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Portrait of Ash Saluja

Ash Saluja

Head of Financial Services & Products

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
United Kingdom
Languages English

Ash Saluja has over 20 years of experience advising clients on regulatory and commercial matters.

Clients include banks, broker-dealers, funds, investment managers and advisers, exchanges, platforms and trading facilities, insurers and insurance intermediaries, as well as the large corporate/pension fund clients and suppliers of these types of institutions.

Ash advises on the authorisation and conduct of business requirements, corporate governance, regulatory capital, client money and assets, product design and distribution, cross border business, insider dealing and market abuse, anti-money laundering requirements, as well as the regulatory aspects of mergers and acquisitions, restructurings, joint ventures and outsourcings.

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Legal 500, 2015

Relevant experience

  • Over a dozen FSA/FCA/PRA regulated investment advisers/managers, broker-dealers and banks over the past five years, including advice on regulatory structuring, as well as the preparation of the applications and supporting materials, policies and procedures and related agreements.  Advising on ongoing compliance obligations under the FCA/PRA Handbooks and UK/EU legislation.
  • Several banking and investment groups on the regulatory aspects of their reorganisations, including authorisations/permissions, capital and liquidity issues, change of control approvals, cross border services and branch passports and related governance/prudential issues.
  • Fund managers on the implementation of the AIFMD. Also advising numerous firms (banks, platforms, broker dealers and investment/fund managers) in relation to changes in the FCA’s client money and assets rules.  Currently advising several clients on MiFID II projects.
  • A global investment consultant on the establishment of an umbrella fund structure for “fund of funds” and “multi manager” arrangements post AIFMD. Also advising a large general insurer on the establishment and on-going activities of two in-house umbrella investment funds (an AIF and a UCITS) and the establishment of a new UK portfolio manager.
  • Over twenty large institutional investors on a range of issues including potential investments in pooled funds, custody and segregated mandate arrangements, transition management and bespoke investment structures.
  • UK private banking groups on the implications of their offerings, including on regulatory change such as RDR, cross border business, conflicts of interest, suitability and appropriateness obligations, inducements rules and mis-selling/s166 issues and financial promotions.
  • Several innovative new retail products and services, from rolling cash spread bets, exchange traded CFDs, pooled cash management arrangements and new personal pension products.  Covering design and structuring, drafting product terms, compliance with UK and overseas regulatory obligations and cross-border distribution and marketing.
  • The establishment of new “multilateral trading facilities” in the EU facilitating the auction and trading of electricity CFDs, credit derivatives and bonds.  Also advising on the potential launch of new exchanges and products.
  • Utility companies and commodities traders in relation to the impact on their activities of REMIT, EMIR and changes to MiFID and MAD, and whether their activities require authorisation under the UK/EU financial services regime.
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Memberships & Roles

  • TISA Client Assets Sub-Committee
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  • 1996 – LPC, Nottingham Law School, Nottingham
  • 1995 – LLB (First class hons), University of Manchester, Manchester   
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Fin­an­cial Mar­ket In­fra­struc­tures – a new era of re­spons­ib­il­ity for in­di­vidu­als
HMT has an­nounced that it in­tends to pro­ceed with its new Seni­or Man­agers & Cer­ti­fic­a­tion Re­gime (SM&CR) for fin­an­cial mar­ket in­fra­struc­tures (FMIs).  The new re­gime will be sim­il­ar to the SM&CR for...
The Whole­sale Mar­kets Re­view – no “big bang”
On 1 March 2022, HM Treas­ury pub­lished its re­sponse to its con­sulta­tion on the Whole­sale Mar­kets Re­view (WMR), which closed on 24 Septem­ber 2021. A re­l­at­ively large num­ber of or­gan­isa­tions from across...
New HM Treas­ury Con­sulta­tion Re­sponse: chan­ging the way fin­an­cial pro­mo­tions...
On 22 June 2021, HM Treas­ury (“HMT”) pub­lished its re­sponse (the “Con­sulta­tion Re­sponse”) to its earli­er con­sulta­tion (the “Con­sulta­tion”) in Ju­ly 2020, an­noun­cing changes to le­gis­la­tion and...
New SM&CR for FMIs pro­posed by HM Treas­ury
HM Treas­ury is pro­pos­ing to in­tro­duce a Seni­or Man­agers and Cer­ti­fic­a­tion Re­gime (“SM&CR”) for fin­an­cial mar­ket in­fra­struc­tures (“FMIs”) to en­cour­age ef­fect­ive gov­ernance, in­centiv­ise good be­ha­viour...
The Whole­sale Mar­kets Re­view – fine-tun­ing the Mi­FID II re­gime?
On 1 Ju­ly 2021, HM Treas­ury pub­lished a con­sulta­tion pa­per launch­ing its Whole­sale Mar­kets Re­view, which is pitched as an op­por­tun­ity to make the UK’s fin­an­cial ser­vices rule­book “nimble and fit for...
PRA pub­lishes draft rules and state­ment of en­force­ment policy for bank...
On 21 June 2021, the Pruden­tial Reg­u­la­tion Au­thor­ity (“PRA”) pub­lished a Con­sulta­tion Pa­per (CP12/21) de­tail­ing its pro­pos­als to ap­ply its ex­ist­ing rules for con­sol­id­ated pruden­tial re­quire­ments and...
A look of dis­ap­prov­al: the FCA’s new dis­cus­sion pa­per on fin­an­cial pro­mo­tions...
On 29 April 2021, the Fin­an­cial Con­duct Au­thor­ity (“FCA”) pub­lished a Dis­cus­sion Pa­per DP21/1 con­cern­ing the pro­posed strength­en­ing of the fin­an­cial pro­mo­tion rules for high-risk in­vest­ments and firms...
The FCA and PRA ask banks to re­view their ar­range­ments with de­pos­it ag­greg­at­ors
On 14 April 2021, the Fin­an­cial Con­duct Au­thor­ity (FCA) and Pruden­tial Reg­u­la­tion Au­thor­ity (PRA) sent a “Dear CEO Let­ter” to the chief ex­ec­ut­ive of­ficers of banks and build­ing so­ci­et­ies re­gard­ing...
The new pruden­tial re­gime for in­vest­ment firms: key points from the first...
In Decem­ber 2020, the Fin­an­cial Con­duct Au­thor­ity (FCA) pub­lished the first of three planned Con­sulta­tion Pa­pers (CP20/24) (link) on the new UK In­vest­ment Firm Pruden­tial Re­gime (“IF­PR”), which is...
ESMA ob­serves ques­tion­able re­verse so­li­cit­a­tion prac­tices after Brexit
The EU-UK Trade and Co­oper­a­tion Agree­ment and the end of the Brexit trans­ition­al peri­od on 31 Decem­ber 2020 has res­ul­ted in sig­ni­fic­ant changes to EU-UK trade in fin­an­cial ser­vices. In par­tic­u­lar, UK...
What does the  EU-UK Trade and Co­oper­a­tion Agree­ment mean for fin­an­cial...
Fol­low­ing the end of the Brexit Trans­ition Peri­od, we as­sess the im­pact of the EU-UK Trade and Co­oper­a­tion Agree­ment on the UK fin­an­cial ser­vices sec­tor and set out our ana­lys­is of the key points be­low...
The new pruden­tial re­gime for in­vest­ment firms: pruden­tial con­sol­id­a­tion...
In this art­icle, we look at the new pruden­tial con­sol­id­a­tion re­gime for in­vest­ment firm groups set to be in­tro­duced by the In­vest­ment Firms Reg­u­la­tion (“IFR”) and the In­vest­ment Firms Dir­ect­ive (“IFD”)...