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.
This speech by the CFTC Acting Chairman is likely to cover regulatory developments and priorities related to banking, capital markets, and the crypto/digital assets sector.
Governance Annual report Executive & other private individuals Journalists Listed companies and issuers The AMF examines the transparency of executive succession plans as part of its 2025 Corporate Governance Report
Why this matters
This regulatory update from the AMF examines the transparency of executive succession plans, which is relevant for banking, investment management, and wealth management firms. It touches on reporting and disclosure requirements as well as senior management and governance topics.
Der Bundesrat hat die Sanktionslisten betreffend Russland und Belarus am 12. Dezember 2025 ausgeweitet. Die Schweiz übernimmt damit diverse Änderungen, welche die EU im Rahmen ihres 19. Sanktionspakets beschlossen hat.
AI Analysis
The Swiss Federal Council expanded sanctions lists against Russia and Belarus on December 12, 2025, adopting changes from the EU's 19th sanctions package to align Swiss measures with EU restrictions. This matters for Swiss financial institutions as it imposes immediate asset freezes, transaction bans, and reporting obligations on newly listed entities, strengthening efforts to counter Russia's military-industrial complex and shadow oil fleet while preventing sanctions evasion.
Key dates
29 October 2025
- Prior expansion decision (related 18th EU package adoption)
30 October 2025
- Entry into force of October measures (export restrictions, RDIF transaction bans)
13 December 2025 Deadline
- Measures enter into force; immediate implementation required
31 December 2025
- Extension of certain derogations (e.g., Russia investment withdrawals)
Suggested considerations
Immediate screening: Review client lists, transactions, and assets against updated SECO sanctions lists (published by WBF) for matches to 22 persons, 42 entities, 116 vessels, 45 export-controlled firms, 5+4 banks, and 8 third-country firms.
Asset freezing: Block and freeze any matching assets/funds; prohibit making available.
Transaction halts: Cease dealings with listed banks, entities, vessels, or sanctioned goods/services.
Reporting: Notify SECO of frozen assets, blocked transactions, or existing business relationships immediately; conduct additional due diligence on suspicions per Art. (FINMA guidelines).
Ongoing monitoring: Update compliance systems for dynamic lists; train staff on shadow fleet risks and third-country evasion.
What changed
- Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists.
Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans.
Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector.
Financial transaction bans: Five Russian banks and four branches of Russian banks in third countries banned from transactions, especially those using Russian payment systems; eight third-country...
Compliance impact
Urgency: Critical - Effective immediately (13 Dec 2025), with no grace period for asset freezes/transaction bans, exposing non-compliant firms to severe penalties amid FINMA's active enforcement on sanctions (type: enforcement). This escalates existing Russia/Belarus regimes, targeting evasion vectors like shadow fleets and third-country facilitators, demanding urgent system updates given the volume of new listings (225+ entities/vessels).
The Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) today published a report that reviews the implementation of margin requirements for non-centrally cleared derivatives.
Why this matters
This is a published assessment by BCBS and IOSCO reviewing implementation of the 2013 margin requirements standard for non-centrally cleared derivatives. The report confirms the framework is working effectively, finds no material issues, and proposes no changes—making it informational rather than prescriptive.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
This Statistical Notice 2025/06 announces the release of Bank of England Statistics Taxonomy version 1.3.1, which updates definitions and guidance in the Banking Statistics Yellow Folder, including upgrades from XBRL 2.3.0 to 3.0, validation fixes, and data point model changes. It matters for compliance teams at reporting firms as it ensures accurate submission of statistical data to the BoE, supporting monetary policy, financial stability monitoring, and national accounts under the Bank of England Act 1998.
Key dates
Provisional UAT windows (two proposed)
- User Acceptance Testing periods for validating the new taxonomy 1.3.1; exact dates to be confirmed via BoE updates
Suggested considerations
Review and update reporting systems to support XBRL 3.0, incorporating validation fixes and DPM changes.
Participate in the two proposed UAT windows to test submissions under the new taxonomy.
Subscribe to or amend BoE Statistical Notices circulation list to receive updates.
Cross-reference against the Banking Statistics Yellow Folder for any definitional impacts on ongoing returns.
What changed
- Upgrade of the reporting taxonomy from XBRL 2.3.0 to XBRL 3.0, introducing technical enhancements for improved data structure and interoperability.
Validation fixes to address errors in data submission processes.
Changes to the data point model (DPM), refining how specific data elements are defined and reported.
These updates align with ongoing refinements to the Banking Statistics Yellow Folder, which contains core definitions for BoE statistical returns.
Compliance impact
Urgency: Medium - This is a technical taxonomy update rather than a substantive regulatory shift, but non-compliance risks invalid submissions, data rejection, or delays in BoE reporting, which could affect supervisory assessments and national statistics. Firms with automated reporting pipelines face moderate implementation effort, especially for XBRL migration, but proactive UAT participation mitigates risks.
Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and…
AI Analysis
The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.
