The Regulatory Committee reviewed the Blueprint Two Exit Plan, noting data protection implications and the need for managing agents to assess transfer risks. Updates were shared on the SMB legal opinion and anti-bribery guidance. The committee discussed the FCA’s upcoming Insurance Simplification consultation and agreed to collate questions ahead of the 20 May COG session.

Consultations covered included ransomware, AI governance, terrorism as a standard peril and pay gap reporting. Members were asked to provide jurisdictional examples to support the FCA’s redress system review. International updates included Brazil’s reinsurance legislation, New Zealand COFI training and India’s model clause. The committee also discussed LIC’s funds withheld model and requested agreement wording.

The LMA’s financial crime workstream is producing guidance on the new corporate failure to prevent fraud offence.