Investment Management Update - March 2026

Welcome to the latest edition of our investment management update. This publication has been tailored to highlight topical news, cases and changes in the law impacting the investment management sector.

Speech by Nikhil Rathi, chief executive: Renaissance at market speed: on 26 February Nickhil Rathi, FCA chief executive, gave a speech at the Goldman Sachs EMEA Head of Trading conference 2026. The speech:

• raised again the theme of predictable volatility which Mr Rathi described as a mix of macro uncertainty, a rapid succession of geopolitical events, the fast-moving frontier of technology, shifting liquidity conditions, and the combination of risk and opportunity coming through;
• explained the FCA's approach to reform to ensure that FCA rules don't create unnecessary friction, lock in outdated structures, or push activity into less transparent places. Mr Rathi also confirmed that further wholesale market reform would be delivered; and
• reiterated the FCA's desire for more industry engagement and set out the different ways in which firms can engage.

Renaissance at market speed: UK wholesale finance in 2026 | FCA

Consumer Duty board report review: on 24 February 2026, the FCA updated its web page to provide further insights for firms on good practice and areas for improvement when producing the annual Consumer Duty board report. Although there are additional findings focused on smaller firms, the FCA flags that the findings are relevant for all firms. Areas for improvement included: data quality, oversight across distribution chains, analysis of customer types, challenges from the board, and action-taking.

Consumer Duty board reports: good practice and areas for improvement | FCA

FCA Regulatory Priorities reports: on 24 February 2026, the FCA published the first of its newly introduced annual Regulatory Priorities reports to replace its portfolio letters. Although the first report is an Insurance report, the FCA has confirmed that it will publish reports for consumer investments and wholesale buy-side in March as well as the following other sectors: pensions, retail banking, mortgages, consumer finance, wholesale markets and payments.

The reports will set out specific key priorities for each sector and further work that the FCA will undertake in the next year. The FCA has made clear that boards and CEOs should review the reports and act on the priorities set out within.

Regulatory Priorities reports | FCA

Appointed Representatives: on 12 February 2026, the Treasury consulted on changes to the appointed representatives regime to address concerns that poor oversight is putting consumers at risk. This follows last August's Treasury policy statement. Please see our article for further information on the proposals which include:

• a requirement for an FCA permission to act as principal;
• the extension of FOS jurisdiction to appointed representatives; and
• bringing appointed representatives within scope of the Senior Managers and Certification Regime.

Consultation paper

Joint Money Laundering Steering Group (JMLSG) revised guidance: on 4 February 2026, JMLSG published final amendments to Part I of its anti-money laundering and counter-terrorist financing guidance, including:

• Chapter 3 (Nominated officer/ Money Laundering Reporting Officer), on monitoring the effectiveness of money laundering controls; and
• Chapter 6 (Suspicious activities, reporting and data protection), on data protection and subject access requests in scenarios where a suspicious report has been made.

The revised guidance has been submitted to the Treasury for approval.

JMLSG revisions