Following the Rules

Lucy McNulty

An insider’s guide to the laws dictating life within UK and EU financial services, the people influencing their development and policing finance workers’ compliance

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#113
Monday · 34 min
How to prepare your firm for UK crypto authorisation with the Financial Conduct Authority's Dominic Cashman
The UK crypto industry is approaching a fundamental regulatory shift. Firms that have operated under relatively limited oversight by the UK’s Financial Conduct Authority are preparing to become fully regulated financial services businesses, bringing much broader expectations around governance, consumer protection, capital and conduct. Today’s episode is part of a Following the Rules series delivering practical guidance on legal, regulatory, technological and cultural change. In this episode, we explore what the FCA will really be looking for when its crypto authorisation gateway opens, including why using AI to produce policies and controls won’t compensate for senior managers who don’t understand them, and why the FCA’s growth objective will not mean lowering the authorisation bar. Joining me is Dominic Cashman, the FCA’s Director of Authorisations and one of the people at the heart of determining which firms meet the regulator’s standards for entry. He spent 25 years in senior operational and transformation roles across major financial firms, including TP ICAP, Nomura and Deutsche Bank, before joining the FCA in 2022 We discuss how the FCA will judge whether firms are genuinely ready for regulation, the red flags that can reveal deeper problems with culture and leadership, and why Cashman believes a young crypto industry needs to prepare for the existential crises it has yet to face.
#112
September 7 · 52 min
DFSA’s Mark Steward on rethinking AI regulation, repricing conflict in the Middle East and safeguarding Dubai’s growth
Today’s guest cautions that regulators face a growing gap in understanding and managing the scale and complexity of AI risks and asks whether traditional, technology-neutral regulation can keep pace as adoption accelerates. He also discusses how Dubai International Financial Centre is weathering conflict in the Middle East. Firms and capital continue to flow into the Centre, but he says that the impact could become more pronounced as businesses reprice a conflict many expected to be short-lived. And, amid disruption to cloud infrastructure in the region, he discusses operational resilience, technology concentration, and whether regulators themselves fully understand their exposure to critical infrastructure. Mark Steward is one of the most experienced international regulators of his generation. He previously held senior roles at the Australian Securities and Investments Commission and Hong Kong’s Securities and Futures Commission, before spending seven years at the UK’s Financial Conduct Authority, where he led Enforcement and Market Oversight and latterly also oversaw its International Division. Since May 2025, he has been Chief Executive of the Dubai Financial Services Authority (DFSA), leading the regulator for one of the world’s fastest-growing financial centres. He spoke with Following the Rules on 26 August.
#111
July 27 · 50 min
How to build better regulators with former Bank of England and FCA executives Lyndon Nelson and Gavin Stewart
Regulation has never been under greater scrutiny. Around the world, governments are asking regulators to support growth and innovation while continuing to protect consumers, preserve financial stability and prevent the next crisis, and increasingly, to do all of it at once, as if the trade-offs between them didn't exist. Today’s episode is part of a Following the Rules series delivering practical guidance on navigating legal, regulatory, technological and cultural change. Joining me are Lyndon Nelson, former Deputy CEO of the Prudential Regulation Authority and Executive Director at the Bank of England, where he spent more than 30 years in senior regulatory and supervisory roles, and Gavin Stewart, a former senior leader at the Bank of England, the Financial Services Authority and the Financial Conduct Authority, including serving as the FCA's Chief Risk Officer. Together, they are the authors of Building Better Regulators: The Art of the Impossible. In this episode, we discuss why regulation is fundamentally about managing trade-offs rather than eliminating risk, why regulators remain among the least understood public institutions, and what happens when political pressure demands growth, competitiveness and stability all at once, without acknowledging that something has to give. Whether you work in regulation, financial services or public policy, this episode offers a practical and timely perspective on what it really takes to build better regulators. ---- You can pre-order Building Better Regulators: The Art of the Impossible here. You can play the enforcement game Lyndon mentions here.
