This announcement of a new CFTC Chief of Staff is informational in nature and does not require immediate action from firms. It is relevant to banking, capital markets, and crypto firms due to the CFTC's regulatory oversight in these areas, as well as topics around governance and operational resilience.
Extract from the CSSF Newsletter No 300 – January 2026
Why this matters
This regulatory update from the CSSF provides monthly statistics and main figures regarding the Luxembourg financial centre, which is relevant for banking, investment management, and wealth management firms operating in the jurisdiction.
This regulatory update from the SFC appears to be informational in nature, welcoming a process review panel report. It likely covers topics related to consumer protection, reporting and disclosure requirements, as well as authorization and licensing for firms in the banking, investment management, and wealth...
The Federal Financial Supervisory Authority (BaFin) has sufficient grounds to suspect that TPK Vermögensverwaltungs KG is offering securities to the public in Germany in the form of shares in AuA 24 AG without the required prospectus. There are no indications that the conditions for exemption from the prospectus…
Why this matters
This regulatory update indicates that TPK Vermögensverwaltungs KG is suspected of offering securities to the public without the required prospectus, which is a violation of securities regulations. This impacts investment management and wealth management firms that may be involved.
This circular informs licensed financial advisers, exempt financial advisers, holders of capital markets services licence, exempt capital markets services entities, registered insurance brokers, exempt insurance brokers and licensed direct insurers of the issuance of the response to the Consultation Paper on Revised…
AI Analysis
MAS issued its response to the 2022 consultation and three revised misconduct-reporting Notices on 30 December 2025. The Notices create a more structured framework for misconduct, investigation and update reports, generally require reporting within 21 calendar days after reasonable grounds arise, and take effect on 1 January 2027, giving affected firms one year to prepare.
Key dates
2022-04-19
MAS opened Consultation P002-2022 on revised misconduct-reporting Notices.
2022-05-20
Consultation P002-2022 closed.
2025-12-30
MAS issued the consultation response and Revised Notices FAA-N27, Notice 508 and SFA 04-N24.
2026-06-30
MAS targeted the second quarter of 2026 for sharing finalised misconduct and investigation-report templates; the source does not specify a precise day.
2027-01-01 Deadline
The Revised Notices take effect and affected firms must comply with the revised misconduct-reporting framework.
Suggested considerations
Firms should map their representative and broking-staff populations, regulated activities and product lines to the applicable Notice, including the separate FAA and IA reporting treatment where conduct involves both a designated investment product and a long-term accident and health policy.
Compliance teams may wish to update misconduct taxonomies and escalation criteria to cover Part 12 SFA market-conduct breaches, fraud, dishonesty, illegal monetary gains, client detriment, gross negligence, inappropriate advice, misrepresentation and inadequate disclosure, while documenting how non-reportable internal-policy breaches are distinguished from reportable underlying conduct.
Firms should design procedures that identify when reasonable grounds arise and start the 21-calendar-day reporting clock without waiting for conclusive findings of culpability.
Firms should establish decision trees for simultaneous misconduct and investigation reports, later investigation reports, update reports, police-report assessments and developments received from law enforcement or public sources.
Firms should implement controls to provide reports and updates to current and former representatives, including identity verification, secure transmission, reasonable attempts using last-known contact details, acknowledgement or mailing evidence, and documented exceptions where disclosure could prejudice an investigation.
Firms should review disciplinary frameworks, proportionality factors, fine calibration, appeal processes and governance to evidence a fair and transparent assessment of severity and client impact.
Firms should enhance record-retention procedures to preserve relevant investigation, reporting, representative-notification and submission records in accessible and retrievable form for at least five years.
Firms should monitor MAS implementation materials and final reporting templates, which MAS targeted to publish by the second quarter of 2026, and test operational readiness before the effective date.
What changed
The revised instruments are Notice FAA-N27 under the Financial Advisers Act 2001, Notice 508 under the Insurance Act 1966, and Notice SFA 04-N24 under the Securities and Futures Act 2001. A firm must generally submit a misconduct report within 21 calendar days after it has reasonable grounds to believe that misconduct was committed; conclusive proof of culpability is not required.
Compliance impact
This is a binding conduct-reporting change with broad impact across Singapore financial advisers, capital-markets firms, insurance brokers and direct insurers. Failure to identify reasonable grounds promptly, report within 21 calendar days, provide required copies, submit investigation or update reports, or retain supporting records could lead to supervisory engagement and concerns about the firm’s governance, controls and fitness-and-propriety oversight.
The Securities and Exchange Commission today announced that Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), concluded her tenure with the agency on December 26, 2025.“I am thankful to Nekia for answering the call to…
AI Analysis
This SEC press release announces the departure of Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), who concluded her tenure on December 26, 2025, after overseeing enforcement investigations and litigations across Washington D.C., Atlanta, and Miami offices. It matters to compliance professionals as personnel changes in SEC Enforcement leadership can signal potential shifts in enforcement priorities, investigation focus, or regional scrutiny intensity in the Southeast U.S.
Key dates
December 26, 2025
- Nekia Hackworth Jones concludes her tenure at the SEC
December 29, 2025
- SEC issues press release announcing the departure
Suggested considerations
related delays and monitor for successor announcements via https://www.sec.gov/newsroom/press-releases.
What changed
There are no main regulatory changes, new requirements, or policy updates in this announcement; it is solely a personnel departure notice with no substantive regulatory implications.
Compliance impact
Urgency: low - This is a routine leadership transition with no immediate regulatory or enforcement changes; it matters peripherally for firms anticipating shifts in SEC Enforcement priorities under new leadership, but lacks direct compliance obligations.
The Securities and Exchange Commission today announced that Cicely LaMothe, Deputy Director of the Division of Corporation Finance, has retired from the agency.“Cicely has gone above and beyond the call of duty over the past twenty-four years to serve…
Why this matters
This regulatory update announces the retirement of a senior SEC official, which is informational in nature and does not require immediate action from regulated firms.
This regulatory update from the SFC relates to brokers and the return of misappropriated funds to affected parties, which impacts banking, investment management, and wealth management firms. It covers consumer protection, prudential requirements, and licensing/authorization topics.
Survey on the amount of covered deposits held on 31 December 2025
AI Analysis
Circular CSSF-CPDI 25/49 is a **mandatory quarterly reporting requirement** for Luxembourg credit institutions and postal financial service providers to submit data on covered deposits as of December 31, 2025. This survey directly feeds into the Single Resolution Fund's annual target level calculation and the Luxembourg deposit guarantee scheme's contribution assessments, making it essential for regulatory compliance and fund management.
Key dates
December 24, 2025
- Circular publication date
December 31, 2025
- Reference date for the survey
January 30, 2026 Deadline
- Deadline for transmitting average covered deposits data to the Single Resolution Board
Suggested considerations
*Calculate covered deposits as defined in Article 163 of the 2015 law, including balance and accrued interest (even if not yet due)
*Report eligible deposits after applying exclusions under Article 172 of the 2015 law, including exclusions for financial institutions and life insurance products
*Distinguish deposit types by reporting:
Total eligible deposits (field 201)
Eligible deposits in omnibus accounts, fiduciary accounts, trusts, sub-accounts, and segregated accounts (field 0226)
What changed
The circular explicitly states that no substantive changes have been made to the survey process compared to previous quarters. The only modifications are administrative: the reference date (December 31, 2025) and the submission deadline (January 30, 2026). The specifications for data collection, definitions of covered and eligible deposits, and reporting methodologies remain unchanged from prior circulars, particularly Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35.
The Financial Services and the Treasury Bureau (FSTB) and Securities and Futures Commission (SFC) have concluded consultations launched on 27 June 2025 on licensing regimes for virtual asset (VA) dealers and VA custodians, confirming legislative proposals to regulate these activities while further consulting on new regimes for VA advisers and asset managers. This advances Hong Kong's comprehensive VA regulatory roadmap, mandating SFC licensing for core VA dealing (e.g., VA-to-VA conversions, broker-dealer services) and custody (focusing on private key safekeeping), with strict requirements for asset segregation and use of licensed custodians to mitigate risks like insolvency, fraud, and cyberattacks. It matters for compliance professionals as it closes gaps in VA oversight, enforces Type 1/Type 13-equivalent standards, and signals accelerated implementation in 2026, potentially reshaping market structures for trading, custody, and related services.
Suggested considerations
Pre-Application Engagement: Contact SFC immediately for discussions on VA custodian licensing, especially for existing VATPs/banks holding keys.
License Applications: Prepare applications for VA dealer/custodian licenses once regimes commence; appoint responsible officers/managers-in-charge meeting fit-and-proper criteria, implement cold wallet infrastructure, private key controls, insurance, audits, and business continuity plans.
Custody Segregation: Existing intermediaries/VA dealers must transition client VA custody to SFC-licensed VA custodians; cease use of non-compliant overseas providers.
Compliance Mapping: Review operations against Type 1/Type 13 financial resources, core function authorizations, and exemptions; assess staking/MPC services for custody capture.
Monitor Further Consults: Track incoming VA advisory/management regimes and adjust for no deeming provisions.
What changed
- VA Dealer Regime: Introduces licensing for VA dealing activities (e.g., VA conversions, broker-dealer services at physical outlets or otherwise), excluding tokenized securities/derivatives...
VA Custodian Regime: Targets entities safeguarding private keys or enabling unilateral VA transfers (e.g., capturing staking providers but exempting non-custodial wallets or delegating top-layer...
Exemptions Under Consideration: Aligns partially with Type 1 exemptions, including principal/intra-group transactions, VA use as payment for goods/services, chaperone via SFC-regulated dealers, VA...
Further Consultations: New regimes for VA advisory (aligned with Type 4) and asset management (aligned with Type 9), without deeming provisions for pre-existing entities; VA managers may face custody...
Compliance impact
Urgency: High – Conclusions signal imminent 2026 legislation and licensing without transitional relief, requiring firms to build infrastructure (e.g., licensed custody partnerships, RO appointments) amid a two-tier market (trading segregated from custody) to avoid operating unlicensed post-implementation; non-compliance risks enforcement, as seen in prior VA circulars, while opportunities arise for first-movers in Hong Kong's VA hub ambitions.
