Conflicts of interest and fair customer treatment in private markets

For compliance teams, the message is that conflicts cannot be treated as a static policy exercise: they arise across deal sourcing, allocations, fee structures, valuation, co-investment and investor communications. Firms should expect scrutiny of governance, independent challenge, disclosure quality and evidence that customer and investor outcomes are fair. Actionable steps include refreshing conflict inventories, testing whether disclosures are specific and understandable, reviewing allocation and valuation decisions, strengthening board and committee oversight, and documenting remediation.

Private-market growth makes this a board-level issue, not just a compliance one. Firms with robust frameworks can use transparency as a competitive advantage; weak controls risk remediation costs, reputational damage and regulatory action. No new rules are announced, but supervisory expectations are clear: identify, manage, mitigate and disclose conflicts consistently, with fair treatment embedded in product design and ongoing oversight.

Compliance teams should prioritise gap assessments and targeted monitoring.