#110
July 13 · 29 min
Special episode: How to unlock AI innovation without losing control with Smarsh's Goutam Nadella
Today's episode is a special one, produced in association with Smarsh, a technology firm that helps financial institutions capture, govern and monitor their communications. This episode forms part of our Following the Rules: How To series, focused on practical guidance for firms navigating legal, regulatory and technological change. Today we're discussing Smarsh's new 2026 AI Trends Study, conducted by FTI Consulting, which argues that communications data is moving from being a regulatory obligation to one of an organisation's most valuable strategic assets. But it also highlights a growing challenge. While firms are racing to deploy AI, governance is struggling to keep pace. Communications data remains fragmented, shadow AI is creating new blind spots, and many compliance teams are being asked to manage risks they were never designed to oversee. So what does good AI governance actually look like? How do firms unlock the value of communications data without creating new regulatory risks? And what should compliance leaders be doing now to build the right foundations for AI? Joining me to discuss this is Goutam Nadella, Chief Strategy Officer at Smarsh. We explore the report's findings, why AI governance starts with data governance, and why the firms that get this right may find compliance becoming a competitive advantage, rather than simply a control function.
#109
June 29 · 58 min
How to rewire UK financial regulation for growth with the PRA's David Bailey, FCA's Kate Collyer, former City minister John Glen, shadow City minister Mark Garnier and New Financial's Max Bierbaum
Today’s episode is a little different to normal. It’s a recording of a panel discussion I was Invited to moderate a recent event convened by the Managed Funds Association or MFA, the global trade body for the alternative asset management industry, and organised by POLITICO. The discussion brought together senior figures from across financial services, regulation and policymaking to explore one of the biggest questions facing the UK today: how to balance growth, competitiveness and financial stability. We discussed whether the UK’s regulatory reforms are delivering on their ambitions, the role of regulators in supporting innovation, the future of UK capital markets, and what it will take for the UK to remain a leading global financial centre. I hope you enjoy it.
#108
June 15 · 36 min
Nomura's Chris Barlow on taking politics out of regulation, preparing compliance for the future and building the right culture
Today’s guest argues that one of the biggest risks facing financial services isn’t market volatility or even regulatory complexity. It’s the growing politicisation of the rulebook around the world. As geopolitical tensions rise and regulatory regimes increasingly diverge, he warns that firms are being forced to navigate a world where consistency and predictability can no longer be taken for granted. From the UK’s search for competitiveness to deregulation in the US and a different trajectory in Europe, he explains why fragmentation is becoming a strategic challenge for legal and compliance teams. He also reflects on how the role of legal and compliance is changing. Increasingly, it is about helping businesses navigate uncertainty, exercise judgment and build cultures where challenge, escalation and accountability are embedded long before problems emerge. And as AI reshapes the way firms identify risk, he discusses how new technologies could transform compliance functions while also raising expectations of what firms should be able to see and prevent. Chris Barlow’s 30-year career includes more than two decades at international bank Nomura, where he now guides its Europe, Middle East and Africa business through regulatory change, market disruption and evolving risk landscapes as a Managing Director, and Nomura’s General Counsel for EMEA, Joint Wholesale Chief Compliance Officer and Head of Legal and Compliance for the bank’s EMEA operations.
#107
June 1 · 37 min
How to ensure your insurance reflects your risk profile with Willis’ Claire Nightingale, Paul Search and Andrew Hill
Today’s episode is produced in association with Willis, one of the world’s leading risk advisory, broking and solutions businesses. It is also part of a Following the Rules series delivering practical guidance on navigating legal, regulatory, technological and cultural change. Insurance has traditionally been viewed as a way of transferring risk. But for financial institutions facing rising regulatory scrutiny, growing cyber threats and the rapid emergence of AI, insurance is now becoming a much more strategic board level issue. Boards are increasingly expected to understand exactly what they’re buying, what it covers and how it fits into the firm’s wider resilience strategy. So what does good insurance governance actually look like? How should firms decide what cover they need? How much is enough? And as risks become more interconnected, where are the biggest gaps beginning to emerge? Joining us to discuss these questions are three experts in the field. Claire Nightingale is a former bank General Counsel and Head of Global Banking Compliance who now helps financial institutions navigate and recover complex insurance claims as Global Head of FINEX Financial Institutions Claims Advocacy at Willis. Andrew Hill is a former insurance lawyer who now leads Willis’ Cyber Coverage and Innovation team alongside its AI coverage strategy. And Paul Search is a Managing Director at Willis, specialising in operational risk, insurance strategy and capital optimisation. Together, they unpack why insurance is becoming a board-level issue in entirely new ways, and what firms need to do now to stay ahead.