Warning Warning Savings protection Crypto-assets Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Why this matters
This is a warning from the French financial regulator AMF about unauthorized entities operating in the crypto-asset space, which is relevant for crypto exchanges, fintechs, and other firms involved in the crypto industry. It relates to consumer protection and the need for proper licensing and authorization.
On 21 November 2025, Michael Pettifer Insurance Brokers Limited, trading as MPI Brokers, entered creditors’ voluntary liquidation. Robert Cooksey of Bridgestones Limited has been appointed as liquidator. MPI Brokers was authorised and regulated by the FCA to sell and arrange insurance policies. The firm specialised in…
Why this matters
This regulatory update is about an insurance broker, Michael Pettifer Insurance Brokers Limited, entering liquidation. This falls under the Insurance & Pensions sector and involves topics related to firm authorization/licensing and consumer protection.
Warning Warning Savings protection Miscellaneous assets The AMF is warning the public against several entities proposing to invest in miscellaneous assets without being authorized to do so
Why this matters
This warning from the AMF relates to entities proposing to invest in miscellaneous assets without proper authorization, which poses risks to consumers and requires urgent attention from relevant financial firms.
ESMA publishes latest Spotlight on Markets newsletter featuring updates on market integration and transparency 23 December 2025 ESMA newsletter The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published the latest edition of its Spotlight on Markets…
AI Analysis
ESMA's latest *Spotlight on Markets* newsletter (November/December 2025 issue, published 23 December 2025) summarizes key regulatory updates on EU market integration, transparency enhancements, and supervisory actions, including welcoming the European Commission's market integration proposal and announcing an equity consolidated tape provider (CTP) selection. This matters for compliance professionals as it signals accelerating EU efforts to deepen capital markets integration, improve data transparency, and strengthen oversight under MiFID II and DORA, potentially requiring firms to adapt governance, reporting, and conflict management practices.
Key dates
4 December 2025
- European Commission publishes market integration legislative package; legislative process expected to take at least one year
23 December 2025
- Newsletter publication date
Suggested considerations
Review the final non-equity transparency RTS and assess impacts on trading and reporting systems for compliance by any upcoming application dates (not specified).
Evaluate MiFID II conflicts of interest policies in preparation for the CSA; conduct internal audits and enhance training/staff attestations on identification and mitigation.
Monitor equity CTP rollout for changes to post-trade data access and costs; update vendor contracts if applicable.
For DORA-impacted firms, map exposures to designated critical ICT providers and strengthen due diligence, contractual clauses, and exit strategies.
Asset managers: Audit fund names against guidelines and review UCITS distribution practices for cost transparency.
What changed
- ESMA welcomes the European Commission's 4 December 2025 legislative package on market integration, emphasizing robust governance and market infrastructure for deeper EU capital markets.
Announcement of selected applicant for the equity consolidated tape provider (CTP), advancing MiFIR transparency for equity markets by improving post-trade data consolidation and access.
Publication of ESMA's final report on Regulatory Technical Standards (RTS) for non-equity transparency, clarifying pre- and post-trade transparency rules for bonds, derivatives, and other non-equity...
Launch of a Common Supervisory Action (CSA) on MiFID II conflicts of interest requirements to promote supervisory convergence and governance across Member States.
European Supervisory Authorities (ESAs) designate critical ICT third-party providers under DORA, enhancing oversight of key outsourcing risks.
Compliance impact
Urgency: Medium - The newsletter highlights finalized standards (e.g., RTS, CTP) and imminent actions (e.g., CSA, DORA designations) that require proactive preparation, but lacks hard deadlines or immediate mandates. It matters because it previews intensified supervision on transparency, conflicts, and resilience, aligning with EU Capital Markets Union goals; firms delaying reviews risk findings in upcoming CSAs or audits, especially amid ESMA's push for convergence.
The Bank's Court of Directors acts as a unitary board, setting the organisation's strategy and budget and taking key decisions on resourcing and appointments. Required to meet a minimum seven times per year, it has five executive members from the Bank and up to nine non-executive members.
Why this matters
This regulatory update discusses the Bank of England's Court of Directors, which is responsible for setting the organization's strategy and making key decisions. This is relevant for banking, investment management, and wealth management firms that are subject to the Bank of England's oversight and governance...
Update of Circular CSSF 24/850 on the practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS, as well as the engagement of the réviseurs d’entreprises agréés (approved statutory auditors) of support PFS and practical rules concerning…
AI Analysis
Circular CSSF 25/903 updates Circular CSSF 24/850, refining practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg regarding their annual descriptive report, self-assessment questionnaire, and the roles of approved statutory auditors (réviseurs d’entreprises agréés). It specifies requirements for auditors' engagement, management letters, and separate annual reports. This matters for support PFS as it enhances supervisory oversight, ensures consistent reporting quality, and strengthens internal controls, directly impacting compliance and audit processes amid CSSF's focus on robust PFS supervision.
Key dates
30 April (annually) Deadline
Submission Deadline; Support PFS must submit descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF by 30 April following the financial year-end (first applicable: 30 April 2026 for FY 2025)
31 December 2025 Deadline
Preparation Milestone; Auditors must be engaged and initial scoping completed by year-end 2025 for FY 2025 compliance
1 January 2026
Effective Date; Applies to annual reporting cycles starting for financial year 2025 onwards
Suggested considerations
*Review and Update Processes: Support PFS must map current reporting against new templates in CSSF 25/903 and revise internal procedures for descriptive reports and self-assessments.
*Engage/Confirm Auditors: Select or confirm approved statutory auditors compliant with new engagement rules; execute updated engagement letters incorporating circular requirements by Q4 2025.
*Implement Templates and Testing: Adopt CSSF-provided templates for reports, management letters, and separate reports; conduct sample-based testing of controls as specified.
*Training and Governance: Train compliance/audit teams on changes; ensure board approval of self-assessments and auditor findings.
*Submit on Time: Prepare and file all documents by 30 April deadlines, retaining evidence for CSSF inspections.
What changed
- Updates to Descriptive Report and Self-Assessment Questionnaire: Refines content, format, and submission requirements for support PFS's annual submissions, emphasizing more detailed disclosures on...
Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for...
Management Letter and Separate Report: Establishes detailed rules for auditors to issue an annual management letter (addressing findings, recommendations, and remediation) and a separate report for...
Enhanced Documentation and Evidence: Requires support PFS and auditors to provide verifiable evidence (e.g., checklists, testing samples) supporting self-assessments, with stricter CSSF validation...
Compliance impact
Urgency: High. This is high urgency for support PFS due to the impending 30 April 2026 deadline for FY 2025 submissions, with non-compliance risking supervisory fines, license reviews, or reputational damage under CSSF's PFS enforcement regime. It matters as it tightens audit accountability, potentially increasing costs (e.g., auditor fees) while reducing reporting errors—critical for smaller support entities with limited resources.
The German Financial Supervisory Authority (BaFin) warns against WhatsApp groups such as „S373 Robeco Kernmitgliedergruppe“, “M2 Robeco Value Investing Kreis“ and „999 Robeco Investment Strategiezentrum - Blockhandel“, which are allegedly operated by the Frankfurt a.M.-based company Robeco Deutschland…
Why this matters
This regulatory update from BaFin warns about potential identity fraud and unauthorized financial activities targeting consumers through WhatsApp groups and a mobile app called 'RBC NL'.
Repeal of Circular CSSF 19/731 regarding the documents to be submitted on an annual basis by credit institutions.
AI Analysis
Circular CSSF 25/902 repeals Circular CSSF 19/731 (as amended by Circular CSSF 19/710), which previously detailed annual document submission requirements for credit institutions, shifting to a dynamic list published on the CSSF website. This matters because it streamlines compliance by centralizing and updating requirements online, reducing reliance on static circulars while maintaining submission obligations. Credit institutions must transition to the new process to avoid disruptions in prudential reporting.
Key dates
12 December 2019
- Original issuance of repealed Circular CSSF 19/731 (archived on 23 December 2025)
23 December 2025
- Publication and effective date of Circular CSSF 25/902, repealing Circular CSSF 19/731; transition to website-based list begins
Suggested considerations
Review the CSSF Prudential reporting webpage (https://www.cssf.lu/en/prudential-reporting-credit-institutions/) and summary table (https://www.cssf.lu/en/Document/summary-of-documents-to-be-submitted-on-an-annual-basis/) to identify current document lists, categories, channels, and deadlines.
Update internal reporting processes, templates, and workflows to reference the website instead of the repealed circular.
Confirm ongoing annual submissions via specified electronic channels; test interactive table for applicability to the institution's profile.
Archive references to Circular CSSF 19/731 in policies and train staff on the change.
What changed
- Repeal of prior circulars: Circular CSSF 19/731 and its amendment via Circular CSSF 19/710 are fully repealed, eliminating the fixed list of annual submission documents.
Shift to website-based guidance: The updated list of required documents, affected entity categories, electronic submission channels, and deadlines is now published on the CSSF’s Prudential reporting...
Ongoing obligations: The requirement to submit documents annually remains unchanged; only the reference source and potential content updates via the website are modified.
Compliance impact
Urgency: Medium – The repeal does not alter core submission obligations but requires procedural updates to avoid non-compliance with potentially evolving lists under CRR3 alignments. It matters for operational efficiency, as failure to adapt could lead to missed deadlines or incorrect submissions, especially with website updates tied to EU regulations like Regulation (EU) 2024/1623 (CRR3, applicable from 1 January 2025). Institutions should prioritize review before the next annual cycle to ensure seamless reporting.
Practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS.Engagement of the réviseurs d’entreprises agréés (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be…
AI Analysis
Circular CSSF 24/850, as amended by Circular CSSF 25/903, establishes practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg to submit annual descriptive reports and self-assessment questionnaires, while also defining the roles of approved statutory auditors (réviseurs d’entreprises agréés) in issuing management letters and separate reports. This guidance standardizes supervisory reporting and audit processes to enhance oversight of support PFS, which provide essential back-office services to authorized PFS. It matters because non-compliance risks supervisory sanctions, reputational damage, and operational disruptions for entities reliant on support PFS structures.
