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 practices in our Brussels office.
Anna advises clients on a range of European legislative, regulatory and policy matters and has experience of advising on banking and financial services legislation, with particular focus on securities and derivatives markets, benchmarks, prudential regulation, asset management and Fintech. Her clients include major international financial market infrastructure operators, benchmark administrators, investment firms, asset managers, as well as energy and technology companies, 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). Recently she also advises clients on the development of new European legislative regime for markets in crypto-assets and digital operational resilience for financial services.
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
- 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 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 documenation 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.
- 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.
- A major international operator of a trading platform - in crypto-assets to conduct 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-currencies and a provider of custody services - on the registration requirements in EU-27 jurisdictions stemming from national transposition of the 5th EU Anti-Money Laundering Directive (5MLD).
Commodities / Energy
- 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.
- 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 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.
Financial Crime Outlook: 2023 and beyond
Publication | March 16, 2023
Split the difference: Markets in EU and UK: Cryptoassets
Blog | March 15, 2023
Split the difference: Markets in EU and UK – Cryptoassets
Podcast | March 13, 2023