Briefed In March 2026 | Baker McKenzie Briefed In March 2026

March 2026

Briefed

Legal insights from Baker McKenzie to power your business globally

Explore the evolution of the private wealth sector, how AI and advanced analytics are sharpening global tax audits – and meet the next generation of legal leaders.

Seeking out the competitive edge for private banking

Banks have an opportunity to scale growth with private wealth clients, but only if they get the formula right.

The private wealth sector continues to evolve rapidly, shaped by global trends that are redefining its landscape and growth potential. Traditional centers, such as Switzerland, are increasingly challenged by the rise of Asian markets like India, Singapore, Japan and Mainland China. This globalization is accompanied by ongoing consolidation and strategic acquisitions among wealth management firms, as businesses seek to scale their offerings and enhance client services. At the same time, innovation in financial products is expanding client access, with the introduction of digital assets such as cryptocurrencies and more flexible investment vehicles like interval funds, providing entry to private equity and credit markets. These developments underscore a dynamic industry focused on broadening access, diversifying portfolios and capitalizing on emerging growth regions.

In the US, the election of President Trump has ushered in a deregulatory wave. While this promises to reduce compliance costs and offer greater operational flexibility, it also introduces uncertainty. The sector must now navigate a fragmented regulatory environment, balancing relaxed fiduciary standards with heightened scrutiny in areas like cybersecurity; environmental, social and governance disclosures; and AI governance.

Additionally, increasingly complex cross-border wealth management requires banks to skilfully navigate a web of regulations, including tax compliance (e.g., the Foreign Account Tax Compliance Act and the Common Reporting Standard), financial reporting, anti-money laundering rules and inheritance laws. These obligations overlap with fiduciary duty, as failure to comply could not only result in legal penalties, but also breach the trust placed in advisers. Private banks and wealth managers must also step up efforts to help clients manage compliance risks across multiple domains.

Regulatory dynamism adds to momentum

With increased scrutiny of offshore tax evasion and aggressive tax shelters, banks must ensure that their international tax planning is robust and transparent, notes Glenn Fox, a partner based in New York. These practices demonstrate that banks are responsible fiduciaries and emphasize cross-border compliance, which strengthens their business as opaque practices can undermine client trust and attract regulatory action.

Trust and transparency remain key tenets of wealth management

“Geopolitics, tariffs and trade shifts are shaping the private wealth market. Banks will need the right mix of risk and legal expertise to successfully help their clients diversify investments internationally.”

Ansgar Schott, Partner, Zurich

Private wealth clients see safety and security as a minimum requirement. Banks should remain vigilant about the risks of inadequate controls or breaches — whether internal or via third-party vendors, including those of the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) and similar laws. Robust data protection measures are not only a regulatory requirement but also integral to maintaining fiduciary standards and managing complex cross-border relationships. “Banks can differentiate themselves in a competitive market, attracting high-net-worth clients who value security and global expertise,” notes Phyllis Townsend, a partner based in London. Comprehensive wealth management solutions need to be backed by leading risk management capabilities and the ability to diversify client investments with ease, across borders and through overlapping regulatory landscapes.”

“Investment in advanced compliance technology — such as automated tax reporting, real-time regulatory monitoring and cybersecurity platforms — positions banks as leaders in risk management and operational resilience.”

Vin Bange, Partner, London

Five targets for banks

Transparency, security, privacy and compliance are no longer unique selling propositions but hygiene factors in decision-making. The tipping point may well be banks that move quickly to integrate legal, tax and regulatory expertise as part of their wealth management solutions, tailoring their offerings to varying portfolio diversification and jurisdictional preferences and risk appetites.

Read more What’s on the radar for financial institutions?

Staying ahead of global tax audits

Multinational enterprises (MNEs) must prepare for a tax environment that is more data- and AI-driven and enforcement-focused than ever before.

