AFB Practice Roundtable: Navigating Non‑Financial Misconduct – Regulatory Expectations and Practical Challenges

Discussions will focus on the following:

• When does an incident become a breach of the Conduct Rules?
• The threshold for seriousness and how firms should assess events that may fall within the scope of the rules.
• Exploring the practical differences between the Conduct Rules (COCON) and the Fit and Proper test (FIT) in light of the FCA’s new guidance, and how these frameworks interact in real‑world scenarios.
• What constitutes sufficient pre‑employment vetting, and how firms should approach ongoing monitoring of employee behaviour in a proportionate and compliant manner.
• When firms should notify the FCA of an investigation into potential misconduct, and how to navigate the regulatory expectations around transparency and timeliness.

Why attend?

This event will offer foreign banks operating in the UK market an opportunity to:

• Gain clarity on evolving regulatory expectations
• Benchmark approaches with peers
• Review internal governance and conduct frameworks

AFB will circulate an agenda and a series of discussion points and questions in advance to those registered to attend.

The capacity for this roundtable is limited to 30 members, one person per member bank.  This ensures as many firms as possible can benefit from the discussions.  Please book early to avoid disappointment.

Who should attend?

This session is aimed at member representatives in People, Compliance and Risk.

Facilitators

Adam Jamieson, Partner

Adam focusses on advising financial services firms and senior individuals involved in internal and regulatory investigations.

He has significant experience of representing clients in regulatory enforcement investigations conducted by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA). Adam previously spent a year on secondment to the FCA’s Enforcement & Market Oversight Division. During his time at the FCA, Adam worked as an investigator on FCA and PRA investigations into both firms and individuals.

Adam has particular experience of investigations relating to: risk management systems and controls; senior management duties and governance; AML and MLRO responsibilities; obligations to notify regulators; shareholder influence; compliance with the listing rules; the client money rules; trading controls; insider dealing and control of inside information; capital requirements; and whistleblowing.

Adam frequently acts for clients in responding to regulatory reviews, including Section 166 FSMA skilled person reviews. He also advises clients on the Senior Managers and Certification Regime, regulatory notification obligations and the imposition of regulatory requirements.

Adam is recognised for his work in the financial services sector on regulatory investigations by Chambers UK.

Nathan Willmott, Partner and Head of Contentious Financial Services

Nathan specialises in representing financial institutions, listed companies, trade associations, regulatory bodies and individual members of senior management on investigations and other complex regulatory and legal issues.

He has over 25 years’ experience of supporting regulated firms and individuals in relation to FCA, PRA and multi-jurisdictional Enforcement investigations and proceedings concerning suspected regulatory breaches and criminal offences, skilled person reviews, SMCR and governance issues, thematic reviews, periodic risk assessments, whistleblower investigations, conducting internal investigations and handling related litigation.

Nathan is a member of the Advisory Board of the Financial Services Lawyers Association and is a Solicitor Advocate holding full Higher Rights of Audience in the Civil Courts. He is dual-qualified in England & Wales and the Republic of Ireland.

He is recommended as a Tier One lawyer for Contentious Financial Regulation in the current edition of Chambers & Partners, and as a Leading Individual for both Contentious and Non-Contentious Financial Regulation in current edition of The Legal 500.   

Please note you will receive confirmation of your booking via email within 24 hours. Should you not receive a confirmation, please contact AFB to double-check if your booking was successful.

Logistics

Fee: Included in AFB membership

Location: Ashurst LLP, London Fruit & Wool Exchange, 1 Duval Square, E1 6PW

Date: Monday 23 March

Time: 15:30 – 17:00 (Registration, networking and refreshments 15:00 – 15:30)

If you would like to submit a question before or have any areas that you would like the session to address, please send them to the AFB at secretariat@foreignbanks.org.uk.

You will receive final event details a week before the event.

Please note that you will only be deemed to have attended (for CPD points) if you have made yourself known at registration and attend 50% or more of the session.