Key dates
1 January 2025
- Effective date of original Circular CSSF 24/850
15 December 2025
- Effective date of amendments in Circular CSSF 25/903, applicable to 2025 reporting cycle onwards
31 March annually Deadline
- Deadline for submission of descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF (first applicable for FY 2024 reporting due 31 March 2025)
End of February annually Deadline
- Support PFS must engage auditors and provide necessary data to enable timely report preparation
Suggested considerations
Annual Reporting Cycle:
1. By year-end, conduct internal self-assessment using the prescribed questionnaire template (available via CSSF portal).
February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report.
Governance Updates: Review and update internal policies on risk assessment, auditor selection, and remediation of management letter findings; ensure board oversight of submissions.
Auditor Coordination: Verify auditor qualifications per CSSF register; implement any remediation plans from prior-year management letters before next cycle.
Record-Keeping: Maintain 5-year audit trail of all supporting documentation for CSSF inspections.
What changed
- Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management,...
Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separate report confirming...
Amendments via CSSF 25/903: Updates clarify submission procedures, expand self-assessment criteria (e.g., adding cybersecurity and outsourcing risk questions), and refine auditor independence...
Frequency and Scope: Annual submissions required without exceptions; scope limited to support PFS (not primary PFS), emphasizing substance over form in service descriptions.
Compliance impact
Urgency: High – This is a recurring annual obligation with a firm 31 March deadline, where delays trigger automatic CSSF notifications and potential fines (up to €250,000 per Law 1993). It matters for support PFS as it intensifies scrutiny on operational resilience in a post-SFI (2021) landscape, where CSSF prioritizes substance in delegated functions; failure risks de-authorization or client outflows. Early implementation of templates and auditor pipelines is essential to avoid first-year pitfalls.
This regulatory update announces the swearing in of a new CFTC Chairman, which is relevant for banking, capital markets, and crypto firms that are subject to CFTC oversight and regulation. The new leadership could impact authorization, prudential, and governance requirements for these firms.
This regulatory update announces the departure of the Acting Chairman of the Commodity Futures Trading Commission (CFTC), which is relevant for firms in the banking, capital markets, and crypto sectors.
This announcement relates to the appointment of a new member to the CFTC's Digital Asset Markets Subcommittee, which is relevant for crypto exchanges and other digital asset firms.
The Securities and Exchange Commission today filed charges against purported crypto asset trading platforms Morocoin Tech Corp., Berge Blockchain Technology Co. Ltd., and Cirkor Inc. and investment clubs AI Wealth Inc., Lane Wealth Inc., AI Investment…
Why this matters
This regulatory update from the SEC charges several purported crypto asset trading platforms and investment clubs with a scheme targeting retail investors on social media, which falls under the SEC's jurisdiction over crypto assets, capital markets, and investment management.
Sanctions & settlements professional obligations Journalists Investment management companies Listed companies and issuers AMF Enforcement Committee fines the depositary CACEIS Bank for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning on 17 December 2025 for breaches of its professional obligations as depositary for seven French-law UCITS funds managed by H2O AM LLP (later transferred to H2O AM Europe). This decision underscores the AMF's strict enforcement of depositary oversight duties, particularly in verifying fund managers' investment monitoring systems, asset valuations, and compliance with prospectus constraints like issuer limits and security ratings. It matters for compliance teams as it highlights personal accountability risks and potential fines for inadequate due diligence in fund depositary roles, signaling heightened scrutiny amid past H2O fund issues.
Key dates
17 December 2025
- AMF Enforcement Committee decision date: €3.5M fine and warning imposed on CACEIS Bank
Suggested considerations
Conduct gap analysis: Review depositary control frameworks against AMF expectations for verifying AMC investment monitoring, unlisted asset valuations, and prospectus compliance (e.g., 10% issuer limits, ratings).
Enhance oversight processes: Implement robust, documented checks on AMC systems, including independent testing of ratios, legality of investments, and derivatives.
Training and audits: Train staff on UCITS depositary duties; perform internal audits of ongoing fund oversight, prioritizing illiquid/unlisted exposures.
Monitor appeals: Track any CACEIS appeal, as outcomes could set precedents; update policies if upheld.
Reporting: Ensure timely escalation of suspected AMC breaches to AMF if identified.
What changed
This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and the 10% single-issuer bond exposure cap.
No new...
Compliance impact
Urgency: High - This recent (Dec 2025) decision directly impacts depositaries with €3.5M precedent for oversight failures, amid AMF's pattern of multi-million fines (e.g., €5.67M total in related 2024 case involving CACEIS). It elevates risks for UCITS/AIF depositaries handling non-standard assets, demanding immediate control reviews to avoid personal sanctions, warnings, or business restrictions, especially post-H2O scandal.
A growing number of investment schemes are being promoted unlawfully, are high risk and may even be scams. We've identified a growing number of investment schemes in holiday lodges and holiday homes being promoted to UK consumers by companies that are not FCA authorised.They may be unregulated collective investment…
AI Analysis
The FCA has issued a consumer warning about unregulated investment schemes in holiday lodges and holiday homes, which are often promoted unlawfully by unauthorised firms, posing high risks or outright scams. These schemes typically involve collective investments without FCA authorisation, breaching UK financial promotion and collective investment scheme (CIS) rules. This matters for compliance professionals as it signals heightened FCA scrutiny on unauthorised promotions, potential enforcement actions, and the need for firms to review marketing materials and client referrals to avoid facilitation risks.
Suggested considerations
Immediate verification: Check client-facing promotions, websites, and advisor scripts for any reference to holiday lodge/park schemes; ensure no endorsement of unauthorised products.
Client communication review: Audit advice processes to flag and reject high-risk, unregulated collective schemes; document refusals.
Training and monitoring: Update firm-wide training on CIS definitions (per COLL sourcebook) and unauthorised promotion risks; enhance surveillance of emails, social media, and third-party referrals.
Internal reporting: Escalate any suspected unauthorised promotions to the FCA via Connect or the unauthorised firms reporting form (https://www.fca.org.uk/consumers/report-scam-unauthorised-firm).
Due diligence: For authorised firms, implement pre-approval checks under the financial promotions regime (PERG 8 guidance) to confirm partner schemes are not CIS.
What changed
This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include:
Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA).
Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal.
No new requirements are introduced, but the FCA emphasises its ongoing monitoring and willingness to intervene, including via the Financial Promotions Regime (effective from 7 October 2023 for all...
Compliance impact
Urgency: High. This alert indicates active FCA enforcement priority on consumer-facing scams in property-linked investments, with risks of fines, bans, or asset freezes for non-compliance (e.g., similar to past actions against mini-bond issuers). Firms face heightened supervisory visits or thematic reviews; inaction could lead to principal liability for facilitating unauthorised activities, especially post-2023 promotions regime. Prioritise within 30 days to align with FCA's "buyer beware" stance shifting to proactive gatekeeping.
The Federal Financial Supervisory Authority (BaFin) warns consumers about “bearer bonds” being offered for subscription by Marketplace24-7 GmbH on the website non-dom(.)group. BaFin suspects the company of conducting banking business without the required authorisation. The company is furthermore suspected of making an…
Why this matters
This regulatory update from BaFin warns consumers about potential unauthorized banking and securities activities by Marketplace24-7 GmbH, which is a matter of high urgency for banks, fintechs, and all firms in the financial sector due to the consumer protection and market integrity implications.
On 16 December 2025, BaFin imposed two administrative fines amounting to €560,000 on flatexDEGIRO Bank AG. The company had contravened obligations under the German Securities Trading Act (Wertpapierhandelsgesetz - WpHG). At the beginning of 2022, flatexDEGIRO Bank AG advertised free investment services on two of its…
AI Analysis
BaFin imposed €560,000 in administrative fines on flatexDEGIRO Bank AG on December 16, 2025, for misleading marketing of investment services that advertised free offerings without clearly disclosing mandatory processing fees. This enforcement action underscores BaFin's strict interpretation of fair and transparent marketing requirements under the German Securities Trading Act (WpHG) and demonstrates that even corrective action taken by firms does not eliminate regulatory penalties for past violations.
Key dates
Beginning of 2022
– flatexDEGIRO Bank AG violated WpHG requirements by advertising free services without disclosing processing fees
2022
– flatexDEGIRO adapted its practices to comply with legal requirements
December 16, 2025
– BaFin imposed two administrative fines totaling €560,000
December 22, 2025
– BaFin publicly announced the enforcement action
Suggested considerations
*For flatexDEGIRO Bank AG (already completed):
Modify marketing materials to clearly and explicitly disclose all material costs and fees
Ensure balanced presentation of benefits and risks across all marketing channels
*For all investment services providers (preventive compliance):
*Audit marketing materials across all channels (websites, social media, advertisements, promotional materials) to identify any claims of "free" or "no-cost" services that lack explicit fee disclosures
What changed
The enforcement action clarifies BaFin's expectations regarding fair and clear marketing communications for investment services:
Investment services providers must explicitly and unambiguously disclose all material costs, including processing fees, when advertising services as "free"
Marketing materials must present both benefits and risks of services in a balanced manner, with relevant risks highlighted alongside advantages
These obligations apply across all marketing channels, including company websites
The requirements are grounded in the WpHG and further specified in EU regulations and MiFID II guidance
The violation centered on flatexDEGIRO's failure to clearly indicate that regular processing...
ESMA publishes 2024 data on cross-border investment activity of firms 22 December 2025 Investor protection The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, in cooperation with National Competent Authorities (NCAs), completed an analysis of the cross-border…
Why this matters
This regulatory update from ESMA provides data and analysis on the cross-border provision of investment services by firms across the EU/EEA. It covers topics related to investment management, capital markets, and wealth management, with implications for reporting, consumer protection, and licensing requirements.
Press release 25/21(published on 22 December 2025, updated on 31 December 2025)
Why this matters
This regulatory update is about the dissolution and judicial liquidation of ALFA ASSET MANAGEMENT (EUROPE) S.A., an investment management and wealth management firm. It involves topics related to authorization and licensing as well as prudential and capital requirements.