Multinational enterprises (MNEs) must prepare for a tax environment that is more data- and AI-driven and enforcement-focused than ever before. To future-proof their organizations, business leaders must proactively respond to the risks posed by a convergence of digital enforcement tools, heightened transfer pricing scrutiny and the rollout of global minimum tax rules. In this climate, resilience and growth will hinge on how effectively organizations manage compliance, optimize tax positions and mitigate risk within rapidly evolving regulatory landscapes.

Around the world, tax authorities are accelerating their adoption of AI and advanced analytics to sharpen audit precision. According to Allen Tan, chair of Baker McKenzie’s Asia Pacific Tax Practice Group, authorities are increasingly leveraging predictive models to identify medium- to high-risk taxpayers, as this can deliver far greater recoveries than traditional audit selection methods. These algorithms can prioritize areas such as transfer pricing and intangible assets, which are critical to the technology and pharmaceutical sectors. At the same time, governments are strengthening cross-border cooperation by expanding exchange-of-information frameworks and joint audit programs, signaling a decisive shift toward multilateral enforcement and coordination.

AI powers audit precision

Transfer pricing intensifies scrutiny

“Transfer pricing is not just about benchmarking. Authorities want the full narrative — where decisions occur, how value is generated, where functional activities occur through an evaluation of the conduct of parties, and whether the numbers and contractual terms reflect economic reality.”

Allen Tan, Baker McKenzie’s Asia Pacific Tax Practice Group Chair, Singapore

This scrutiny increasingly intersects with trade and customs. As MNEs seek to manage their supply chain strategies to counter tariff disruptions, tax authorities are closely monitoring intercompany pricing. In response, many companies are turning to advance pricing arrangements (APAs) to secure certainty and avoid costly, prolonged disputes. Bilateral and multilateral APAs are gaining traction as strategic tools to mitigate double taxation and reduce compliance risks. Similarly, the mutual agreement procedure remains a vital treaty-based mechanism for resolving cross-border disputes.

Globally, transfer pricing remains a core focus of tax audits. For example, authorities are intensifying their reviews of intragroup services and royalty arrangements, requiring justification for selecting transfer pricing methodologies and comparables, detailed documentation, and clear evidence of value creation. In the US and elsewhere, officials are increasingly deploying anti-abuse and economic substance arguments in transfer pricing cases.

“In certain cases, adjustments are being made using current data that the taxpayer could not have predicted.”

María Antonia Azpeitia, Partner, Madrid

The OECD’s Pillar Two global minimum tax is transforming compliance obligations worldwide. The US and the OECD recently brokered a significant “side-by-side” agreement that could streamline these obligations. However, numerous jurisdictions are implementing Qualified Domestic Minimum Top-Up Tax regimes that will still demand significant resources and attention. Businesses must now navigate Global Anti-Base Erosion reporting, safe harbor elections and top-up tax calculations across multiple jurisdictions. Tan emphasizes that Pillar Two is not just another reform — it’s a compliance revolution. Companies need to rethink their internal systems and data architecture, governance, and the impact of organizational changes.

Preparing for Pillar Two and beyond

Tax enforcement is entering a new era of precision and aggression. Businesses that cling to outdated, reactive approaches are courting disaster. As enforcement becomes more sophisticated, coordinated and relentless, tax strategy can no longer operate in isolation — it must align seamlessly with operational realities to avoid exposing the business to high-impact risk. The path forward is clear: Focus on pre-audit readiness and invest in real-time data integrity and tight collaboration across tax, legal and finance, while pursuing certainty where appropriate, especially for high-risk areas like IP, financing and restructuring.

Strategic alignment: Delay is not an option

Partner spotlight:

We sat down with a few of Baker McKenzie’s recently promoted partners to reflect on their pathway to partner and how they are supporting their clients in overcoming their business challenges.

