCR is underpinned by three key pillars that firms must abide by:

  • the Senior Managers Regime;
  • the Certification Regime; and
  • the Conduct Rules.

The FCA has, however, taken a proportionate approach to the extension of the SMCR rules by creating three classifications of firms:

  • Enhanced firms - where the requirements are similar to the banking SMCR rules;
  • Core firms - which applies to most firms that are neither "Enhanced" or "Limited"; and
  • Limited Scope firms - where light touch SMCR requirements are applied.

The majority of firms will be Core firms. For these firms, individuals holding Significant Influence Functions under the Approved Persons Regime will automatically be transferred to the Senior Managers Regime. They will become Senior Managers and will hold Senior Management Functions ("SMFs"). Senior Managers will require a "Statement of Responsibility" setting out their role and responsibilities.

Current CF30 function holders and certain other individuals, however, will not become Senior Managers. They will instead fall under the Certification Regime and will need to be assessed by firms themselves rather than being approved by the FCA. Firms will need to assess they are fit and proper and issue them with a certificate annually.

The Conduct Rules will replace the Principles for Approved Persons. All employees except ancillary staff, such as receptionists, switchboard operators, etc. will be bound by Individual Conduct Rules. Senior Managers will also be bound by an additional tier of Conduct Rules.>/p>

MPAC has developed an SMCR toolkit to provide firms with training, policies, templates and guidance to enable them to implement SMCR effectively. If you would like further guidance on SMCR or a discussion about how we can help, please don't hesitate to contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk.

What Next for Crypto?

On 9th May 2019, the FCA published the Minutes of its Meeting of 28th March at which it considered the UK Government's proposed approach to crypto asset regulation and supervision.

It was noted that HM Treasury is consulting on the introduction of domestic legislation to implement an AML regime for certain crypto asset activities by January 2020. The Treasury is also proposing to include further provisions that would require the UK to meet the relevant FATF standards and has requested the FCA to take on supervision of the new regime. The Board Minutes reflected that the proposed new regime would introduce AML supervision for businesses that enable (1) crypto asset exchanges and (2) custodian wallet providers which store crypto assets for underlying clients. Depending upon the consultation's final outcome, it may also include other types of business models which facilitate exchange of one crypto asset for another, crypto asset ATMs and also possibly businesses enabling peer-to-peer exchange of crypto assets or the provision of wallets without arranging actual custody of such wallet. In essence, this is the Treasury proposing to "gold plate" 5 MLD and extend its reach which has been seen as controversial in certain parts of the market.The FCA Board also addressed the resourcing implications and the corresponding risks/issues associated with assuming these new supervisory responsibilities. As far as risks not covered by the regime itself are concerned e.g. technology and resilience requirements, financial promotions and consumer protections, the Board deliberated on whether communication alone was sufficient for managing such risks and whether it would be necessary to implement additional rules; further discussion on this topic was deemed to be necessary.

The Board agreed in principle that the FCA is prepared to act as AML supervisor for specified UK based crypto asset businesses provided this continues to be the Treasury's preferred approach following close of the consultation on 10th June 2019. This will be dependent on a comprehensive blueprint of the regime and development of the supervisory model and associated funding. The FCA also undertook to ongoing interaction with the sector pending the consultation outcome to shape design, and allow timely implementation, of the new regime. All EU Member States are required to implement 5MLD by 10th January 2020.


Any queries about crypto, contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk

Securities Token Offering (STO)

It's what we have been talking and writing about for a long time now… a mainstream Security Token Offering (STO). The week saw the issue of a €100m debt issue by a subsidiary of Soc Gen Paris; fully subscribed by the bank itself. Actually it was a covered bond called an OFH (obligations de financement de l'habitat). The bank says it was a live, experimental issue to test the backend systems amongst other things. Interesting as to whether this will cause other major institutions to speed up their offerings, live and/or experimental?

The opportunities for the issuer to reduce operations costs are potentially significant and can also increase liquidity in such issues - so we watch the first OFH with interest. If you want to talk about how we can help in you launching your own STO or need help in being regulated in any way to participate in the new world order of distributed ledgers and crypto, please do contact us. We are working in many areas of this sector and be delighted to help.


Should you need any additional information, advice or assistance, please do not hesitate to contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk

GDPR- What's in Store in the Regulatory Enforcement Backdrop?

The ICO published its Regulatory Action policy late last year, the high level guidance on how it will apply GDPR enforcement powers going forward. The ICO has said that it will update the Policy to reflect any amendments to legislation, including any implementation of an updated e-Privacy Regulation, which was anticipated to occur towards the end of this year/start of 2020; but this is dependent upon the final settlement between the EU and the UK post-Brexit being confirmed.

There have been no data breach penalties imposed under the new GDPR regime by the ICO as yet. However, recent enforcement actions and penalties in cases initiated under the 1998 DPA have resulted in maximum fines of £500,000 being imposed on Facebook and Equifax which indicate that the Commissioner will impose heavy fines under the new regime in the near future.

To put some context on this, in the case of Lloyd v Google LLC regarding a Safari workaround, the class of affected users was estimated at different times as comprising in the region of 4-5 million people; with a suggested tariff of £750 per claimant, Google's potential liability would be between £2-3 billion. In another action, CNIL (French Data Regulator) imposed €50m fine on Google as a result of users not giving informed consent; this is under appeal by Google. So these give some indication of the potentially significant fines and claims to come with the added dimension of specialist litigation funding coming into play in the large class actions.


Should you need any additional information, advice or assistance, please do not hesitate to contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk

ESMA Q&A - MiFID II - Reverse Solicitation

ESMA has recently updated its Q&A on MiFID II and MiFIR investor protection and intermediaries. One of the key questions addressed is whether under Article 42 of MiFID II the reverse solicitation rule allows a firm, within the context of a one-off service to a client, which has sold/has had the opportunity to sell a product or service under this rule, to offer again products/services from the same category? The short answer is No. The reverse solicitation exemption is based on the proviso that the product/service is marketed at the client's own exclusive initiative and can only be applied to the specific/product service provided.

When a one-off investment service is provided to a client, the third country firm must not sell to that client (without establishing a branch as required under local law) a product/service from the same category, unless it is requested to do so by the client at its own exclusive initiative and only at the time that the client asks for an investment product/service.

In the course of a transaction, the firm may offer the client another product/service of the same category as the one requested by the client but not at a later stage- unless the client specifically requests it on its own initiative. So, for example, if the client contacts the third county firm to buy an equity, the firm could market other equities from the same stock exchange sector to the client. However, the firm would not be entitled to market additional equities to the client one month later- unless this was to be carried out via a branch.


Should you need any additional information, advice or assistance, please do not hesitate to contact us on +44 (0) 20 3056 0956 or email us on info@mpacgroup.co.uk







MPAC is proud to be a member of the
ASSOCIATION OF PROFESSIONAL COMPLIANCE CONSULTANTS




MPAC's Safety Commitment

We have been thinking about you lately. The uncertainty that COVID-19 has imposed upon our businesses, families and communities is unprecedented. The MPAC Group share your concerns and are committed to helping you through this challenging time.


Like other companies, we have instituted work from home policies. Our team is equipped with excellent collaborative tools and technology, so this change in operations will not impact accessibility to the company’s resources or expertise.


We understand that these are uncharted waters, and you may have questions. If you want to connect with us, we’re here. We remain committed maintaining open lines of communication and equipping you with guidance and expertise to weather this storm. We recognize the gravity of this disruption, both to your business and your global community. No matter how this situation develops, we will be here to support you.