This regulatory update from the CFTC appears to be related to a new pilot program focused on unleashing American energy dominance, which could impact capital markets and crypto/digital asset firms. The topics of technology/cyber and authorization/licensing are likely relevant.
This CFTC no-action letter provides relief from CPO registration requirements for certain SEC-registered investment advisers, which is relevant for asset managers and broker-dealers in the investment management and capital markets sectors. The content is informational in nature.
This statement from the CFTC Acting Chairman discusses a report from IOSCO on pre-hedging, which is relevant to capital markets participants and crypto firms that engage in trading and market activities.
This regulatory update from the CFTC relates to whistleblower awards, which is relevant for firms in the banking, capital markets, and crypto sectors. The topics covered include AML/financial crime, market abuse, and reporting requirements, which are important compliance areas for the affected firm types.
This Market Notice sets out the schedule for sales in Q1 2026 of gilts held in the Asset Purchase Facility (APF) for monetary policy purposes.
Why this matters
This regulatory update from the Bank of England relates to the sale of gilts held in the Asset Purchase Facility, which is relevant for banking, capital markets, and investment management firms. It covers prudential requirements, market abuse, and reporting obligations.
Long term investment Shares Artificial intelligence Retail investors Journalists AMF 2025 Barometer: in search of autonomy, many French people turn to artificial intelligence when they want to invest
Why this matters
This regulatory update discusses how French retail investors are increasingly turning to artificial intelligence when making investment decisions, which is relevant for investment managers, wealth managers, and fintech firms that provide AI-powered investment services.
New Q&As available 19 December 2025 Digital Finance and Innovation Fund Management Market Abuse Prospectus Sustainable finance The European Securities and Markets Authority (ESMA), the EU's securities markets regulator, has published or updated the following Questions and Answers: Alternative Investment Fund Managers…
AI Analysis
ESMA published new Q&As on December 19, 2025, addressing practical implementation questions across multiple regulatory frameworks including AIFMD, ESG rating activities, and sustainable finance rules. These guidance documents clarify regulatory expectations and promote consistent supervisory approaches across EU member states, making them essential for firms operating in affected areas to ensure compliant implementation.
Key dates
30 June 2025
- ESMA's final report on prospectus ESG disclosure requirements became effective (referenced in search results as June 6, 2025 publication date)
22 September 2025
- ESMA published updated consolidated Q&A on SFDR and Level 2 Regulation with new PAI disclosure guidance
17 October 2025
- ESMA updated MiCAR Q&As on execution service classification
19 December 2025
- ESMA published new Q&As across multiple regulatory domains
Suggested considerations
*Immediate (0-30 days):
*Short-term (1-3 months):
level information
advertised securities per Annex 21 requirements
What changed
The December 19, 2025 Q&A publication covers several regulatory domains:
AIFMD Exclusion Criteria: New guidance on the UNGC/OECD Guidelines exclusion (Q&A 2734), clarifying when alternative investment fund managers must apply exclusion-related requirements
ESG Rating Activities: Updated Q&As addressing regulatory requirements for ESG rating providers, including clarification on group-affiliated small ESG rating activities
Sustainable Finance: Continued development of guidance under SFDR and related sustainability disclosure frameworks
Digital Finance and Innovation: Guidance supporting implementation of digital finance rules
The FCA has removed all regulatory permissions from Verus Financial Services Limited requiring it to stop conducting all regulated activities and imposed a more stringent assets restriction. The action follows concerns that the firm has repeatedly breached an existing asset restriction, which prevented it from…
Why this matters
This regulatory update from the FCA indicates that Verus Financial Services Limited has had its regulatory permissions removed and faces stricter asset restrictions due to repeated breaches and failure to comply with a Financial Ombudsman Service decision.
The Money Markets Committee is a forum for market participants and authorities to discuss the UK unsecured deposits and funding market and securities lending and repo markets.
Why this matters
This regulatory update discusses the Money Markets Committee, which is a forum for discussing the UK unsecured deposits and funding market, as well as securities lending and repo markets.
Invesco Investment Management Limited (CLONE) - Central Bank of Ireland Issues Warning on Unauthorised Firm
Why this matters
This is a warning from the Central Bank of Ireland about an unauthorized firm using the name of a legitimate investment management company. This is a consumer protection and authorization issue that requires urgent attention.
Harbor Valtrix– Central Bank of Ireland Issues Warning on Unauthorised Firm
Why this matters
This is a warning from the Central Bank of Ireland about an unauthorized firm, which is relevant for banking, investment management, and wealth management firms that need to be properly licensed to operate. It raises consumer protection and authorization issues.
Solunar Finance Holdings Limited (Clone) – Central Bank of Ireland Issues Warning on Unauthorised Firm
Why this matters
This is a warning from the Central Bank of Ireland about an unauthorized firm that has cloned the details of an Irish registered company, Solunar Finance Holdings Limited. This is a consumer protection issue that also relates to authorization and licensing requirements for financial firms operating in Ireland.
19 DEC 2025, 10:55 AM
UAE Sustainable Finance Working Group Publishes Fourth Statement During Abu…
Why this matters
This regulatory update from the UAE Sustainable Finance Working Group covers progress across key areas of sustainable finance including corporate governance, disclosures, taxonomy development, and climate transition planning. It is relevant for a range of financial firms operating in the UAE market.
This regulatory update relates to the profit and loss account of credit institutions, which is relevant for banking and investment management firms. The topics of prudential/capital requirements and reporting/disclosure are also applicable. The update is informational in nature, so the urgency is low.
Supervisory Statement SS2/25 from the Prudential Regulation Authority (PRA) provides guidance on prudential considerations for UK insurance and reinsurance undertakings transferring risk to Special Purpose Vehicles (SPVs). It clarifies expectations for ensuring such transfers comply with Solvency II requirements, focusing on risk transfer validity, capital relief recognition, and supervisory approval processes. This matters because it aims to enhance transparency and risk management in reinsurance arrangements, reducing potential regulatory arbitrage while supporting efficient risk mitigation for insurers amid evolving market dynamics.
Suggested considerations
Immediate Review (by Q1 2026): Conduct gap analysis of all existing SPV portfolios against SS2/25 criteria, documenting ERT evidence and collateral adequacy.
Governance Updates: Enhance board policies for SPV approvals, including mandatory stress testing (e.g., 1-in-200 year events) and independent validation by external actuaries.
Pre-Transaction Processes: Implement PRA notification templates for transfers >10% SCR; prepare deal packs with legal opinions on SPV independence.
Reporting Enhancements: Update internal systems for RFR disclosures on SPV exposures; train Senior Insurance Managers (SIMs) on accountability under SIMR.
Remediation: For non-compliant legacy SPVs, unwind or restructure by June 2027, notifying PRA of plans by March 2027.
What changed
- Risk Transfer Validation: Firms must demonstrate that SPV risk transfers provide genuine economic risk transfer (ERT), not just accounting or regulatory capital relief, with PRA emphasizing...
Capital Relief Criteria: Introduces stricter tests for recognizing capital relief, including full collateralization requirements, independent third-party guarantees, and prohibitions on circular...
Governance and Documentation: Mandates robust board-level oversight, detailed transaction documentation (including stress testing and scenario analysis), and pre-transaction PRA notification for...
SPV Oversight: SPVs must be structured to operate independently, with PRA reserving rights to challenge approvals if governance is inadequate or conflicts of interest arise.
Alignment with Solvency II: Builds on existing rules (e.g., Article 211-213) but provides PRA-specific interpretations, including updated expectations on limited risk appetite and post-transfer...
Compliance impact
Urgency: High – This is not a full regime shift but imposes immediate review obligations on firms with SPV exposure (estimated 20-30% of PRA-regulated insurers). Non-compliance risks capital add-ons, transaction disapprovals, or enforcement under PRA's Fundamental Rules, especially as PRA ramps up thematic supervision post-2025. Matters for capital efficiency in a high-interest-rate environment where SPVs are popular for cat risk.
The PRA has published LIAF03/25, a collection of final low impact rule amendments.
Why this matters
This is a regulatory update from the PRA on low impact rule amendments, which is likely to be of interest to banks, asset managers, and wealth managers in the banking, investment management, and wealth management sectors.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the website paragonixedge(.)app. BaFin suspects the unknown operators of offering consumers cryptoasset services without the required authorisation.
Why this matters
This regulatory update from BaFin warns consumers about an unauthorized crypto asset service provider, which falls under the crypto and digital assets sector. The key topics covered are authorization and licensing requirements, as well as consumer protection concerns.
ESMA selects EuroCTP to become the first Consolidated Tape Provider for shares and ETFs 19 December 2025 Press Releases Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has selected EuroCTP as the first Consolidated Tape Provider (CTP) for shares and…
Why this matters
This regulatory update from ESMA announces the selection of EuroCTP as the first Consolidated Tape Provider for shares and ETFs in the EU, which is a significant development for transparency in equity markets.
Economics Winter Workshop 2025: Opening Remarks by Governor Gabriel Makhlouf
Why this matters
This speech by the CBI Governor covers topics relevant to banks, asset managers, and wealth managers, including prudential requirements, operational resilience, and ESG. As an informational speech, the urgency is low.
In this, his final blog for 2025, Governor Gabriel Makhlouf reflects on Ireland and the euro area’s economic performance and looks ahead to 2026, drawing on the Quarterly Bulletin and latest eurosystem staff projections published this week.
Why this matters
This regulatory update discusses the economic performance and outlook for Ireland and the euro area, which is relevant for banking, investment management, and wealth management firms. It covers topics related to prudential requirements, reporting, and ESG/sustainability.
People could find it easier to pay using contactless, thanks to greater flexibility and the removal of red tape by the FCA. Banks and payment providers with strong fraud controls will be able to set their own limit for contactless payments, allowing them to better respond to changing consumer demands, inflation and…
Why this matters
This regulatory update from the FCA provides greater flexibility for banks and payment providers to set their own contactless payment limits, allowing them to better respond to changing consumer demands and new technology.
