Financial promotion reform: impact on ECM transactions

On 19 January 2022, the FCA published consultation paper CP22/2 in which it proposes various changes to, among other things, the role of authorised firms in communicating and approving financial promotions. Whilst the stated focus of the paper is financial promotions in connection with high-risk investments, including cryptoassets, some of the proposed reforms will have wider implications, including for the systems and controls used by authorised persons when approving financial promotions in the context of an equity capital markets transaction.