Contact details

Richard Small

T: +44 20 7809 2424 M: +44 7525 896 736 Email Richard | Vcard Office: London


Financial services

Financial services

Richard Small Partner

Contact details

Richard Small

Richard Small

T: +44 20 7809 2424 M: +44 7525 896 736 Email Richard | Vcard Office: London

Richard is a partner in the London office specialising in financial services regulation. He assists UK and international clients across a variety of industry sectors on financial regulatory matters. Richard has particular experience in helping clients in their interaction with regulatory authorities.
  • Profile
  • Services
  • Sectors

Richard's experience includes assisting banks, asset managers and other financial institutions in connection with various conduct of business and other issues arising out of the FCA Handbook and advising clients on the international, EU and UK sanctions regimes. He has recently represented a financial institution in a contested FCA enforcement action in relation to alleged market abuse, systems and controls and short selling failings in connection with a number of natural resource issuers.

Richard has published articles in both legal and industry-related periodicals and has been quoted in the press on financial regulatory developments. He regularly participates in a number of industry committees including the Regulatory Committee of the City of London Law Society and various working groups of the Bank of England's Financial Markets Law Committee.

  • Regulatory compliance
  • Sanctions
  • Regulatory litigation
  • Banking and financial services regulation

FCA perimeter advice, authorisations and permissions

General FCA perimeter advice. Assisting clients with new authorisations and variations of permission and provides related advice including reviewing internal systems and controls.

Conduct of business

Advising on conduct of business issues arising out of the FCA Handbook, including the FCA’s rules on best execution, use of dealing commissions and conflicts of interest. 

Commodities regulation 

Advising a Category 4 LME member on the ability of appointed representatives to enter into LME contracts.  Representing an African oil company in a dispute in relation to the raising of finance for participation in Kenya's Open Tender System for the supply of petrol.  Representing a market maker in relation to an FCA investigation into alleged market abuse failings in connection with a number of natural resource issuers.  

Corporate support

Frequently advises on the regulatory aspects of M&A and corporate finance transactions, including in connection with FCA change in control notifications, the financial promotions regime and disclosure under the Disclosure and Transparency Rules.

More: Regulatory compliance

UK insurance broker

Advising on potential breaches of the Iranian sanctions regime in connection with insurance intermediation.  Related advice on systems and controls failures under the Money Laundering Regulations and the FCA Handbook.

Japanese oil & gas company

Advising on the impact of the imposition of international sanctions on Iran on the ongoing participation in an oil and gas project in Iran.

UK corporate finance house

Advising on the implication of the EU sanctions regime on Russia on a UK corporate finance house acting on behalf of an entity engaging in the sale of a material asset to a Russian SDN.

Dual-use technology

Advising a UK corporate finance house on the scope of the dual-use sanctions on Russia in connection with arranging transaction financing.

More: Sanctions

Market abuse and systems and controls failures 

Acting for a market maker in an FCA investigation in relation to allegations of breaches of the market abuse regime and related systems and controls failings.

Foreign exchange investigation

Assisting on the UK and cross-border aspects of a US led regulatory investigation and private action in connection with alleged abuses of the spot FX markets.

Disclosure requirements 

Representing a UK listed Chinese entity in connection with regulatory scrutiny relating to various potential breaches of the Disclosure and Transparency Rules.

More: Regulatory litigation

European/UK regulatory developments

Advising clients on the impact of Brexit as well as new and forthcoming financial regulation, including MAR/MiFID II/MiFIR.  Updating legacy client documentation to reflect new regulatory requirements.

Custody/client money

Advising clients on complex custody and client money matters, including in connection with the clearing and settlement of derivatives contracts. Advised a leading asset manager on custody and client money issues arising out of the bulk transfer of ISAs and savings accounts. 


Obtained cross-jurisdictional approval for various leading US asset managers to market their funds across Europe under the AIFMD including, where necessary, the appointment of depositary-lites.

More: Banking and financial services regulation

  • Art and cultural property

Private bank

Assisted in relation to the taking security over a piece of art work for the future production of works of art.

Auction house

Assisted on various private wealth matters in relation to the extension of credit to HNWIs for the purchase of art work.

More: ​Art and cultural property


Financial services

Financial services

Latest news & insights

21 Dec 2016

From News

Stephenson Harwood advises Vistra on its acquisition of Jordans

Law firm Stephenson Harwood LLP has advised Vistra on its acquisition of the Jordans Group from its current shareholder, The West of England Trust Limited.


12 Jul 2016

From Insights

BREXIT: The MiFID passport

A significant part of the UK's financial services industry relies on the passport under the MiFID to provide its services in other Member States of the EEA. The loss o..


05 Jul 2016

From Insights

BREXIT: The AIFMD passport

The AIFMD creates a single pan-EEA regulatory framework for the managers of alternative investment funds. This overview considers the potential availability of the pan..


24 Jun 2016

From Insights

BREXIT: What now?

The results of the referendum on whether or not the UK should remain in the European Union are in and the British public have voted to leave. What does this mean?


09 Jun 2016

From Insights

A bird's eye view

Richard Small and Katherine Dillon provide an overview of the principal changes arising from the new MAR regime. This briefing covers the core elements of the current ..


10 Feb 2016

From Insights

Custody and client money watch - Issue 1

In this issue we look at what you should be doing now about the Securities Financing Transactions Regulation, the current rules on title transfer collateral arrangemen..


05 Jan 2016

From Insights

Spotlight on regulatory compliance

Financial regulation is constantly evolving with ever more byzantine, copious and intrusive rules, whose reach is ever-widening. Richard Small highlights where early-s..


18 Dec 2015

From Insights

FCA Hot Topic: Suitability of investment portfolios

In its December Regulation round-up, published yesterday, the FCA set the suitability of investment portfolios as a hot topic.


04 May 2015

From Insights

Media coverage: Compliance Monitor - CASS The grand finale

Richard Small writes for Compliance Monitor on the Financial Conduct Authority's overhaul of its client asset regime.


02 Dec 2014

From News

Stephenson Harwood appoints new regulatory partner

Stephenson Harwood LLP has appointed Richard Small as partner in its corporate practice group and London office.


© Stephenson Harwood LLP 2016. Any reference to Stephenson Harwood in this document means Stephenson Harwood LLP and/or its affiliated undertakings. Any reference to a partner is used to refer to a member of Stephenson Harwood LLP.