Approved persons regime places greater emphasis on role of senior management

Approved persons now likely to include non-executive directors, proprietary traders, persons employed by unregulated parent companies, and others who may exert “significant influence” on the functions of regulated firms, following confirmation of changes outlined in a 12/25/2008 FSA consultation paper. The FSA has also extended the reach of the approved persons regime to UK branches of overseas firms based outside the European Economic Area.

About The Author

Felix Shipkevich

Felix Shipkevich is a Manhattan-based attorney and general counsel for Shipkevich Law Firm. He has extensive experience working with the CFTC and NFA on registration, compliance, and enforcement issues for CPOs, CTAs, FCMs, IBs, and RFEDs. Felix also practices intellectual property and corporate governance law.