Country Manual Private Banking
United Kingdom
out of Bank’s Country of Establishment (Def, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | Yes |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The manual has been reviewed and updated. There have been a number of changes to the content:
There are extra comments in the BT and RT comments for Presenting the Bank in General Terms and Providing the Bank’s Annual Report and Press Reviews to reflect the text better – e.g. provided the information remains factual and objective;
There are extra comments for all negotiation activities to reflect the text better – e.g. the contract must be concluded abroad. This means that the answers for these activities by remote means are now all Grey zone/YES as opposed to mostly YES;
There are extra comments for provision of Research Material: No investment advice is given and No promotion of services or products. This means that the answers for this section by remote means are now Grey zone/YES as opposed to YES.
There have been no major legislative changes affecting the Template, but in the context of consumer law the Consumer Protection from Unfair Trading Regulations (CPUTR Regulations) have been replaced by Part IV Digital Markets, Competition and Consumer Act 2024.
Non-material changes
Some content has been amended and/or slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. In particular:
Minor changes to the wording covering EAMs in the Third Party Section.
There is further wording on controls for access to a bank’s website in the Advertising Section;
There is further wording relating to visits to UK in the Permanent Establishment Section;
BT Short Comparison
This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (MyBRPOnline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “UK” in the Target Country Field
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Geneva, July 7th, 2025