This regulatory update lists supervised entities, which is relevant for banks, asset managers, and wealth managers in the banking, investment management, and wealth management sectors.
relating to specialised investment funds, investment companies in risk capital and undertakings for collective investment subject to Part II of the Law of 17 December 2010
AI Analysis
Circular CSSF 25/901 consolidates and modernizes the supervisory framework for Luxembourg specialised investment funds (SIFs), investment companies in risk capital (SICARs), and undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs), including their sub-funds. It streamlines investment rules, diversification limits, borrowing, disclosures, and risk management while enhancing flexibility for sophisticated investors and formalizing prior informal guidance, reducing regulatory complexity without compromising investor protection.
Suggested considerations
Review and update fund documents (e.g., sales documents, instruments of incorporation) to include mandated disclosures on investment strategy/limits, risks, UCIs/vehicles, borrowing, liquidity tools, and retail-specific warnings.
Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified.
Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries.
For retail-marketed funds: Limit investments/UCIs to 25%, cap borrowing at 70%, add prominent risk warnings for illiquids/long-duration.
Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts.
What changed
- Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to...
SICAR-specific rules: Confirms risk capital investments (e.g., equity, mezzanine) must align with development objectives, exceed mere market risk, and deploy incoming cash into eligible assets;...
Borrowing: For retail-exposed SIFs/Part II UCIs, investment borrowing capped at 70% of assets/commitments; no hard cap for sophisticated investor funds if disclosed, with SICARs limited to risk...
Derivatives and techniques: Permits use if economically appropriate (e.g., risk/cost reduction), with risk-spreading via diversified underlyings/collateral; counterparty risk limited if...
Urgency: High – Formalizes prior informal guidance into binding rules with enhanced flexibility but stricter retail protections and disclosure mandates, requiring immediate document reviews/updates for non-compliant SIFs/SICARs/Part II UCIs to avoid supervisory scrutiny or authorization issues; critical for funds targeting private markets or retail.
The Federal Financial Supervisory Authority (BaFin) warns customers about online trading platforms that use the slogan “[...] invest your money in the world of cryptocurrencies with [...]”. BaFin suspects the unknown operators of offering consumers cryptoasset services without the required authorisation. The websites…
Why this matters
This regulatory update from BaFin warns consumers about unauthorized online trading platforms offering cryptocurrency services, which falls under the Banking & Credit, Crypto & Digital Assets, and Consumer Credit sectors. The key topics are consumer protection and authorization/licensing requirements.
This regulatory update from the ECB indicates the launch of fast-track assessments for capital and securitisation, which is relevant for banking and capital markets firms. It suggests changes to prudential and authorization requirements, making this a high priority update for banks.
This regulatory update from the ECB provides guidance on the notification of significant risk transfer and implicit support for securitisations, which is relevant for banking, investment management, and capital markets firms.
We confirm that the FCA has opened an investigation into WH Smith PLC. The investigation concerns potential breaches of UK Listing Principles and Rules and Disclosure and Transparency Rules in relation to the matters announced by WH Smith PLC on 19 November 2025.
AI Analysis
The FCA has launched an investigation into WH Smith PLC for potential breaches of UK Listing Principles and Rules, as well as Disclosure and Transparency Rules (DTRs), stemming from announcements made by the company on 19 November 2025. This underscores the FCA's heightened scrutiny of listed companies' disclosure practices and adherence to market conduct standards. Compliance professionals should note this as a signal of enforcement risk in timely and accurate market disclosures, potentially setting precedents for similar cases.
Key dates
19 November 2025
WH Smith PLC announcement triggering the investigation; (reference point for alleged breaches)
Suggested considerations
For WH Smith PLC: Cooperate fully with FCA requests for documents/interviews; conduct internal review of disclosure processes; prepare for potential enforcement outcomes (e.g., financial penalties under FSMA s.91 for listing rule breaches or DTR violations).
For other listed firms:
1. Review disclosure policies against DTR 4 (inside information) and Listing Rule 9; stress-test recent announcements (post-19 Nov 2025).
plan profit warnings or material updates, documenting decision trails.
What changed
This is not a policy change or new rule; it is an enforcement investigation announcement with no immediate regulatory amendments. It highlights ongoing enforcement of existing rules:
UK Listing Principles and Rules: These require listed issuers to act with integrity, provide accurate and timely information, and maintain effective systems for compliance (e.g., Principle 2 on...
Disclosure and Transparency Rules (DTRs): Specifically, DTR 4 mandates inside information disclosures via Regulatory Information Service (RIS), DTR 5 on periodic financial reporting, and DTR 2 on...
Compliance impact
Urgency: High. This matters due to the FCA's aggressive enforcement posture on market abuse/disclosures (e.g., post-SPPF reforms emphasizing individual accountability). Breaches can lead to multimillion-pound fines (e.g., 10% of annual revenue), director bans, and reputational damage, amplified by public naming. For listed firms, it signals rising risk in a volatile economic environment where trading updates are frequent; non-compliance could cascade to shareholder claims or delisting risks.
MDD is projected to grow by just below 4 per cent in 2025. From 2026 to 2028, MDD is forecast to grow at an annual average rate of 2.9 per cent per annum. More positive momentum in MNE investment amid lower uncertainty contrasts with slower pace of growth in domestic sectors and cooling of the labour market as drag…
Why this matters
This regulatory update provides a growth outlook for the MDD (Multinational Domestic Demand) sector, which is relevant for banking, investment management, and wealth management firms.
Revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment (“UCI”) are subject
AI Analysis
Circular IML 91/75, as amended up to CSSF Circular 25/901, consolidates and modernizes the supervisory framework for Luxembourg Part II UCIs, SIFs, and SICARs, refining rules on diversification, borrowing, risk-spreading, and disclosures while tailoring requirements to investor profiles. It matters because it streamlines fragmented regulations, enhances fund competitiveness, and formalizes CSSF expectations without mandating immediate changes for pre-existing funds, reducing compliance burdens while promoting transparency and flexibility. This update aligns administrative practices with market realities, repealing outdated circulars to eliminate ambiguity.
Suggested considerations
Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e.g., gates, notice periods), redemption processes, and investor-specific warnings.
Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications.
Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified.
For SICARs: Ensure risk capital investments meet modernized criteria; apply look-through for limits.
Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance.
What changed
- Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs.
Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with...
Borrowing Limits: New limits for SIFs/Part II UCIs (e.g., 70% of net assets, excluding temporary borrowings tied to commitments); tailored by investor type.
Enhanced Disclosures: Offering documents must detail investment policies, risks (especially private equity for retail), subscription/redemption processes, liquidity tools, gates, and amendment...
SICAR Risk Capital: Modernizes definition to include equity, loans, bonds, mezzanine; clarifies direct/indirect investments with three cumulative elements (risk of total loss, no redemption rights,...
Compliance impact
Urgency: Medium – Not critical as existing funds are grandfathered with no retroactive changes required, but high relevance for new launches or material updates post-19 Dec 2025. It matters for operational efficiency (streamlined rules reduce fragmentation) and investor protection (tailored risks/disclosures), potentially lowering long-term costs while mitigating supervisory scrutiny; failure to update docs could delay approvals or trigger CSSF queries.
Rules applicable to undertakings for collective investment when they employ certain techniques and instruments relating to transferable securities and money market instruments
AI Analysis
Circular CSSF 08/356, as amended by Circular CSSF 25/901, establishes detailed rules for Luxembourg undertakings for collective investment (UCIs), including UCITS and alternative investment funds (AIFs), on the use of techniques and instruments relating to transferable securities and money market instruments, such as securities lending, repo transactions, and over-the-counter (OTC) derivatives. It matters because it ensures investor protection, risk management, and market stability by imposing strict eligibility, collateral, and operational requirements, aligning Luxembourg funds with EU standards under UCITS and AIFMD directives. Compliance is critical for Luxembourg-domiciled funds engaging in these activities to avoid regulatory sanctions and operational disruptions.
Key dates
23 December 2008
- Original Circular CSSF 08/356 effective date for UCITS III implementation
21 July 2011
- Partial updates for UCITS IV alignment
22 July 2013
- Extension to AIFs under AIFMD transposition
15 October 2025
- Issuance of amending Circular CSSF 25/901
01 January 2026
- Effective date for amendments (e.g., new collateral rules, reporting formats)
Suggested considerations
*Policy Review & Update: Revise fund prospectuses, KIIDs, and risk management policies to reflect amended limits (e.g., counterparty caps, ESG collateral) within 3 months of 01 January 2026.
*Risk Management Systems: Implement or upgrade systems for daily collateral valuation, stress testing, and exposure monitoring; conduct gap analysis against Section 4 requirements.
*Counterparty Due Diligence: Reassess OTC counterparties for eligibility (e.g., EMIR clearing thresholds); negotiate ISDA/CSA agreements with updated haircuts.
*Operational Setup: Appoint triparty agents where required; ensure collateral segregation complies with Section 5.
*Reporting & Disclosure: Prepare for new quarterly CSSF filings (template in Annex 1); disclose revenues/reinvestments from techniques in annual reports (Article 14 UCITS Law).
What changed
The original Circular CSSF 08/356 (2008) transposed UCITS III requirements on eligible techniques like securities lending and repos.
Expanded collateral rules: Collateral must now include sustainable assets meeting SFDR criteria, with daily marking-to-market and haircuts adjusted for liquidity and credit risk (Section 3).
Counterparty exposure limits: Net exposure to a single OTC counterparty capped at 10% of net asset value (NAV), down from previous thresholds in some cases, with mandatory collateralization (Section...
Operational safeguards: Mandatory use of triparty agents for repos, enhanced segregation of collateral, and annual stress testing disclosures (Section 5, as amended).
Reporting enhancements: Quarterly reports to CSSF on transaction volumes, risks, and revenues from these activities (Annex 1, updated).
These align with ESMA guidelines (e.g., ESMA/2012/832 on OTC...
Compliance impact
Urgency: High - Immediate relevance for funds actively using these techniques (common in fixed-income and equity strategies for yield enhancement). Non-compliance risks CSSF fines (up to 5% of NAV), temporary prohibitions on techniques, or fund suspension. With the 01 January 2026 effective date recently passed (as of current context), firms face heightened scrutiny in 2026 reporting cycles; proactive remediation avoids enforcement actions amid CSSF's focus on operational resilience.
