Thomas Bowie is an associate in the Financial Services Practice Group. He works on a diverse range of regulatory matters, and advises on compliance with the FCA/PRA rules and implementation of EU legislation in the UK (including MiFID II/R, EMIR, AIFMD, 4MLD, 5MLD, and PSD2). Tom acts for clients across EMEA, North America and Asia Pacific ranging from start-ups to international organisations, including banks, stockbrokers, investment managers, private equity firms, insurers and intermediaries.

    Tom has a keen interest in fintech and innovators who enable access to traditional financial products in a new technological way. Tom is an active member of a number of fintech communities and has authored articles for Bloomberg Law, Thomson Reuters and TheBusinessDesk.com on the subject.

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    Securities, Markets and Investments

    • Advising challenger banks and stockbrokers on day-to-day compliance queries and drafting customer facing terms and conditions, and key features documentation.
    • Advising large asset managers and private equity firms on ongoing regulatory compliance.
    • Advising on financial promotions and drafting exemption clauses for qualifying investors.
    • Advising on the merits of different fund structures.
    • Coordinating global surveys, including surveys on derivatives regulations, marketing of financial products, and local licensing requirements.

    Conduct of Business and Individual Accountability

    • Advising on whether proposed activities are regulated and, if so, on the necessary authorisations and permissions.
    • Advising on a full spectrum of FCA and PRA registrations and notifications, including authorisations and variations to permissions, regulatory reporting, SUP notifications and change in control notifications.
    • Advising on compliance policies and procedures, including comprehensive manuals and monitoring plans, and bespoke policies on conflicts of interest, market abuse, AML, client categorisation, treating customers fairly (TCF) and remuneration.
    • Advising on the implementation of the different senior managers and certification regimes, including applicability to banks, insurers and solo-regulated firms. Identifying relevant staff, drafting internal policies and procedures, advising on FCA applications and delivering training to staff.
    • Advising on the applicability of remuneration codes and the impact on the payment of fixed and variable remuneration.

    Financial Crime

    • Advising on and drafting business and sector specific AML policies.
    • Advising a US bank, clearing and custody operator on the operational impacts of AML legislation and reliance on third party providers to undertake customer due diligence. Addressing concerns raised by a whistleblower about alleged non-compliance.
    • Advising an Asian bank on money laundering issues and UK regulator notifications, arising from unauthorised transactions executed by one of its employees.

    Education

    • University of Law, Leeds, LPC., 2015
    • University of Law, York, GDL., 2014
    • Lancaster University, B.A. Hons., 2013

    Admissions

    • England and Wales, 2017
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