#106
May 18 · 34 min
How to use training to reduce toxic workplace behaviour
Today’s episode is part of a Following the Rules series exploring how financial institutions can navigate legal, regulatory, technological and cultural change in practice. In this episode, we look at why traditional approaches to compliance training are increasingly falling short in a regulatory environment focused on culture, conduct and behavioural risk. Against this backdrop, firms are now facing difficult questions. Why do so many training programmes fail to change behaviour in practice? Where are institutions most exposed when culture and compliance fall out of step? And how can organisations create environments where people feel confident to speak up before problems escalate? Joining me to explore these questions is Alison Sneddon, an employment lawyer and workplace investigations specialist who has spent her career advising financial institutions on whistleblowing, culture, employee misconduct and regulatory risk. She is also the founder of Conduct Counsel, a specialist training provider for financial institutions. Together, we discuss why traditional compliance training is often missing the mark, how the FCA’s new non-financial misconduct rules are changing expectations, and what firms need to do now to build cultures that are genuinely respectful, psychologically safe, and regulator-ready ---- For more on Conduct Counsel: www.conductcounsel.com
#105
May 4 · 52 min
How to succeed as a Chief Compliance Officer in today’s markets with compliance and risk strategists Natalie McManus-Barnett and Jennifer Geary
Today’s episode is part of a Following the Rules series delivering practical guidance on navigating legal, regulatory, technological and cultural change. In this episode, we turn to a role that has quietly but fundamentally shifted over the past decade: the Chief Compliance Officer. Once seen primarily as a control function, compliance is now expected to sit at the centre of strategy, shaping decisions, influencing culture, and helping firms navigate an increasingly complex and fast-moving regulatory environment. But while expectations have evolved, practice has not always kept pace. Many firms are still grappling with how to move beyond checklist compliance, how to prioritise effectively in the face of competing demands, and how to embed compliance thinking into everyday decision-making, not just frameworks and documentation. So what does good look like in practice? Why do compliance programmes still struggle to deliver consistent, decision-useful insight? And how can firms reposition compliance as an enabler of sustainable business, rather than a cost centre? Joining me to explore these questions are Natalie McManus-Barnett, a former regulator at the Financial Services Authority and senior compliance leader at Citigroup, now founder of thought leadership institute Innovate Compliance, and Jennifer Geary, a former Chief Operating Officer and Chief Risk Officer with senior roles at Barclays and Santander, now a non-executive director and author of five best-selling books in the C-Suite series. Together, they have brought their experience into a new book, How to Be a Chief Compliance Officer, which sets out a practical framework for modern compliance leadership. If you are thinking about how to make your compliance function more effective, more credible, and more aligned with business strategy, this episode is for you. ---- More on The C Suite Framework: https://csuiteframework.co.uk/ More on Innovate Compliance: https://www.innovatecompliance.co.uk/
#104
April 20 · 37 min
Former Goldman’s compliance exec Mark Taylor on fixing accountability in banking, and why banks still get the basics wrong
Today’s guest argues that after decades of regulatory expansion, compliance is still failing at the basics. From incomplete client records to fragmented legacy systems, he warns that poor data remains one of the industry’s most persistent, and underestimated, risks. He challenges the industry’s growing reliance on process, questioning whether accountability regimes and surveillance have come at the expense of judgment, culture and open challenge - the very things that prevent problems before they crystallise. And he explores what happens as technology accelerates ahead of understanding, from AI-driven efficiency to the rise of crypto, warning that regulators and firms alike risk falling behind the businesses they are meant to oversee. Mark Taylor began his career at the Securities and Futures Authority, a predecessor to the Financial Conduct Authority, and spent two decades at Goldman Sachs in various senior compliance positions including its EMEA Head of Financial Crime Compliance. Since 2023, he has run consultancy Ibex Compliance as its partner.
