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Legal Ease with Lexis®PSL – December 2021
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Material outsourcing to the public cloud by UK Financial Market Infrastructures (FMIs)
In September 2021 the Bank of England (BoE) published Dear CEO letters addressed to the CEOs of central counterparties (CCPs) 1 recognised payment system operators and specified service providers (RPSOs and SSPs) 2 and central securities depositories (CSDs)3 (collectively financial market infrastructures or FMIs) setting out its supervisory expectations in relation to material outsourcing to the public cloud.
The letters were a response to the concerns raised by the Financial Policy Committee (FPC) in the Financial Policy Summary and Record – July 2021.4 The FPC noted that since the start of 2020 financial institutions had accelerated their plans to scale up their reliance on cloud service providers (CSPs) and that the increasing reliance on a small number of CSPs and other critical third parties could increase financial stability risks without greater direct regulatory oversight...
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