Senior Government and Regulatory Affairs Advisor
Norton Rose Fulbright LLP
Related services and key industries
Anna Carrier is a lawyer in our financial services regulatory and government relations practice in our Brussels office. She advises clients on a range of European legislative, regulatory and policy matters and has experience in banking and financial services legislation, with particular focus on securities and derivatives markets, benchmarks, asset management and crypto-assets. Her clients include major international financial market infrastructure operators, benchmark administrators, investment firms, banks, asset managers and hedge funds, as well as energy and technology companies, digital platforms, international financial institutions and industry associations.
Anna assists clients in all stages of legislative process, from preparatory work preceding publication of legislative proposal, legislative review of basic legislative text, development of secondary legislation and guidance, through to implementation. She has advised clients on complex matters relating to implementation of European Market Infrastructure Regulation (EMIR), Markets in Financial Instruments Directive and Regulation (MiFID II / MiFIR), European Benchmarks Regulation (BMR), Capital Requirements Directive and Regulation (CRD IV / CRR) and other. Recently she also advises clients on the application of new European legislation on markets in crypto-assets (MiCA) and digital operational resilience for financial sector (DORA).
Anna also helps clients manage submissions to European institutions, national public authorities and international standard-setting bodies. She is a regular and frequent contributor to our Regulation Tomorrow blog, where she reports on European financial services legislative, regulatory and policy developments.
- Anna joined us from a major derivatives marketplace where she was responsible for EU regulatory strategy, government relations and engagement with major trade associations representing banking, asset management, hedge funds, proprietary traders and commodities houses.
Professional experienceExpand all Collapse all
- EU-based operator of an FX trading venue – advising on regulatory status of the trading venues activities in the UK following Brexit and options on subsequent trading arrangements.
- Investment firm operating a trading venue – assisting with an application for authorisation to the Financial Conduct Authority to operate a multilateral trading facility in the UK.
- UK-based investment firm - on regulatory status of their arrangements for accessing trading venues based in the EU and provision of services to their clients, in particular in the light of the MiFID II provisions on direct electronic access.
- A major international agricultural products producer and merchandiser - on assessing their compliance with requirements of MiFID II, and in particular assessment of their eligibility to avail of the ancillary activity exemption and development of proposed hedging policy.
- A major international financial institution - on the application of select European securities and banking legislation, including MiFID II and MiFIR, and coordinated submissions to the European Commission regarding possible amendments to the legislation.
- A leading US brokerage and trading services provider - on the implementation of MiFID II requirements pertaining to payment for research in the UK and in France, and arranged for the client to provide direct technical submissions and present to senior regulators in the Financial Conduct Authority and French Financial Markets Authority (Autorité des Marchés Financiers).
- The operator of a major international derivatives and securities market operator - on the application of General Agreement on Trade and Services (GATS) to agreements governing licensing of market data following expected UK departure from the EU.
- A major international financial institution – led a project focused on development of internal compliance standards for the client's trading department.
- A third-country financial benchmark administrator - in preparation of their application to the UK Financial Conduct Authority for recognition in accordance with the provisions of EU Benchmarks Regulation, including documentation review and drafting.
- A UK-based indices and benchmark provider - to prepare an application to the Financial Conduct Authority for authorization as benchmark administrator, including in-depth documentation review and proposing amendments to the organization's governance structure and documentation outlining systems, arrangements and procedures relevant for benchmark administration business.
- A leading technology and precious metals merchandiser - on regulatory compliance obligations applicable to the company in its role as contributor to price assessments processes, which included development of the required documentation on internal systems and processes.
- Commodity benchmark administrator – conducting audit review for the purpose of verifying the administrator's compliance with the IOSCO principles for oil price reporting agencies.
- A data and technology company – advising on the application of EU Benchmarks Regulation to its select products, their status as regulated indices and benchmarks, and the corresponding compliance requirements.
- Capital markets division of a major international bank – advising on the applicability of the EU Benchmark Regulation's definition of a contributor to the bank's market making activities at a regulated trading platform.