"In 2015, I took a leap from Australia to Tokyo, joining Baker McKenzie as a foreign associate. What started as an exciting challenge quickly became a journey of growth and connection. Working in the M&A team, I’ve had the privilege of advising on transactions that span the globe — from here in Japan to Europe, the US, Vietnam and back home in Australia. Along the way, I’ve visited offices across the globe — Melbourne, Sydney, Singapore, New York, Chicago, Houston, London and Hong Kong — each trip deepening my appreciation for the Firm’s collaborative spirit and global reach. Regional training sessions and countless conversations with colleagues have shaped not only my career but also created lifelong friendships.

Can you tell us about your Baker McKenzie journey?

What has been your most memorable moment during your time as partner so far?

Financial institutions in a digital and regulatory reset

“International payments entities are looking to modernize cross-border transactions using blockchain, including stablecoins and tokenized deposits to facilitate transactions.”

Karen Man, Partner, Hong Kong

In 2026, financial institutions face a rapidly evolving digital landscape influenced by technological advances, shifting regulations and changing priorities in responsible business practices. Success in 2026 depends on integrating innovation with adaptive governance within flexible regulatory frameworks. Here are some of the key things to look out for:

Deregulation efforts, led by the US and mirrored globally, aim to stimulate economic growth, but they also bring complexity, such as new stablecoin regulations and stringent cybersecurity incident reporting. Supervisory stress tests on nonbanks highlight concerns over systemic risks, potentially leading to increased oversight of private capital.

The rise of agentic AI introduces autonomous functionalities with promising applications in areas such as wealth management, driving strategic AI-focused M&A as firms seek competitive advantages. However, AI also presents cybersecurity challenges, necessitating robust outsourcing and regulatory frameworks. “To thrive in wealth management’s evolving landscape, banks and wealth managers must embrace technology, invest in compliance infrastructure and develop agile strategies.” Ansgar Schott, Partner, Zurich

Private equity and direct lending gain prominence — for example, their growth in European markets — while affording greater access to noninstitutional investors. Yet, high debt levels and credit delinquencies prompt regulatory scrutiny to mitigate systemic risks.

Private capital’s growing role

Sustainable finance remains vital, especially in data center development, with anticipated global standards emerging. Financial crime prevention and accountability gain emphasis, alongside shifting workforce diversity strategies varying by region.

Sustainability and responsibility refocused

A pivotal stage of AI adoption

Regulatory landscape shifts

“Authorities are scrutinizing private capital to boost transparency, including the use of stress testing. This opens the possibility of heightened regulation and more disclosure.”

Carlo de Vito Piscicelli, Partner, Milan*

Guidelines for AI: The in-house counsel checklist

“What’s going to differentiate them is whether they have the best lawyers who can use that technology, and whether they have data that is unique to them that models can’t access unless they are given access.”

Ben Allgrove, Partner and Chief Innovation Officer

“What we are seeing now is AI as a general-purpose technology which cuts across everything that lawyers and their clients do. The challenge isn’t finding the opportunity — it’s seizing it in a way that delivers real ROI, while mitigating the quality and other risks that exist.”

Ben Allgrove, Partner and Chief Innovation Officer

AI is no longer theoretical for the legal industry — it is transforming how legal services are and will be delivered. Best practices for implementation are still emerging. Large law firms are adopting AI at nearly twice the rate of smaller firms, creating a shift in the economics of delivering legal services. Against a backdrop of market volatility and economic pressures, in-house teams are assessing whether their legal providers’ investments in and deployment of AI are delivering maximum value, as well as how their providers are viewing their future AI strategy.

Ask how AI is being integrated into workflows such as contract review, litigation strategy and compliance monitoring. Discover which tools are being used or considered. Include AI capability questions in panel reviews and pitches — not to drive AI for AI’s sake but to prompt conversations about service delivery.

The AI deployment checklist for in-house counsel is as follows:

The state of AI adoption

1 Find out what AI is being used

Firms should be able to demonstrate how AI improves quality, efficiency, accuracy and risk management and not get distracted by the hype. Many firms have deployed numerous AI tools, but the real differentiator is how they are used — how technology, talent, information and data combine to deliver a better service.

