Contact details

Richard Small

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


Financial services

Financial services

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 and the head of the non-contentious financial services regulatory practice in the London office. He assists UK and international clients to navigate the regulatory regime and in their interaction with regulatory authorities.
  • Profile
  • Services
  • Sectors

Richard's experience includes advising clients in connection with the regulatory perimeter, the market abuse regime and conduct of business issues arising out of the FCA Handbook. His clients include financial institutions, private wealth managers and corporates across a variety of sectors. Richard has particular experience advising on commodities regulation and the international, EU and UK sanctions regimes.

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.

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

MiFID II position limits

Advising a number of non-EEA based corporates on the MiFID II commodity derivative position limits regime.  Assisting clients to apply to the FCA for an exemption from the regime.

Market Abuse

Representing a market maker in relation to an FCA investigation into alleged market abuse failings in connection with a number of natural resource issuers.

FCA authorisations and permissions

Assisting a new oil market trader to obtain FCA authorization as a commodities broker.  Advising a financial institution in relation to a variation of permission in connection with commodities trading.

International sanctions

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

More: Commodities

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.

Commodities regulation

Advising a Category 4 LME member on the ability of appointed representatives to enter into LME contracts. Advising corporates on ISDA protocols in connection with commodities hedging. 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.

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.

Market abuse

Advising in relation to the new market abuse in the context of corporate transactions. Assisting clients to review their systems and controls for compliance with the Market Abuse Regulation. 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 in connection with a number of natural resource issuers.

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.

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

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 perimeter advice on the scope of the CASS rules and drafting custody and escrow agreements. Advised a leading asset manager on custody and client money issues arising out of the bulk transfer of ISAs and savings accounts.

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.

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.

More: Banking and financial services regulation

  • Art and cultural property
  • Private wealth
  • Funds and financial services

Consumer credit authorisation

Advising a leading auction house on the regulatory perimeter in relation to the provision of consumer credit and the authorisation process for obtaining permission to provide consumer credit.

Private bank

Assisted in relation to 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

Collective investment schemes

Advising a leading UK private wealth manager on the establishment, operation and winding up of a number of collective investment schemes in the context of its SIPP business.

Regulated mortgage contracts

Assisting a number of Swiss, Singapore and UK based private banks in relation to the consumer credit and regulated mortgage contracts regime.

Cross-border distribution of financial products to HNWIs

Advising a number of private banks and asset managers on the distribution of funds and other financial products on a cross-border basis to HNWIs located in the UK.

Family offices and ultra-HNWIs

Advising family offices, ultra-HNWIs and their financial advisors on a variety of regulatory issues arising out of the structuring of their investments.

More: Private wealth

Investment trust ISA and Savings Schemes Transfer

Advising a leading asset manager on the regulatory issues in connection with the transfer out of investment trust ISAs and savings schemes.


Advice on the AIFMD including in relation to reporting, disclosures and the marketing of funds. 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.

Investment funds

Advising clients on various applicable FCA rules including in relation to custody and client money, market abuse and conflicts of interest. Regulatory advice on fund related agreements and documentation including Discretionary Investment Management Agreements and ISA terms and conditions.

More: Funds and financial services


Financial services

Financial services

Financial services

Financial services

Latest news & insights

29 Aug 2017

From Insights

Senior Managers Regime

Final rules for the extension of the Senior Managers & Certification Regime (SMCR) to the asset management industry together with other regulated sectors not already s..


21 Apr 2017

From Insights

FCA hot topic: Money laundering

On 18 April, the Financial Conduct Authority published its 2017/2018 Business Plan. The FCA makes it clear that it may start prosecuting firms or individuals for serio..


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.