Update

UK Regulatory Reform

	Money Laundering Verification Checks

The question of whether executing brokers have an obligation to carry out money laundering verification checks when part of a tri-partite give-up arrangement has been raised again by a number of FOA members. The JMLSG guidelines suggest that executing brokers should seek written assurance from the clearing broker that the appropriate checks have been carried out. This has led to executing brokers seeking this reassurance from clearing brokers by sending them declarations to sign. The FOA has been asked to explore whether there is some way to avoid the need for these bilateral agreements by developing some sort of central protocol that will satisfy all parties.

	Human Resources Forum

The FOA will be holding its first Human Resources Forum on 19th February at Clifford Chance's offices, 200 Aldersgate Street. Topics to be covered will include data protection, training and competence, recruitment practice and procedure, fitness of approved persons and “personnel risk”.

Details have been circulated to all member contacts and Human Resources Managers known to the FOA. However, if anyone else would be interested in attending, please contact Ann-Mari Burt (who, as you may know, is currently standing in for Julie Adolphus during her maternity leave) on +44 (020)7 426 7262.

	N2 Arrangements

The FOA continues to focus on N2-related issues. The Compliance Forum held on 30 January was structured in the form of a “roundtable” format to which a large number of N2 related problems and the usefulness or otherwise of FSA’s grandfathering and transitional arrangements was discussed. The FSA were in attendance in order to hear at first hand some of the practical problems encountered by firms. The FOA will be following up with the FSA how any difficulties being encountered by firms may be addressed (and, in particular, whether it would necessitate any change in the current arrangements).

	Director - UK Regulation

Due to the increasing focus of the FOA on EU matters and on enhancing its role as a commentator on EU regulatory policy and initiatives, the FOA is looking to recruit an extra member of staff at Director/Senior Manager level to address UK regulatory matters.