2 Focus on outcomes, not hype

The technology landscape is currently very fluid. Are the bets that your firm is making likely to survive a market shakeout?

3 Assess scalability and change management

Set KPIs with your firms for turnaround time, cost-savings and increased matter capacity. This will be key in ensuring that the business case for deploying AI plays out. The winners will be those who use the technology to increase the volume and value of the work delivered and not just reduce costs.

4 Define the return on investment

“If you have a knowledge base because you’ve done a certain type of deal more than anyone else, or you’ve operated in a region that no one else operates in for longer, and you have proprietary or unique data, then that combined with the right legal talent and using the right tools is a winning combination.”

Ben Allgrove, Partner and Chief Innovation Officer

The success of any AI deployment depends on the quality and integrity of the data to which the AI is applied. Ask how your legal provider governs data and leverages its institutional knowledge to deliver value. It’s also important to understand how your firm uses its institutional knowledge base to differentiate itself while ensuring that privileged and confidential information remains protected.

5 Prioritize data strategy

Ask if your legal provider is buying the technology or building it. While building technology in-house might seem like a more “bespoke” offering, buying the best-in-class technology can often be the better choice.

6 Buy, don’t build

Ask your legal provider about its AI training programs and talent strategy. Future lawyers will be AI natives. Firms that are forward-leaning will focus on hiring and developing multiskilled individuals who can bridge the gap between law and technology.

7 Focus on training and talent

AI is redefining the way that legal services are and will be delivered. By setting clear expectations, monitoring performance and asking the right questions, it can be a strategic enabler to better relationships with your strategic partners.

Want to learn more about how we are using innovation to maximize value for our clients?

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Learn more

Read our 2025 and 2026 partner promotion announcements

Awareness

89%

of lawyers are aware of generative AI tools

use them for legal-specific work

Use

28%

are considering to use AI tools

Planning

50%

Source: Thomson Reuters 2025 Generative AI in Professional Services

While awareness is high and growing, successful use lags.

Partner and Chief Innovation Officer, London

Ben Allgrove

 Partner, Zurich

Ansgar  Schott

Partner, New York

Glenn Fox

Partner, London

Phyllis Townsend

Partner, London 

Vin Bange

Principal, Singapore 

Allen Tan

Partner, Madrid

María Antonia Azpeitia

Partner, Washington, DC 

George M. Clarke

"My Baker McKenzie journey began in 2016 when I joined as an associate in our Tax Practice Group, bringing transfer pricing experience from a Big Four firm. I was drawn to the Firm’s interdisciplinary collaboration and truly international character, which matched my passion for working with people across borders. What defined my path was building deep expertise in complex transfer pricing cases, with a particular focus on controversy, advanced pricing agreements (APAs) and mutual agreement procedures (MAPs), while working in integrated international teams across Europe and the US. A six-month client secondment was transformative, teaching me to even better understand client needs from their perspective and deliver solutions that work in practice.

"I joined Baker McKenzie as a junior lawyer straight out of law school after being a part of the Firm’s summer associate program, and I am still here almost a decade later. Interestingly, Baker McKenzie had shaped my career even before my employment officially started. Before summering at Baker McKenzie, I was convinced that I wanted to be an M&A lawyer; turned out, it’s because I didn’t know that one can have a regulatory compliance and investigations practice! It’s been an exciting ride helping companies investigate violations and deal with the authorities."

Partner, Düsseldorf

Rabea Pape-Lingier

What has been essential to my journey is building genuine relationships. Collaboration with people, both clients and colleagues, is at the heart of what I do. I actively embrace Baker McKenzie’s “culture of friendship” and global mindset, attending conferences and industry events to build strong professional contacts across many countries. Many of these have become personal friendships. This international network enriches my work daily: Wherever clients face challenges, I can bring in the right experts to develop solutions together."