#103
March 25 · 26 min
Special episode: How to modernise voice surveillance for today’s markets with Smarsh's Eric Wiggins and Shaun Hurst
Today’s episode is a special one, produced in association with Smarsh, an AI technology firm providing global financial institutions with tools to capture, store and monitor their communications across 100+ channels. This episode is part of our ‘Following the Rules: How To’ series, focused on practical guidance for firms navigating legal, regulatory and technological change. In this episode, we turn to trader voice - a mission-critical part of market infrastructure now under growing pressure as trading evolves, with hybrid working, mobile devices, multiple platforms, shorter settlement cycles, and increasing regulatory scrutiny around supervision, auditability and operational resilience. That raises some important questions. Are the voice systems many firms still rely on fit for today’s environment? What does good look like under current regulatory expectations? And how should firms be thinking about surveillance, data and defensibility as scrutiny continues to increase? Joining me to discuss this are Eric Wiggins, product marketing director at Smarsh, and Shaun Hurst, principal regulatory advisor at Smarsh. They share their perspectives on how the risk profile of trader voice has changed, where legacy infrastructure falls short, and what firms should be doing now to build voice frameworks that are genuinely regulator-ready.
#102
March 10 · 29 min
Former insider trader Tom Hardin on the blind spots in finance’s fight against market abuse
Today’s guest is better known to the FBI as ‘Tipper X’, a former hedge fund analyst who became a key cooperating witness in the largest insider trading enforcement sweep in a generation, helping authorities bring cases against more than 80 individuals. In this episode, he explains why market abuse is rarely a single rogue act. Instead, it’s an incremental process, driven by performance pressure, network drift and the quiet normalisation of ethical grey zones. Drawing on his experience inside a hedge fund, inside a federal investigation and now advising firms and regulators, he argues the industry remains too focused on detecting bad trades rather than preventing bad decisions. He challenges compliance leaders to look beyond surveillance dashboards, to measure culture as seriously as they measure transactions, and to rethink escalation pathways before misconduct crystallises. And he urges regulators to invest as heavily in prevention and human insight as they do in enforcement technology. Tom Hardin now works with boards and compliance teams globally, helping them spot the warning signs before misconduct becomes a headline. He is also the author of Wired on Wall Street, which tells the story behind the codename ‘Tipper X’. ---- Want to read Tom’s book? Find out more here: https://www.tipperx.com/book
#101
February 24 · 44 min
FCA deputy CEO Sarah Pritchard on the regulator's to-do list as it navigate new rules, new risks and "uncertain" times
Today’s guest sets out the Financial Conduct Authority’s to-do list for 2026 and beyond. She details the watchdog’s plans to future-proof UK financial regulation, and outlines what City firms should expect as landmark reforms, including new rules on non-financial misconduct, begin to bed down. She discusses the FCA’s efforts to build a more open relationship with financial institutions and explains why a more collaborative partnership between regulator and regulated is crucial in the face of unprecedented and rapidly evolving geopolitical, technological and market risks currently shaping financial services. She also outlines how the watchdog is balancing growth and competitiveness with its core duty to protect consumers and markets and explains why it will continue to push for clearer political accountability to support that task. Sarah Pritchard’s near three-decade career includes senior roles at banking giant HSBC and the UK’s National Crime Agency. She joined the FCA in 2021 to lead its Supervision, Policy and Competition division and was appointed the regulator’s first Deputy Chief Executive in 2025.