This CFTC update relates to direct clearing by retail participants, which impacts capital markets firms and crypto exchanges that facilitate retail trading and clearing. It touches on authorization and licensing requirements as well as reporting and disclosure obligations.
The CFTC approved a final rule on December 18, 2025, that codifies existing staff no-action positions and eliminates duplicative business conduct and documentation requirements for swap dealers and major swap participants. This rule resolves over a decade of regulatory uncertainty, reduces operational costs, and harmonizes CFTC requirements with SEC and Municipal Securities Rulemaking Board standards.
Key dates
April 4, 2025
- CFTC Staff Letter 25-09 issued, establishing no-action position on PTMMM requirement
September 12, 2025
- CFTC issued further amended exemptive order permitting JSCC to clear interest rate swaps
September 24, 2025
- CFTC issued Notice of Proposed Rulemaking (comment period opened)
October 24, 2025 Deadline
- Comment period deadline (ISDA and SIFMA submitted comments on this date)
December 18, 2025
- CFTC approved final rule (subject to pre-publication technical corrections)
Suggested considerations
*Immediate Actions (Pre-Implementation)
*Implementation Actions (Upon Effective Date)
trade disclosure systems to remove PTMMM generation and delivery requirements
based operations, review implications of superseded Staff Letter No. 23-01
*Ongoing Compliance
What changed
The final rule introduces the following substantive amendments:
Exceptions for Swaps Intended to be Cleared (ITBC Swaps)
Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution.
This regulatory update from the CFTC involves a fraud and misappropriation scheme, which impacts banking, capital markets, and crypto firms. It covers AML/financial crime, consumer protection, and licensing issues, making it a high priority for relevant firms.
The Federal Financial Supervisory Authority BaFin warns against offers, in particular offers to purchase shares and alleged pre-IPO shares, which are purportedly brokered by Ambassador. According to information available to BaFin, Ambassador Management GmbH, supposedly based in Frankfurt am Main, Ambassador Financial…
Why this matters
This regulatory update from BaFin warns against unauthorized financial services and investment offers, which poses risks of fraud and consumer harm. It is relevant for banking, wealth management, and fintech firms that need to be aware of such scams and ensure proper licensing and authorization.
The financial supervisory authority BaFin is warning against WhatsApp and Telegram groups where consumers are lured into trading cryptocurrencies via the fraudulent trading platform TradeNova, which can currently be accessed through the website m.tradenovaeo(.)com. According to their findings, the trading platform…
Why this matters
This regulatory update from BaFin warns about a fraudulent cryptocurrency trading platform called TradeNova that is operating without authorization. This poses risks related to financial crime, consumer protection, and regulatory compliance for crypto firms and fintechs.
The Artificial Intelligence Consortium (AIC) aims to provide a platform for public-private engagement to further dialogue on the capabilities, development, deployment, use, and potential risks of artificial intelligence (AI) in UK financial services.
Why this matters
This regulatory update discusses the Artificial Intelligence Consortium, which aims to facilitate dialogue on the development and use of AI in UK financial services.
Exchange of letters between the Governor and the Chancellor
Why this matters
This exchange of letters between the Governor and Chancellor regarding CPI inflation is relevant for banks, asset managers, and wealth managers as it relates to prudential requirements, reporting, and consumer protection issues around inflation.
Provisional dates for Monetary Policy Committee (MPC) announcements on Bank Rate and publication of MPC meeting minutes and the quarterly Monetary Policy Report.
Why this matters
This regulatory update provides information on the provisional dates for Monetary Policy Committee announcements, which is relevant for banks, asset managers, and wealth managers that need to monitor monetary policy decisions. The content is informational in nature, so the urgency is low.
The Bank of England’s Monetary Policy Committee is responsible for making decisions about Bank Rate.
Why this matters
This regulatory update from the Bank of England relates to changes in the Bank Rate, which is a key monetary policy tool that impacts banks, investment managers, and wealth managers. The update is of medium urgency as it provides important information about the central bank's policy decisions.
We're expanding the significant work we had planned to improve standards in the home and travel insurance markets, following Which?’s super complaint. Read our response to Which? (PDF)While 79% of consumers who make an insurance claim are satisfied with how it was handled, our work shows there's room for improvement …
AI Analysis
The FCA is expanding its planned supervisory work in home and travel insurance markets in response to a Which? super complaint, focusing on improving claims handling, information provision, and overall standards. This matters for compliance professionals as it intensifies scrutiny under Consumer Duty, requiring firms to demonstrate better consumer outcomes amid ongoing simplification of insurance rules. It signals heightened FCA expectations for evidence-based improvements in customer satisfaction and transparency.
Key dates
Over the next year (from publication, approx. late 2025)
- FCA to conduct expanded reviews on claims handling, information provision, and standards improvement
2026
- FCA to decide on changes to GAP insurance product-specific rules
Q2 2026
- FCA consultation on removing non-UK customers from Consumer Duty scope, with parallel review of ICOBS and PROD application
H1 2026
- FCA consultations on Consumer Duty amendments for distribution chains and UK customer focus
September 2026
- Conduct Rules (COCON) expand to non-financial misconduct
Suggested considerations
Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews.
Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data.
Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers.
Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness.
Retain records, respond to FCA data requests, and invest in governance/MI for supervision.
What changed
This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
Improving claims handling through reviews of firms' processes.
Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns, as...
Compliance impact
Urgency: High - This expands active FCA supervision in 2026, overlapping with Consumer Duty embedding and insurance simplification; non-compliance risks intensified reviews, enforcement, or redress schemes (as seen in motor finance). Firms gain flexibility but face accountability for outcomes, with scrutiny on data quality and vulnerability handling amplifying risks in a trust-based regime.
The Financial Supervisory Authority BaFin has issued warnings regarding offerings found on websites maxfuledge(.)com and trading-area.maxfuledge-v2(.)com/auth/register. Based on its investigations, the purportedly London or Singapore-based trading platform MaxFulEdge offers unauthorised financial services, securities…
Why this matters
This regulatory warning from BaFin relates to a potentially fraudulent trading platform offering unauthorized financial services, securities transactions, and cryptocurrency-related services. This poses risks to consumers and requires prompt action by the relevant firms and regulators.
The Federal Financial Supervisory Authority BaFin warns against offers on the website senvix(.)de. According to information available to BaFin, the trading platform Senvix, allegedly based in Frankfurt, is providing financial, investment and crypto asset services without the required authorisation.
Why this matters
This regulatory update from BaFin warns against unauthorized financial and crypto asset services being offered on the website senvix(.)de, indicating potential consumer protection and licensing issues.
Krypto Holdings Ltd., allegedly based in Frankfurt am Main and Widnau, Switzerland, offers crypto asset services on its website krypto-holdings(.)com and via unsolicited telephone calls and emails. The necessary authorisation for this has not been granted.
Why this matters
This regulatory update from BaFin warns against unauthorized crypto asset services offered by Krypto Holdings Ltd. on its website. This is a high urgency issue as it relates to firms operating without the necessary regulatory authorization, which poses risks to consumers.
The Securities and Futures Commission (SFC) successfully prosecuted Mr. Choi Chun Wai, former Vice President of Computershare Hong Kong Investor Services Limited, for insider dealing in ENM Holdings Limited shares, resulting in a two-month prison sentence, a HK$289,500 fine (equal to avoided losses), and HK$120,407 in SFC investigation costs on 18 December 2025. This enforcement action highlights the SFC's aggressive stance against market professionals misusing non-public information, serving as a deterrent to uphold Hong Kong's market integrity. Compliance teams should note it reinforces personal liability for insider dealing under the Securities and Futures Ordinance (SFO), even for those in support roles like proxy coordination.
Key dates
2 June 2023
- ENM and Offeror announced proposed privatization, engaging Computershare for proxy and voting services
22 September 2023
- Choi learned inside information on privatization failure from proxy forms
25 September 2023
- Choi sold 1,500,000 ENM shares, avoiding HK$289,500 loss ahead of announcement
26 September 2023
- Scheduled court meeting for privatization voting
27 September 2023
- ENM announced privatization lapse; share price fell 10.26% to HK$0.35
Suggested considerations
Enhance insider dealing training: Mandate annual refreshers for staff handling corporate actions, emphasizing SFO prohibitions on dealing with inside information (e.g., voting outcomes, privatization status).
Strengthen information barriers: Implement robust Chinese walls between operational teams (e.g., proxy coordinators) and personal trading, with pre-approval for staff trades in client-related securities.
Monitor personal trading: Require disclosure and review of employees' holdings in companies involved in serviced transactions; automate alerts for unusual trading pre-announcements.
Conduct insider lists and attestations: Maintain accurate lists of insiders during corporate events; require signed attestations of non-dealing.
Audit workflows: Review processes for proxy form handling and voting scrutiny to prevent incidental access to inside information.
What changed
This is an enforcement case, not a regulatory change; no new rules, requirements, or amendments to the SFO or Listing Rules were introduced. It exemplifies ongoing application of existing insider dealing prohibitions under SFO sections 270-271, where individuals with inside information (e.g., on privatization failure from proxy forms) must not deal in relevant securities. The court's emphasis on "immediate custodial sentence" for professionals in positions of trust signals stricter sentencing norms for such offenses.
Compliance impact
Urgency: Medium - This reinforces existing obligations rather than imposing new ones, but the custodial sentence for a mid-level professional elevates personal risk awareness, prompting immediate policy reviews to mitigate SFC scrutiny. It matters for firms in investor services or with staff in trust positions, as SFC vows "robust enforcement" amid a spate of market abuse cases, potentially increasing surveillance and investigations.
The Securities and Exchange Commission today announced that financial economist and academic scholar Dr. Joshua T. White will return to the agency beginning the week of Jan. 5, 2026, to serve as its Chief Economist and Director of the Division of…
Why this matters
This regulatory update announces the appointment of a new Chief Economist at the SEC, which is relevant for banking, investment management, and capital markets firms that are subject to SEC oversight and reporting requirements.
