Thought Leadership
Expert Analysis and perspectives on critical GRC topics and trends.
The FCA's Digital Assets Regime Will Redraw Fund Distribution
10 January 2026
The FCA’s emerging regulatory framework signals a fundamental rebuild of fund distribution infrastructure through stablecoin rules, tokenised fund units, and crypto ETN access.
Consumer Duty's Assessment of Value Is Quietly Reshaping Fund Economics
20 October 2025
The FCA’s Assessment of Value obligation is enforcing structural change in fund economics.
Fee compression is becoming regulatory fact, not market choice.
Operational Resilience Is Not a Technology Problem. It Is a Governance Problem.
15 December 2025
The FCA expects operational resilience governance as a board mandate.
Fund managers built technology resilience. The gap is where enforcement lands.
Why Templated Compliance Frameworks Are the Biggest Risk UK Fund Managers Face
15 September 2025
The FCA assesses what you’ve built, not what you bought. Firms using off-the-shelf compliance architectures are systematically mispricing their regulatory risk.
Fund Tokenisation Is Not just a Technology Upgrade. It Is a Governance Restructuring.
20 November 2025
The FCA’s tokenisation consultation is being read as a market-modernisation exercise.
It is more consequential than that. CP25/28 begins to reallocate dealing, operational and compliance functions across the UK fund chain, raising harder questions about AFM relevance, depositary responsibility, SM&CR accountability and Consumer Duty.
For boards, the issue is no longer whether tokenisation arrives, but whether governance now keeps pace.
Private Credit Liquidity Crisis. Why Retail Fund Redemptions Are Exposing a Structural Flaw
01 March 2026
The private credit industry sold retail investors a simple promise: institutional-grade returns with mutual-fund-style liquidity. That promise is now unravelling.
Blackstone is writing cheques from its own balance sheet to meet redemptions. Blue Owl has permanently gated its retail credit fund. BDCs are trading at their steepest discount since late 2022.
The $2 trillion liquidity illusion has met its first real stress test.
Understanding the Private Debt Market
It’s amazing how private debt has transformed from a niche alternative investment category in just over a decade. Before the 2008 financial crisis, when I had just started out, private credit funds played what I can describe as a “complementary” role, often providing the final slice of financing and assuming the highest credit risk in traditional capital structures. When banks suddenly retreated from middle-market lending post-crisis due to heightened regulatory pressures, private debt managers seized the opportunity, evolving from the gap fillers to primary capital providers.
Simplifying the Regulatory Capital framework for Investment Firms
SM&CR Was Built for Banks. Fund Managers Are Paying the Price.
18 August 2025
SM&CR was designed for banks with clear chains of command. Fund managers by contrast operate in a different way. Their decisions are spread across partners, committees, outsourced providers and multiple entities, leaving accountability harder to pin down than the rules expect. This deep dive examines where this creates accountability gaps, why the FCA is probing more aggressively, and how managers can redesign their accountability framework.
Optimal fund structures for Private Debt strategies.
15 May 2025
The architecture of a private debt fund can fundamentally impact its operational efficiency, capital deployment capabilities, and investor appeal. While investment strategy rightly dominates the discussion of private debt opportunities, fund structure selection is an equally important decision that determines long-term success. The appropriate structure can maximise capital efficiency and investor alignment, while suboptimal structures can create friction even with sound investment execution.
Selecting fund domiciles for Private Debt funds
06 June 2025
The selection of fund domicile is a strategic decision for private debt managers, influencing everything from investor accessibility to operational efficiency. Yes, investment strategy usually drives the preliminary discussions, but jurisdictional selection impacts a fund’s regulatory profile, tax efficiency, and institutional appeal. Luxembourg and the Cayman Islands remain the predominant jurisdictions, with 59% of private debt managers establishing vehicles in these locations, followed by the US, Ireland and UK as secondary preferences.
How does Proportionality apply for New and Simple Firms?
17 March 2025
Firms going through the regulatory authorisation process often struggle to assess the extent to which standard rules and regulations apply to them and what best practice is, especially when designing their governance and compliance framework and drafting regulatory documents, policies and procedures.
Identifying Market Manipulation in Digital Assets
28 April 2025
“We ran it through our market surveillance tools, but nothing was flagged as suspicious.” I’ve heard this from a manager tipping their toes in the digital asset space using legacy detection systems. I am not surprised to say the least, considering some of the manipulation techniques in the crypto markets are entirely new without parallels in traditional finance. Market manipulation in digital assets can be from familiar patterns with new twists to entirely new exploitation techniques enabled by blockchain.
Designing effective Risk Management Frameworks for Digital Assets
07 April 025
As institutional investors increasingly eye the digital asset space, I’ve observed a concerning trend: many are attempting to apply traditional risk frameworks to a market that plays by fundamentally different rules. As someone who has advised asset managers on their digital assets risk management strategies, I can tell you firsthand that this approach is like bringing a knife to a gunfight.
Navigating G-SII Designation: A Practical Guide for Global Banking Institutions
24 July 2025
Large banking institutions operating across multiple jurisdictions often struggle to assess their exposure to Global Systemically Important Institution (G-SII) designation and understand the practical implications of enhanced capital requirements. This complexity is particularly acute when institutions are approaching the threshold metrics or undergoing significant structural changes.