#100
February 10 · 45 min
How to handle non-financial misconduct without damaging organisational culture, with former Standard Chartered surveillance chief Emily Wright and conduct risk consultant Emma Parry
Today’s episode is part of a Following the Rules series delivering practical guidance on navigating legal, regulatory, technological and cultural change. In this episode, we turn to one of the most challenging and fast-evolving areas of regulatory focus: non-financial misconduct. With the UK’s Financial Conduct Authority set to introduce new rules this year that explicitly bring serious non-financial misconduct within scope of the conduct rules, expectations on firms to identify NFM, address it early, and evidence fair and consistent outcomes are rising fast. And this isn’t just a UK story: regulators globally are paying much closer attention to culture, behaviour and individual conduct. So what does good look like when regulatory guidance is deliberately principles-based? Why are firms still struggling to translate expectations into defensible decisions? And how can they respond to lower-level misconduct in a way that genuinely supports culture, rather than quietly undermining it? Joining me to explore these questions are: - Emily Wright, a compliance and conduct consultant with over 20 years’ experience, including senior roles at Standard Chartered, JP Morgan and ICAP, and,- Emma Parry, the Founder and CEO of NovaFin Consulting and former Global Head of Product Governance and Conduct in HSBC’s Global Banking and Markets division. Together, we unpack what the FCA’s rule changes mean in practice, where firms are getting stuck, and why remediation, not just punishment, is becoming a critical part of the conduct conversation. We also discuss the launch of the Conduct Compass, a new framework designed to help firms address non-financial misconduct earlier, more consistently, and in a way that drives real behavioural change. If you’re grappling with how to make conduct frameworks work on the ground, and how to get ahead of regulatory expectations on culture, this episode is for you. ---- Download the Conduct Compass white paper here: https://go.ewrightconsulting.com/free-conduct-compass-wp-lm
#99
January 27 · 31 min
Special episode: How to modernise trader voice technology to better meet today's regulatory demands with Symphony's Ben Chrnelich and Antoine Stephen
Today’s episode is a special one produced in association with Symphony, a secure and compliant communications and markets technology provider, offering messaging, voice, directory and analytics for financial markets and trading teams. It also forms part of a new Following the Rules series providing practical, actionable guidance to help listeners and the financial services firms they work for navigate legal, regulatory, technological, and cultural change. In this episode, we turn to a part of market infrastructure that is mission-critical but often overlooked: trader voice. As firms grapple with hybrid working, rising regulatory expectations, and growing scrutiny around operational resilience and third-party risk, the case for modernising legacy voice technology is becoming harder to ignore.  So why has trader voice remained so static for so long? What has changed to make transformation both possible and necessary? And how should firms be thinking about compliance, surveillance, and governance as they move away from traditional on-premise turret systems? Joining me to explore these questions are: Ben Chrnelich, CEO and president at Symphony, and  Antoine Stephen, head of product management for Symphony's Cloud9. Together, they share their perspectives on the regulatory pressures shaping investment in trader voice, the practical realities of moving to cloud-based and software-driven solutions, and how data, analytics and AI are set to reshape voice communications on the trading floor in the years ahead.
#98
January 13 · 45 min
FRC CEO Richard Moriarty on cutting red tape, calling time on “dumb” compliance checklists and futureproofing the accounting watchdog without the legislative powers he was promised
Today’s guest is leading the UK’s audit regulator through reform without the legislative powers originally promised. Two years into the job, he argues the Financial Reporting Council is acting anyway, using proportionate, common-sense regulation to support growth and investment. He sets out a pragmatic agenda for keeping UK audit credible and relevant, covering everything from market concentration and SME audits to AI and the future talent pipeline. He explains why the watchdog has stripped back governance and stewardship codes, warning that over-prescription has driven box-ticking and weakened board accountability. He defends comply-or-explain as a strength of the UK system and urges companies to be braver in using it. And he renews his call for political action to back his reform agenda in peacetime, before the next corporate failure forces Parliament’s hand. Richard Moriarty is Chief Executive of the FRC, the UK regulator responsible for audit, corporate reporting and governance.
#97
Dec 16, 2025 · 46 min
Special episode: How to prepare for the next wave of crypto regulation
Today’s episode is part of a special series of Following the Rules, produced in association with Simmons & Simmons, an international law firm supporting financial institutions across the global regulatory landscape. The series offers practical insights to help firms navigate legal, regulatory, technological and cultural change. Today, we’re examining one of the most complex shifts in modern financial regulation: the process of bringing crypto into the regulatory perimeter. Across the UK, EU and US, policymakers are rewriting the rulebook at pace - not only to manage risk, but also to reflect the rapid developments in digital finance. For firms, that means heavier compliance obligations, shifting expectations, and a genuine opportunity to help shape the rules ahead. So what should businesses be preparing for now? Which parts of the regulatory agenda will hit hardest in the coming months? And how do firms avoid the strategic and structural mistakes that can derail applications or push innovation offshore, while positioning themselves to benefit from clearer rules? To help unpack all of that, we’re joined by two people at the centre of developments: Gordon Ritchie, is a Managing Associate in the UK financial regulation team at Simmons & Simmons, advising firms across the evolving UK and EU crypto regimes; and Tom Duff Gordon, is Vice President for International Policy at Coinbase, leading the crypto exchange’s engagement with governments and regulators globally as they design the next generation of digital-asset rules. Together, they explore where the regulatory landscape is heading, how business models will need to adapt, and what firms can do today to be ready for, and benefit from, the regulatory wave ahead. --- Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...