- Drafted policies and benchmark-setting procedures in compliance with IOSCO principles for financial benchmarks for a newly established commodities benchmark administrator.
- A major international financial institution - in assessing its regulatory compliance requirements in respect of EU Benchmarks Regulation, including advice on exemptions available to benchmarks provided by central banks.
- An authorized benchmark administrator on the application of environmental, social and governance (ESG) disclosure requirements stemming from the amended EU Benchmarks Regulation, helped to review and update the relevant documentation.
Fintech and crypto-assets
- A major international operator of a trading platform for crypto-assets - conducting pan-EU jurisdictional survey to assess regulatory status of the company's services provided in the Member States and identify any licence or registration requirements stemming from local law.
- Provided training sessions for major international financial institutions on the development of new European legislative framework for markets in crypto-assets.
- A non-EEA operator of trading platform in crypto-assets and a provider of custody services – advising on the registration requirements in EU-27 jurisdictions stemming from national transposition of the 5th EU Anti-Money Laundering Directive (5MLD).
- A European issuer of crypto-assets – advising on the application of UK payments regulations to a blockchain-based crypto-asset developed by the client.
- An operator of an EU-based trading platform for crypto-assets – advising on requirements concerning marketing and promotion of crypto-assets in the UK and regulatory status of the platform's activities in the UK.
- A coalition of regional industry associations representing blockchain industry and crypto-asset service providers – advised on the development of the FATF recommendations applicable to virtual asset service providers, including drafting of their joint submission to the FATF consultation on the draft interpretative note to FATF Recommendation 15 on New Technologies.
Commodities / Energy
- A major international oil and gas producer – on the application of the revised MiFID II test for ancillary activity exemption in the EU and in the UK.
- Belgium-based subsidiary of a major international oil and gas producer - on the transposition of MiFID II into Belgian law and in particular, procedure and required documentation for ancillary activity notification provided therein.
- Reviewed and advised the commodities financing arm of a large global bank on proposed requirements - to report physical commodity borrowing and lending transactions to authorised trade repositories.
- A brokerage business of a major international bank - on their post-Brexit trading arrangements in physical energy and energy derivative products, including compliance with the relevant regulatory reporting obligations.
- Co-authored a report for an industry association grouping energy exchanges on the application of European financial services legislation to physical gas and electricity trading.
- A major international integrated oil and gas company – advising on the application of inside information restrictions and reporting requirements as set out in European wholesale energy market integrity and transparency (REMIT).
- Designed bespoke and comprehensive information, monitoring and reporting services for a number of financial institution clients, and covering select European and UK legislative, regulatory and policy issues.
- Led lobbying on the controversial Risk Reductions Measures package for the London-based industry association representing the precious metals markets and London-based clearing banks and successfully secured a clause obliging the European Commission and EBA to review the proposed liquidity requirements for precious metals.
- Assisted a major international e-commerce operator with a design and execution of an advocacy and lobbying campaign focused on legislative review of the proposed Digital Markets Act and Digital Services Act.
- Assisted an industry group representing derivatives counterparties in developing a policy submission to EU policy makers and legislators supporting expanded regulatory forbearance powers for the European Commission and the European supervisory authorities.
- Worked with an industry group representing major European utilities and other wholesale energy market participants to devise and successfully promote a position on prudential requirements for commodities dealers in the European Commission's review of Singe Rulebook requirements for investment firms.
- Coordinated engagement campaign of a major international information technology company vis-à-vis European Commission and ESMA and focused on promoting transitional arrangements in Prospectus Regulation in the event of no-deal Brexit.
- Supported one of the global leading asset management and investment firms in managing their EU and UK horizon scanning and advocacy engagement efforts.
- Developed a comprehensive information, monitoring, reporting and analysis support service for a major international public financial institution.
- Led advocacy and lobbying activities for a group of large commodity market participants on new insider information rules for commodity derivatives and emissions allowances under the EU's revised market abuse (MAR/CSMAD) regime.
Financial Services Regulatory Developments in ESG
Publication | May 16, 2023
AI and the UK regulatory framework
Blog | May 15, 2023
AI and the UK regulatory framework
Blog | May 15, 2023