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 the Anti-Greenwashing rule which came into force on 31 May 2024.

The last meeting of the WG was held on 28 November 2024 and a draft summary can be read here.

The WG will inform AFB’s response to the HMT UK Green Taxonomy consultation.

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 FCA Guidance Consultation 24/4 on proposed amendments to the Guidance on the treatment of Politically Exposed Persons (here), and the HMT Consultation on improving the effectiveness of the MLRs  (here).

The last meeting of the WG was held on 11 September 2024 and a draft summary can be read here.

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.

The last meeting of the PRN was held on 5 December 2024 and a draft summary can be read here.

This WG was created to identify tax related issues specific to international banks operating in the UK. The group will identify challenges, provide insight into how that has an effect on the competitiveness of international banks operating in the UK, and propose potential solutions or more efficient ways to operate.

Following the collapse of Silicon Valley Bank UK, the PRA informed AFB that it was 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.

This group informed AFB’s response to PRA Consultation Paper 11/24 – International firms: Updates to SS5/21 and branch reporting.

This Working Group was formed following the FCA/PRA DP3/22 – 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. The WG informed AFB’s response to PRA/FCA CP26/23 – Operational resilience: Critical third parties to the UK financial sector, which was submitted in March 2024.

AFB will continue to monitor developments on this topic following the publication of PS 16/24 – Operational Resilience: Critical Third Parties to the UK Financial Sector and joint Supervisory Statement 6/24.

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.

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 outlined 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.

On 21 March 2024 HMT published ‘Building a Smarter Financial Services Regulatory Framework: Next Phase’, which listed the progress made by then on the programme and set out the government’s approach to the remaining assimilated law.

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

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 biannual updates on the work of FSSC.

The Working Group was initially formed in 2020 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 5 February 2025 the PRA will hold a roundtable to discuss with the WG its supervisory expectations for category 2-4 subsidiaries on operational resilience ahead of the 31 March 2025 deadline for the full implementation of all aspects of the PRA’s operational resilience policy (SS1/21).

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’. AFB submitted its response to the consultation paper on 29 April.

On 26 April 2024 AFB signed a joint trade association letter, sent to the Chancellor Jeremy Hunt MP, on the FCA’s proposals.

The WG will inform AFB’s response to CP24/2 – ‘Part 2: Greater transparency of our enforcement investigations’.

This Working Group was formed after the publication of Consultation Paper PRA 16/24 and FCA 24/23 in November 2024. The WG will hold a meeting on 24 January to inform AFB’s consultation responses.

One year after the implementation deadline of the New Consumer Duty, the FCA published a Call for Input on the Review of FCA requirements, which considered whether the Regulator could simplify its retail conduct rules and guidance via addressing potential areas of complexity, duplication, confusion, or over-prescription.

The Working Group supported AFB’s response to the CfI, which was submitted on 31 October 2024.

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 with the relevant stakeholders when updates on the SM&CR regime will be published. FCA/PRA/HMT consultation papers are expected to be published in Q1 2025.

This Working Group was formed to feed into discussions on PRA Policy Statement 5/24 – ‘Solvent exit planning for non-systemic banks and building societies’  ahead of its 1 October 2025 implementation.

On 20 November 2024 AFB held a roundtable with the PRA at Deloitte to discuss the PS (PRA slides here).

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’ 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.

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 meeting on 26 January 2024 with the Department for Business and Trade to provide feedback on the recent amendments. In July 2024 AFB published its position paper ‘The UK Immigration System – Proposed Amendments to Requirements’.

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.

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. 

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.

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 discussed the implementation of CRD VI with peers and increase their understanding of the requirements.

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.

On 12 September 2022 AFB held a meeting for members interested in contributing to it’s response to CP6/22. Following feedback and comments from members, the AFB submitted its response to CP6/22 on 21 October (here).

On 15 December the AFB hosted a virtual member roundtable on CP6/22 with the PRA.

On 21 April 2023, an AFB MRM member survey was launched, in partnership with KPMG. The results of the MRM survey were presented as part of the AFB-KPMG virtual seminar (recording here) on the PRA’s final MRM principles as set out in PS6/23 and SS1/23.

AFB held a practice workshop on 18 April with Mazars ahead of the principles coming into effect on 31 May 2024.

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.