Corporate/M&A Partner, Baker & McKenzie (Gaikokuho Joint Enterprise)*, Tokyo

Byron Frost

This year, achieving partnership feels like both a milestone and a reminder of how far we’ve come together. I’m grateful for every opportunity, every challenge and every person who made this journey possible."

Partner, Los Angeles

Maria Piontkovska

"My most memorable moment so far has been attending the EMEA Tax Partner Meeting for the first time. It was valuable to sit at the table to discuss and develop solutions to our clients’ specific needs across the region. What I appreciate most is impacting the direction of our practice. Being able to contribute directly to how we serve clients across jurisdictions, identify what’s coming next and build strategies together with partners from different countries is a great next step. This experience highlighted what I have always enjoyed about this work: bringing the right people together to solve complex problems. As a partner, I now have more direct influence on the future of our practice and how we deliver value to clients. It is practical, collaborative work at a strategic level, which is exactly what drew me to this field in the first place."

"One of my most memorable moments as a partner so far has been attending the recent Hotel Investment Conference Asia Pacific (HICAP) in Singapore, where I had the privilege of collaborating with fellow partners from across APAC. The opportunity to meet clients, connect with new contacts, and share knowledge and experiences together with my fellow partners made the event truly rewarding. For me, it reinforced that every effort invested in becoming a partner at Baker McKenzie was worthwhile. The camaraderie among partners and the sense of belonging within our wider Firm community is unmatched. This recent experience highlighted the strength of our collaborative culture and the value of working together to achieve common goals. Looking ahead, I am excited to share my journey and insights with incoming associates, supporting them as they progress through the ranks. Helping shape the next generation of leaders is a responsibility I embrace with pride and enthusiasm."

"So far, my most memorable moments as partner relate to generating new work with clients — particularly when those opportunities involve collaborating with colleagues across the globe. There is something uniquely energizing about identifying a client need and seeing their trust translate into new engagements. Being able to do it with great people doesn’t just make it easier — it makes it fun."

Learn what’s on the radar for financial institutions in 2026

 Partner, Zurich

Ansgar Schott

Partner, Hong Kong

Karen Man

Partner, Milan

Carlo de Vito Piscicelli

Disclaimers

Privacy & Cookies Statement

Seeking out the competitive edge for private banking

Staying ahead of global tax audits

Partner spotlight

Financial institutions in a digital and regulatory reset

Guidelines for AI: The in-house counsel checklist

Catch up on previous issues

Integrated legal, tax and regulatory guidance Banks need legal expertise to deliver comprehensive advisory services that address complex cross-border regulations, tax laws and fiduciary duties, ensuring compliance and client confidence.

Technology and compliance risk management Legal guidance is crucial for implementing advanced compliance technologies and meeting evolving cybersecurity and data privacy standards to minimize risks and penalties. Leveraging AI for regulatory reporting and client profiling is becoming a competitive differentiator.

International market entry and diversification Legal support is required to navigate foreign regulations, tariffs and market entry restrictions, safeguarding global investments and ensuring compliance.

*Studio Professionale Associato a Baker & McKenzie is a member of Baker & McKenzie International, a Swiss Verein.

Partner, Los Angeles

Maria Piontkovska

Corporate/M&A Partner, Baker & McKenzie (Gaikokuho Joint Enterprise)*, Tokyo

Byron Frost

Partner, Düsseldorf

Rabea Pape-Lingier

Strategic partnerships and outsourcing Partnering with third-party legal, tax and technology experts requires careful structuring to manage liability, data sharing and compliance, especially across borders.

Transparency, disclosure and fiduciary standards Clear legal guidance ensures transparent client disclosures, helping banks stand out and meet high-net-worth clients’ expectations for security, privacy and compliance.

Integrated legal, tax and regulatory guidance

Technology and compliance risk management

International market entry and diversification

Strategic partnerships and outsourcing

Transparency, disclosure and fiduciary standards

*Baker & McKenzie (Gaikokuho Joint Enterprise) is a member firm of Baker & McKenzie International, a global law firm with member law firms around the world.