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Clive Cunningham

Partner
Clive Cunningham is a partner in the financial services regulatory team at Herbert Smith Freehills, based in London.

Articles by author

Pooled audit: a welcome step forward, but not yet over the line …

The option to participate in collective assurance activities is welcome, but this article makes the case for more guidance from sectoral regulators and competition authorities to allow banks and their service providers to truly get comfortable.

1 SEP 2021

More than meets the eye: a new UK regime for critical third parties: what does it mean for regulated firms?

Financial services regulators across the globe are considering how to regulate in some way cloud providers and other information and tech service companies (critical third parties (CTPs)) which many banks and other financial institutions rely on heavily for critical services. While the European Union’s new Digital Operational Resilience Act (DORA) imposes new requirements on both CTPs and the regulated firms which use their services, the UK has started the ball rolling on a new CTP regime aimed only at the CTPs themselves. The UK regulators’ proposals for their part in the new regime are out for consultation. We take a look at some key areas of the proposals which remain unclear from the financial sector’s perspective.

1 FEB 2024