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Portrait ofCassandra Heugh

Cassandra Heugh

Of Counsel

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London
EC4N 6AF
United Kingdom
Languages English

Cassandra Heugh is of counsel in the Finance Team at CMS London. Cassandra has a regulatory and product background increasingly focusing on supporting regulated outsourcing and commercial transactions. She has worked in-house on secondment, including Pension Insurance Corporation supporting their commercial contracting. As well as understanding retail products, she therefore also has hands on experience of the issues facing regulated firms in practice. 

Cassandra also regularly advises financial service providers and institutional investors on topics including authorisation, compliance and regulatory change, corporate governance and product design and distribution.

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Education

  • 2010 - LL.M. – University College London, London.
  • 2009 - LL.B. – University College London, London.
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Expertise

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25/11/2024
Pre-hedging: IOSCO publishes delayed Consultation Report
On 21 November 2024, the International Organization of Securities Commissions (“IOSCO”) published a consultation paper in response to concerns about the appropriateness of pre-hedging practices raised...
14/08/2024
PRA consults on updates to its approach to International Banks
On 30 July 2024, the Prudential Regulation Authority (“PRA”) published a consultation paper (CP11/24) (“CP”) on proposed updates to its supervisory statement on international banks and its approach...
13/08/2024
PRA consults on updates to its approach to International Banks
On 30 July 2024, the Prudential Regulation Authority (“PRA”) published a consultation paper (CP11/24) (“CP”) on proposed updates to its supervisory statement on international banks and its approach...
10/06/2024
ESMA issues first formal guidance on use of AI in retail financial services
The European Securities and Markets Authority (ESMA) recently released a public statement on the use of artificial intelligence (AI) in the provision of retail investment services. The statement provides...
07/06/2024
ESMA issues first formal guidance on use of AI in retail financial services
The European Securities and Markets Authority (ESMA) recently released a public statement on the use of artificial intelligence (AI) in the provision of retail investment services. The statement provides...
06/06/2024
Market outages: IOSCO good practices and key findings from global survey
On 5 June 2024, the International Organization of Securities Commissions (IOSCO) published its Final Report on Market Outages, setting out good practices for trading venues and market participants in...
06/06/2024
Market outages: IOSCO good practices and key findings from global survey
On 5 June 2024, the International Organization of Securities Commissions (IOSCO) published its Final Report on Market Outages, setting out good practices for trading venues and market participants in...
06/06/2024
Consumer Duty Toolkit – Annual Board reports
The FCA has made clear that the Consumer Duty should be a top priority for Boards. Boards must review and approve an annual assessment of whether the firm is delivering good outcomes for their customers by 31 July 2024. Firms should be able to demonstrate how their business model, the actions they have taken, and their culture embed the objectives of the Consumer Duty.  The annual assessment should include:   Before signing off the assessment, the Board should agree the action required to address poor outcomes, any identified risks and agree on any necessary changes to the firm’s business strategy. The assessment will be part of the evidence the FCA uses to assess a firm’s compliance with the Consumer Duty. The FCA may ask to see the annual assessment and Board attestation, including the supporting data and related Board minutes. These materials should be sufficiently robust and evidence a developmental mindset – showing how the firm is focussed on customer outcomes, gaps they have identified and necessary actions to improve products and services. There is no set format to the assessment. Different treatments will be required depending on the complexity of the business, its products and services, its customers and role in the distribution chain. Each firm will be best placed to determine how to present information. Firms will need to consider:Before the Board approves the assessment, it should:For more information and guidance on preparing the annual assessment, click the link below.
05/06/2024
2024 UK EMIR Refit: finalisation of Q&A-style guidance
On 30 September 2024, significant changes to the UK’s derivatives reporting framework will come into effect known as the “2024 UK EMIR refit”. Counterparties are in the process of finalising im­ple­ment­a­tion...
05/06/2024
2024 UK EMIR Refit: finalisation of Q&A-style guidance
On 30 September 2024, significant changes to the UK’s derivatives reporting framework will come into effect known as the “2024 UK EMIR refit”. Counterparties are in the process of finalising im­ple­ment­a­tion...
31/05/2024
Ancillary Activities Exemption – a change in approach for commodity derivatives...
On 29 May 2024, the Financial Services and Markets Act 2000 (Commodity Derivatives and Emission Allowances) (Amendment) Order 2024 (SI 2024/719) (the “2024 Order”) was published alongside an explanatory...
31/05/2024
Ancillary Activities Exemption – a change in approach for commodity derivatives...
On 29 May 2024, the Financial Services and Markets Act 2000 (Commodity Derivatives and Emission Allowances) (Amendment) Order 2024 (SI 2024/719) (the “2024 Order”) was published alongside an explanatory...