#96
Dec 2, 2025 · 37 min
Market Structure Partners' Niki Beattie on why, and how, we need to rethink how markets work
Today’s guest delivers a blunt warning to policymakers, arguing the UK has made “a massive mistake” by failing to stop trading venues from charging for market data - a failure she says has weakened the country’s competitiveness. She calls on the government to “wake up and listen” to the scale of the issue or risk losing ground to rival financial centres. She also argues that the industry’s fixation on blockchain as a panacea to everything has been a decade-long distraction. She sees the real shift now reshaping markets as the move to 24/7 global trading, clearing and settlement. City bosses, she warns, must prepare now by overhauling legacy systems, or risk becoming obsolete. And she sets out a bold vision for London: to use its existing market infrastructure to become the trusted global venue where any asset can be traded and transferred safely, 24/7, between counterparties. Niki Beattie has been at the forefront of market infrastructure transformation throughout her career of more than 30 years in financial markets, including more than a decade as Head of EMEA Market Structure at Merrill Lynch International. She founded consultancy Market Structure Partners in 2008 and has extensive experience as Non Executive Director and Chair of public and privately listed firms in the international financial sector. She is currently Chair of ClearToken, the UK digital-asset clearing and settlement house and a non executive Director of the Financial Markets Standards Board. ---------- Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...
#95
Nov 18, 2025 · 55 min
Special episode: How to navigate a dawn raid with the SFO's Emma Isaac and Simmons & Simmons' Camilla de Silva
Today’s episode is part of a special series of Following the Rules produced in association with Simmons & Simmons, an international law firm supporting financial institutions across the global regulatory landscape. The series offers practical insights to help financial services firms navigate legal, regulatory, technological, and cultural change. In this episode, we’re diving into one of the most intense moments a business can face - a dawn raid. When Nick Ephgrave took over as Director of the UK Serious Fraud Office in 2023, he’s pledged “swifter action and more dawn raids” - a clear signal that the agency is refocusing on proactive, visible enforcement. But what does a dawn raid actually look like in practice? How should firms respond when investigators appear unannounced at the door? And how can businesses prepare, both legally and culturally, for such a high-pressure event? To answer these questions, we’re joined by two experts on the topic: Camilla de Silva, who spent over five years at the SFO, rising to Joint Head of the SFO’s Fraud, Bribery and Corruption division, before joining Simmons & Simmons in 2020 as a Partner in its Disputes and Investigations group. Since 2023, she has lead Simmons & Simmons’ Corporate Crime and Global Investigations group; and, Emma Isaac, who worked as criminal legal adviser before moving to the SFO in 2013. In February, she became a member of the agency’s senior leadership team when she was appointed Joint Head of the SFO’s Fraud, Bribery and Corruption division. Together, they discuss how enforcement dynamics are shifting, what mistakes companies tend to make under pressure, and what practical steps legal and compliance teams can take today to be ready if the SFO comes knocking. ---- Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...
#94
Nov 4, 2025 · 31 min
Graham Kent, Deutsche Bank's Group Chief Compliance Officer, on the compliance challenges shaping the industry’s future
Today’s guest outlines how the accelerating pace of regulatory change poses significant challenges for global financial institutions. He highlights that fragmentation can create a complex landscape for banks’ compliance divisions, and underscores the benefits of adopting a more coordinated, risk-based approach to rulemaking. He also discusses how the industry could best evolve the traditional three lines of defence model, how banks can better anticipate risks and how banks and regulators can collaborate to achieve an effective balance between protecting markets and promoting growth. Graham Kent’s career spans three decades and includes seven years as a lawyer at Clifford Chance. He joined Deutsche Bank’s legal department in 2006. He has since held several senior roles across the bank’s legal and compliance divisions before becoming its Group Chief Compliance Officer in 2024. ---- Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...

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