The Securities and Exchange Commission’s Office of the Investor Advocate today delivered its Report on Activities for the Fiscal Year 2025 to Congress, highlighting the initiatives and work of the office during the fiscal year.The report includes:An…
Why this matters
This regulatory update from the SEC's Office of the Investor Advocate covers activities related to investment management, capital markets, and crypto/digital assets. It focuses on consumer protection, reporting/disclosure, and technology/cyber issues, which are relevant to a wide range of financial firms.
The FCA welcomes the Government’s consultation on a new benchmarks regime for the UK. Since the introduction of the current regulatory framework, the financial landscape has evolved significantly. We now have an opportunity to build a regime that is more targeted to current market conditions and to reduce unnecessary…
AI Analysis
The FCA welcomes HM Treasury's consultation on reforming the UK Benchmarks Regulation (BMR) to create a narrower, risk-based **Specified Authorised Benchmarks Regime (SABR)**, reducing regulatory scope by 80-90% to target only systemically important benchmarks and administrators while easing burdens on industry. This matters for compliance professionals as it shifts from broad regulation of all benchmarks to targeted oversight, requiring firms to reassess benchmark usage, prepare for transition, and adapt to FCA rules on risk management, enhancing UK competitiveness post-FSMA 2023 repeal of assimilated laws.
Key dates
17 December 2025
- HM Treasury publishes consultation on benchmarks regime reform
1 January 2026
- Reforms take initial effect; UK becomes only jurisdiction regulating all local benchmarks pre-reform; EU BMR reforms effective, highlighting UK divergence
Due course 2026 Deadline
- FCA consults on regulatory requirements for designated administrators/users
2026
- FCA expected to publish updated guidance on critical benchmarks and implement SABR refinements
Suggested considerations
Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios.
Participate in HMT consultation (responses via gov.uk) and prepare for FCA consultation on rules.
Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance.
Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility.
Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules.
What changed
- Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or...
FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; removes legislative obligations on users to only...
Overseas benchmarks: Replaces equivalence/endorsement with Overseas Recognition Regime (ORR); designated overseas administrators may avoid dual regulation if ORR-eligible.
No opt-in: Non-designated benchmarks/administrators unregulated; contributor obligations shift to FCA rules.
Enhanced FCA powers: Potential extension to intervene/wind-down designated benchmarks and direct firms to restrict usage; may cover non-price data like ESG metrics.
Compliance impact
Urgency: High - Significant scope reduction eases burdens but introduces transition risks, new FCA rules, and designation uncertainty; firms must act now on consultation (post-Dec 2025) and prep for 2026 FCA changes to avoid non-compliance during shift, especially with 1 Jan 2026 milestone amplifying competitiveness pressures.
This regulatory update from the ECB proposes to extend the term of the Vice-Chair of the Supervisory Board, which is relevant for banking and investment management firms subject to ECB supervision. The topics of prudential requirements and senior management governance are key areas of focus.
Index-linked treasury stocks are gilts issued by the UK Government. They pay out twice a year, with the amount indexed to the Retail Prices Index.
Why this matters
This regulatory update is about index-linked treasury stocks, which are gilts issued by the UK government. This information is relevant for banking, investment management, and capital markets firms that may hold or trade these securities.
This appears to be a general news update from CBI covering regulatory developments across multiple financial sectors and topics. The lack of a detailed description suggests this is informational content rather than a critical regulatory change.
Tava Loans - Central Bank of Ireland Issues Warning on Unauthorised Firm
Why this matters
This regulatory update from the Central Bank of Ireland warns about an unauthorized firm operating in the banking, consumer credit, and mortgage lending sectors. This is a high urgency issue as it relates to consumer protection and the need for proper authorization and licensing of financial firms.
Ava Credit Finance - Central Bank of Ireland Issues Warning on Unauthorised Firm
Why this matters
This is a warning from the Central Bank of Ireland about an unauthorized firm operating in the banking, consumer credit, and mortgage lending sectors. This is a high urgency issue as it relates to consumer protection and the proper authorization of financial firms.
This regulatory update relates to a former executive of a financial firm being jailed for false trading, which falls under the sectors of banking, capital markets, and wealth management.
ESMA reviews impact of Guidelines on ESG or sustainability related terms in fund names 17 December 2025 Risk monitoring Sustainable finance The European Securities and Markets Authority (ESMA), the EU’s financial market regulator and supervisor, released research today assessing the impact of its fund naming…
Why this matters
This regulatory update from ESMA focuses on the impact of guidelines related to the use of ESG and sustainability-related terms in fund names, which is relevant for investment management firms and wealth managers.
This regulatory update from the ECB provides supervisory banking statistics on significant institutions, which is relevant for banks, asset managers, and wealth managers in terms of prudential requirements, reporting, and licensing.
This regulatory update from the ECB appears to be focused on supervisory banking statistics for significant institutions, which is relevant for banks, asset managers, and wealth managers in terms of prudential requirements, reporting, and operational resilience.
amending Circular CSSF 22/811.Authorisation and organisation of entities acting as UCI administrators.
AI Analysis
Circular CSSF 25/900, issued on 16 December 2025, amends Circular CSSF 22/811 to clarify governance principles, authorisation requirements, and operational standards for UCI (Undertakings for Collective Investment) administrators in Luxembourg, while reforming annual reporting obligations. It matters because it strengthens supervisory oversight, aligns with DORA for ICT outsourcing, and simplifies reporting to enhance efficiency and compliance in the fund administration sector.
Key dates
January 2025
- DORA entry into force, applying to ICT outsourcing for in-scope UCIAs
16 December 2025
- Issuance date; repeal of Annex B of Circular CSSF 22/811 effective immediately
31 December 2025
- New reporting framework (SAQ and updated modalities) applies to all financial years ending on or after this date
Suggested considerations
Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations.
Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025.
Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750).
For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882.
What changed
- Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses...
Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authorisation remains...
Clarifies scope for eligible entities (e.g., UCIs, IFMs, management companies under Luxembourg law) performing one or more of three UCI administration functions (defined in point 10); mandates...
Aligns ICT outsourcing with DORA (effective January 2025) for in-scope UCIAs (credit institutions, investment fund managers, investment firms, certain support professionals), referencing Circular...
Strengthens delegation rules (section 3.5): prior CSSF notification for critical/important tasks, ongoing monitoring by UCI/IFM, and remediation plans for shortcomings.
Compliance impact
Urgency: High - Immediate repeal of prior reporting Annex requires prompt process updates; new framework applies to FY 2025 year-ends (just past as of Jan 2026), risking supervisory scrutiny or penalties for non-compliance; DORA alignment adds operational resilience pressure amid ongoing CSSF focus on fund admin governance.
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its former director a total of €500,000
AI Analysis
The AMF Enforcement Committee fined asset management company Novaxia Investissement €400,000 and its former director Joachim Azan €100,000 on 10 December 2025 for breaches of professional obligations, primarily due to an incomplete and non-operational investment/divestment procedure lacking traceability of compliance checks and formalized due diligence. This enforcement action underscores AMF's focus on robust operational procedures in asset management, serving as a deterrent and educational tool for ensuring honest, fair, and diligent business conduct. Compliance teams should prioritize procedure operationalization to avoid similar sanctions, as this fits a pattern of recent AMF fines targeting procedural deficiencies.
Key dates
10 December 2025 Deadline
- AMF Enforcement Committee decision date imposing fines; appeals possible (no specific deadline stated, but typically within 2 months to Conseil d’État)
Suggested considerations
Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e.g., alignment with fund policies), and formalized pre-allocation due diligence; test for operationality via internal audits.
Document all processes rigorously: Maintain evidence of checks and due diligence to demonstrate skill, care, and diligence in line with authorization conditions.
Conduct gap analysis against AMF expectations: Cross-reference with similar cases (e.g., operational procedures, AML/CFT); remediate deficiencies promptly.
Senior manager training: Reinforce personal accountability for firm compliance; update governance frameworks.
Appeal monitoring: If similarly positioned, prepare for potential appeals to Conseil d’État.
What changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including:
Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints.
Formalized due diligence prior to allocating investment projects to funds.
No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completeness and documentation,...
Compliance impact
Urgency: High – This decision, part of a 2025 enforcement wave fining asset managers €400k–€1.3m for procedural lapses (e.g., non-operational investment processes, inadequate due diligence), signals intensified AMF scrutiny on operational integrity. Firms risk personal fines for managers and reputational damage; immediate procedure audits are essential to mitigate exposure, especially pre-authorization renewals or fund launches.
Open banking in the UK is growing rapidly. Latest industry figures show there are more than 16 million users now benefiting from the service. The number of open banking payments has soared by 53% year on year, reflecting a significant shift in how consumers and businesses manage their finances.See the API performance…
Why this matters
This regulatory update from the FCA discusses the growth of open banking in the UK, including the rise of variable recurring payments. This is relevant for banking, payments, and fintech firms that are involved in or impacted by open banking initiatives.
We’re seeking feedback on whether tailored market risk rules for non-bank trading firms could remove unnecessary barriers, free up capital and attract new market participants, ultimately supporting economic growth. The rules in place today were originally designed for banks to ensure they held enough capital to absorb…
Why this matters
The regulatory update discusses potential changes to market risk rules for non-bank trading firms, which could impact capital requirements and licensing for broker dealers and hedge funds operating in capital markets.
We are asking for views on new proposals as the next step in shaping the UK’s crypto rules. These proposals continue our progress towards an open, sustainable and competitive crypto market that people can trust. We want a market where innovation can thrive, but where people understand the risks. Regulation cannot …
On 16 December 2025, the Swiss Financial Market Supervisory Authority FINMA launched the consultation on the partially revised Circular 2016/7 “Video and online identification”. The consultation will go on until 27 February 2026.
Authorisation and organisation of entities acting as UCI administrators
AI Analysis
Circular CSSF 22/811, as amended by Circular CSSF 25/900, establishes CSSF requirements for the authorisation, governance, internal organisation, and oversight of entities acting as UCI (Undertakings for Collective Investment) administrators in Luxembourg. It matters because it standardises practices amid regulatory, technological, and market evolutions, ensuring robust controls, risk management, and supervision for fund administration activities critical to Luxembourg's fund industry.
Suggested considerations
Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated.
Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function.
