We are issuing a one off newsletter during the month of December. Not an annual review as it would be difficult to put into a limited amount of space what type of year 2020 has been. But to reflect that on 12 December, this marks 15 years since Gem Compliance was established and therefore we thought we would mark the occasion, as any reason to celebrate these days is personally welcomed! 
We issued a similar newsletter for the first time around Gem’s 10th anniversary, and so this edition reflects on the last five years since then, although even then, there seems to be plenty to review. This includes: 
  • Increase in our client base, personnel, and office space;  
  • Regulatory developments, with the last couple of years being particularly busy; and 
  • Political landscape: difficult to know where to start!  
Gem Compliance
At Gem, this has brought about an expansion of the team alternating between 8 to 10 members over the last couple of years. This includes most recently a new Compliance Associate being recruited, joining and going through induction all under lockdown. How strange that must have been. 
Some colleagues have also moved onto pastures or even countries new but we remain in touch. 
We also increased office space in July 2019 although in practice have seen very little of the office in 2020. However the key thing being that due to flexibility of working conditions before Covid-19, we were able to move to remote working quickly and seamlessly. However we very much look forward to being able to go back into the office at some stage in 2021 as despite working arrangements, something that can’t be replaced is seeing and speaking to teammates in 3D/person.
Regulatory developments
This has included (but is not an exhaustive list): 
  • MiFID II
  • GDPR/UK Data Protection Act
  • PRIIPs
  • Senior Managers and Certification Regime
  • Brexit. 
As ever, compliance is full of acronyms! 2018 proved to be a particular busy year with MiFID II and GDPR implementation overlapping. Future developments include of course Brexit planning but also into 2021 onwards, planning for the the new Investment Firms Regulation, which will restructure prudential supervision of investment managers but also exempt CAD firms. 
Political and external environment
Back in 2015, it might have been difficult to foresee many of the changes that have happened during the period including:
  • Brexit, including 4.5 years beyond the vote, decisions on how the UK will operate globally  from 1 January 2021 still not being clear with 3 weeks to go.  
  • Donald Trump becoming US President and it will be interesting to see what happens in the US over the next month or so prior to inauguration including whether he attends – and in what capacity!  
  • Boris Johnson becoming UK Prime Minister, the third of three Prime Ministers in just over 4 years.  
And finally … 2020  
And whilst perhaps not wanting to focus too much on 2020 itself, with it now being over 9 months  since the full impact of Covid-19 impacted on the UK in March, this also brought about new words to be remembered (and possibly never forgotten) including: 
  • Lockdown;
  • Social Distancing; and
  • PPE and face coverings 

To name but a few.  

Apart from the obvious mental, physical and health personal impacts on large numbers of the UK population, businesses had to implement business continuity plans to adapt. But equally this has also shown that in many cases, the current way of flexible working was in fact flexible enough to adapt fairly quickly on a more permanent basis compared to perhaps had this happened even 5 years ago. But that it did also illustrate the need of having robust continuity plans in the first place.   
It has also brought about investment market volatility and uncertainty for all investment market participants, and financial (and non-financial) strains on firms, their employees and families. Ways of internal and client communication have changed massively (possibly even permanently) with less face to face meetings but a major increase – and acceptability – of video calls. Possibly another most common phrase used in 2020 is ‘you are on mute’. 
Into 2021 and onwards, it is slightly difficult to predict both short term and long term changes right at this moment until we can see how the next 12 months develop, including specifically post Brexit and hopefully post pandemic. But that equally operational resilience and compliance remains a core objective for the FCA and one which we endeavour to support for our clients. 
Finally, on behalf of the whole team at Gem Compliance, we would like to wish all newsletter recipients a healthy, peaceful and enjoyable festive season. Perhaps when looking forward to 2021, reflecting on 2020 as a year to both remember and forget for differing reasons in years to come.  

This newsletter contains generic information and has been generated for professional clients and associates of Gem Compliance Consulting Limited only and should not be regarded as advice. We will not be liable for loss, however caused by parties acting on the information contained herein.

Copyright © 2020, Gem Compliance Consulting Limited, All rights reserved.

Gem Compliance Consulting Limited, Registered in Scotland, no. SC 294346.

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Gem Compliance Consulting Limited · Hudson House · 8 Albany Street · Edinburgh, Midlothian EH1 3QB · United Kingdom

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