Pan Papakyprianou
Pan is an Associate in Linklaters LLP’s Financial Regulation Group. He has experience advising a wide range of clients – including retail and investment banks, fintech and cryptoasset firms, and asset managers – on a breadth of financial regulatory matters.
Pan has advised clients in contentious, advisory, and transactional contexts. This has included advice in relation to the regulatory perimeter, client asset custody, CSDR, and AML requirements (including in relation to cryptoasset registration).
Practice Area
Panel
- Contributing Author
Qualified Year
- 2020
Qualifications
- Bachelor of Laws (LLB) (2017)
- LPC and MSc Law, Business, and Management (2018)
Education
- University of Exeter (2017)
- University of Law (2018)
1 Contributions by Pan Papakyprianou
PRACTICE NOTES
Attestations under FCA and PRA supervision in UK financial services: purpose, usage trends, enforcement risks and practical steps for firms and Senior Managers
What is an attestation?
The Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) can seek an attestation from a firm when they are worried about, or looking into, an actual or possible breach of regulatory obligations. In essence, an attestation is the regulator asking a named individual within a regulated business—typically a manager who also holds a Senior Manager function—to give a signed written statement confirming the firm’s compliance with particular regulatory requirements affecting a defined part of the business. The FCA also employs attestations as part of day-to-day supervision; for example, every firm must annually attest that the details held on the Financial Services Register are correct (see Practice Note: The Financial Services Register). The PRA likewise uses attestations routinely, generally via standardised forms, while noting that it may require attestations addressing compliance with specific rules on an ad hoc basis. As discussed below, the PRA has not, to date, made public any attempt to use attestations for investigatory purposes; nevertheless, it did request an attestation following the enforcement action against Jes Staley to monitor Barclays’ whistleblowing systems and controls...
Financial Services
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