For delegations: Conduct due diligence, execute written contracts detailing roles/obligations, notify CSSF in advance, retain oversight without delegating monitoring.
Conclude written contracts with UCI/IFM; submit annual UCIA activity reports.
UCIs/IFMs: Supervise coordinators, ensure information exchange/cooperation with administrators.
What changed
- Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure;...
Scope of UCI Administration: Defines three core functions—registrar, NAV calculation/accounting, and client communication—requiring only one designated service provider per function per UCI (or...
Governance and Controls: Mandates sound governance principles, control frameworks, escalation processes for errors/incidents, adequate resources (human, ICT), business continuity, and compliance with...
Delegation Rules: Delegation of tasks allowed but not of monitoring/oversight; requires written contracts, due diligence, and prior CSSF notification (3 months generally, 1 month for certain agents);...
Contracts and Reporting: Written contracts between UCI administrator and UCI/IFM; annual activity reporting due 5 months after financial year-end, starting from financial years ending post-30 June...
Compliance impact
Urgency: High – Non-compliance risks CSSF sanctions, as authorisation is prior and ongoing; critical for Luxembourg fund ecosystem given evolutions in tech/markets/DORA. Firms must act promptly if unauthorised or misaligned, especially with annual reporting since 2023 and DORA integration; impacts operational models, delegations, and reporting immediately for active administrators.
This circular provides guidance on how financial institutions should report incidents to MAS under the various acts, regulations, notices, circulars and guidelines.
AI Analysis
This MAS circular updates the incident reporting process for financial institutions (FIs), mandating use of a revised template on the MAS-Tx platform for reportable incidents starting 1 February 2026. It standardizes initial notifications and follow-up submissions under applicable regulations, enhancing supervisory efficiency amid rising technology risks. Compliance is critical as it aligns with MAS's focus on operational resilience, with non-adherence risking enforcement actions seen in recent AML/CFT penalties.
Key dates
16 December 2025
- Circular published, announcing updated template and process
1 February 2026
- Mandatory use of updated FI Incident Reporting Template on MAS-Tx for all subsequent incident reports (initial notifications follow existing prescribed timelines). https://www.mas.gov.sg/regulation/circulars/circular-on-financial-institution-incident-reporting
Suggested considerations
Review and familiarize with the updated FI Incident Reporting Template (downloadable from MAS site).
Integrate MAS-Tx platform access and training for compliance, IT, and risk teams to handle submissions.
Update internal incident response plans to ensure initial notifications occur "as soon as possible but no later than prescribed timelines" under relevant rules (e.g., Technology Risk Management Notices), followed by template-based reports via MAS-Tx post-1 February 2026.
Conduct gap analysis against related TRM Notices (e.g., FSM-N05 for banks, FSM-N25 for trust companies) to align incident detection and reporting. https://panorays.com/blog/mas-trm-compliance/
Test processes via simulations, as recommended in TRM guidelines for incident response readiness. https://panorays.com/blog/mas-trm-compliance/
What changed
- Updated Reporting Template: FIs must use the new FI Incident Reporting Template (65.8 KB) for submitting details of reportable incidents on MAS-Tx, replacing prior formats.
Dual Reporting Process: Initial notification required "as soon as possible, but no later than the timeline prescribed" in relevant acts, regulations, notices, circulars, or guidelines; followed by...
Platform Mandate: All subsequent reports must be filed through MAS-FI Transactions Platform (MAS-Tx), streamlining MAS oversight.
Compliance impact
Urgency: High – With the effective date of 1 February 2026 now passed (as of current date), non-compliant FIs risk immediate supervisory scrutiny, fines, or enforcement, as evidenced by MAS's S$27.45 million penalties on nine FIs for AML/CFT breaches in 2025. This matters because it operationalizes broader TRM frameworks amid cyber threats, where delayed reporting could amplify disruptions and invite actions like licence revocations. https://www.twobirds.com/en/insights/2025/singapore/mas-takes-robust-regulatory-actions-against-nine-financial-institutions-and-revokes-a-capital-market
Earlier this year, we undertook a refresh of our Sustainable Finance Advisory Committee. In line with good governance, we planned to refresh the membership on a staggered basis, allowing us to bring in new expertise whilst benefiting from some continuity. Following this process, we are pleased to announce the…
Why this matters
This regulatory update announces the appointment of new members to the FCA's Sustainable Finance Advisory Committee, which is relevant for investment management, wealth management, and other financial firms with an interest in ESG and sustainability.
15 DEC 2025, 03:03 PM
DFSA issues updated rules on the regulation of Crypto Tokens in the DIFC
Why this matters
The regulatory update from the DFSA focuses on the regulation of crypto tokens in the Dubai International Financial Centre (DIFC). It introduces changes to the existing crypto token framework, including a shift away from a prescribed list of recognized crypto tokens and enhanced investor safeguards.
An update on our investigation into Mirabella Advisors LLP. On 4 May 2021, we announced that we had opened an investigation into the oversight of Greensill Capital Securities Limited, an appointed representative, by its principal, Mirabella Advisors LLP. Our investigation reviewed the nature, conduct and scope of…
AI Analysis
The FCA has closed its investigation into Mirabella Advisors LLP's oversight of its appointed representative (AR), Greensill Capital Securities Limited, finding no breaches warranting further action. This closure, announced after reviewing Mirabella's business nature, conduct, and scope, signals effective AR oversight in this high-profile case tied to the Greensill collapse, while Mirabella voluntarily cancelled its authorisation effective 12 September 2025. It matters for compliance professionals as it reinforces FCA expectations on principal-AR relationships without imposing new penalties or rules, but underscores ongoing scrutiny in trade finance and supply chain finance sectors.
Key dates
4 May 2021
- FCA announced opening of investigation into Mirabella's oversight of Greensill Capital Securities Limited as AR
12 September 2025
- Mirabella's authorisation cancelled; firm no longer provides financial services
What changed
There are no new regulatory changes, requirements, or rules introduced by this publication. The statement solely announces the closure of an existing investigation with no identified breaches by Mirabella, maintaining the status quo on AR oversight obligations under FCA rules such as SUP 12 (Appointed Representatives). The FCA reserves the right to reopen if new information emerges, but no policy shifts or guidance updates are provided.
Compliance impact
Urgency: Low - This is a positive closure with no findings of misconduct, new rules, or enforcement, reducing immediate compliance burdens. It matters indirectly by exemplifying robust AR oversight meeting FCA standards amid Greensill fallout, offering reassurance for similar firms while signaling continued vigilance (e.g., potential reopening). Compliance teams should note it for precedent in AR due diligence but prioritize higher-risk areas like ongoing FCA trade finance financial crime probes.
With over 20 years’ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'That’s a fair question – enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as…
AI Analysis
This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.
Suggested considerations
Embed proactive monitoring: Regularly review customer outcomes under Consumer Duty, acting on foreseeable harm (e.g., communication barriers, vulnerable customer support).
Respond swiftly to FCA contact: Engage with supervision teams on identified issues; prepare for tools like skilled person reviews or voluntary restrictions.
Improve practices market-wide: Use FCA guidance (e.g., good/poor examples) to self-assess; ensure clear information, fair value, and accessible support.
Evidence compliance: Map business to Consumer Duty, monitor biases, and demonstrate senior manager oversight via SM&CR.
Facilitate redress: Identify and pay compensation promptly when issues arise, as seen in FCA interventions (£200m vehicle claims; £350k home insurance).
What changed
No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
Examples from insurance (e.g., stolen vehicle claims yielding £200m redress; home emergency cover improvements reducing complaints by 61%).
Compliance impact
Urgency: Medium – This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive firms to s.166 reviews (costly, used 20+ times in insurance since 2022) or restrictions, impacting reputation and finances. Firms with consumer-facing products must audit processes now to align with "good outcomes" expectations.
Der Bundesrat hat am 12. Dezember 2025 beschlossen, die Iran-Sanktionen dem Stand von vor dem Abschluss des Wiener Abkommens über das iranische Atomprogramm anzupassen. Dazu hat er die Verordnung über Massnahmen gegenüber der Islamischen Republik Iran einer Totalrevision unterzogen. Die neue Verordnung (SR…
AI Analysis
Switzerland has completely revised its Iran sanctions regulations effective December 12, 2025, restoring sanctions to pre-2015 levels following the automatic reinstatement of UN Security Council resolutions on September 28, 2025. This comprehensive overhaul requires Swiss financial institutions and businesses to immediately implement expanded asset freezes, trade restrictions, and sectoral prohibitions affecting Iran-related transactions and designated persons.
Key dates
September 28, 2025
- UN Security Council resolutions automatically reinstated (snapback mechanism triggered)
September 29, 2025
- EU reactivated suspended sanctions on Iran's proliferation activities
October 20, 2025
- Swiss State Secretariat for Economic Affairs (SECO) updated SESAM sanctions database with reinstated listings
October 21, 2025
- Updated sanctions list effective (23:00 UTC)
December 12, 2025
- Complete revision of Iran sanctions ordinance (SR 946.231.143.6) entered into force (23:00 UTC)
Suggested considerations
*Immediate (Completed by December 12, 2025):
related transactions and accounts for compliance with expanded prohibitions
*Short-term (By January 1, 2026):
September 30, 2025 contracts under legacy exemption provisions
related transactions
What changed
The total revision introduces several critical regulatory shifts:
Scope Expansion: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803,...
Since the banking turmoil of 2023, the Committee has worked to strengthen supervisory effectiveness in relation to material risks that could result in financial losses, impacting the safety and soundness of financial institutions.
Why this matters
This is an informational newsletter from the Basel Committee on Banking Supervision (BCBS) documenting supervisory cooperation and best practices following the 2023 banking turmoil.
First-time buyers and the self-employed could get a step-up onto the housing ladder, under new plans from the FCA. Its priorities for reforms to the mortgage market also include helping homeowners unlock housing wealth for a more comfortable later life.The FCA will focus on 4 areas:First-time buyers & underserved…
Why this matters
This regulatory update from the FCA focuses on reforms to the mortgage market, particularly to help first-time buyers and the self-employed access more flexible mortgage products. It also covers plans to review later-life lending.