Key dates
2014
- CBI enforcement investigation into Mr Smith and RSAII commences
December 2018
- CBI reprimands and fines RSAII €3.5m for related breaches, including reserve failures
November 2022
- CBI decides to hold an Inquiry into Mr Smith's participation under Part IIIC of the Central Bank Act 1942
1 December 2025
- Reprimand and 13-year disqualification imposed on Mr Smith, effective immediately under IAF Act transitional provisions (no High Court confirmation needed)
12 December 2025
- CBI publishes public statement on the enforcement action
Suggested considerations
Conduct internal audits of large loss claim reserving processes to verify compliance with Article 13(1)(a) of the 1994 Regulations, ensuring estimates are accurately recorded in databases without undocumented overrides.
Review senior management oversight of claims handling; document all approvals and prohibit informal (e.g., in-person or hard-copy only) processes that bypass controls.
Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios.
Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines).
Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments.
What changed
This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities.
Compliance impact
Urgency: High – This action signals intensified CBI scrutiny on individual accountability in insurance reserving, with 13-year bans possible for deliberate breaches risking policyholders, even without actual losses. It matters now (post-1 Dec 2025 effective date) as firms face elevated enforcement risk amid CBI's "full extent of powers" approach, potentially leading to parallel firm/individual sanctions and long inquiries; proactive reviews prevent similar outcomes, especially with statutory fine limits not mitigating non-financial penalties.
We're providing guidance to support firms to tackle bullying, harassment and violence in financial services, after they asked for additional support. In July, we changed our rules – setting clearer standards for how financial services firms should address non-financial misconduct.This more closely aligned the rules…
Why this matters
This regulatory update from the FCA provides guidance to financial services firms on addressing serious non-financial misconduct, such as bullying, harassment and violence. It is relevant for banking, investment management and wealth management firms, as well as the broader financial services industry.
The Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) today published a review of the implementation of the framework for margin requirements for non-centrally cleared derivatives.
Why this matters
The BCBS and IOSCO review of margin requirements for non-centrally cleared derivatives is a substantive assessment of an existing post-2008 framework. The finding of no material issues and recommendation for continued supervisory monitoring represents concrete regulatory guidance, but the absence of new obligations or...
This regulatory update from the ECB indicates that they will be assessing banks' stress testing capabilities to capture geopolitical risk. This is relevant for banking, investment management, and wealth management firms, as they will need to ensure their risk management frameworks are robust enough to handle potential...
11 DEC 2025, 06:08 PM
Notice of Consultation Paper Release: CP 169
Why this matters
This regulatory update from the DFSA announces the release of a consultation paper on miscellaneous topics, which is likely to impact banking, investment management, and wealth management firms operating in the Dubai International Financial Centre (DIFC).
11 DEC 2025, 05:55 PM
Notice of Amendments to Legislation: December 2025
Why this matters
This regulatory update from the DFSA includes amendments to the DFSA Rulebook that will impact various financial services firms operating in the Dubai International Financial Centre (DIFC).
This appears to be a general regulatory news update from CBI covering multiple financial sectors and topics, so a low urgency classification is appropriate.
David Roberts has been reappointed as Chair of the Court of the Bank of England by His Majesty the King
Why this matters
This regulatory update announces the reappointment of key individuals to the Bank of England's Court of Directors, which is relevant for banks and wealth managers from a governance and regulatory oversight perspective.
MiCA Crypto-assets Financial products Marketing Journalists Investment management companies Listed companies and issuers The AMF adapts its policy on complex financial products in response to the rise of crypto-assets
Why this matters
This regulatory update from the AMF (French financial markets authority) relates to the adaptation of its policy on complex financial products in response to the rise of crypto-assets. This impacts crypto exchanges, asset managers, and fintech firms operating in the crypto/digital assets space.
Given at the 20th High-level meeting on financial stability and regulatory and supervisory priorities (jointly organised by the Arab Monetary Fund, the Basel Committee on Banking Supervision and the Financial Stability Institute of the Bank of International Settlements).
Why this matters
This speech discusses the need to promote innovation in the financial sector while also guarding against financial stability risks. It covers topics related to prudential requirements, technology and cyber risks, as well as authorization and licensing for financial firms.
This regulatory update from the ECB proposes simplification of EU banking rules, which would impact banks, asset managers, and wealth managers in the banking and investment management sectors. The key topics covered are prudential/capital requirements, operational resilience, and reporting/disclosure.
This regulatory update from the ECB focuses on streamlining and enhancing the effectiveness of European banking supervision, which is relevant for banks, asset managers, and wealth managers.
Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs der Verordnung vom 7. August 1990 über Wirtschaftsmassnahmen gegenüber der Republik Irak (SR 946.206) publiziert.
AI Analysis
This FINMA publication announces a SECO update to the annex of the Ordinance on Economic Measures against the Republic of Iraq (SR 946.206), reflecting UN Sanctions Committee amendments to the list of sanctioned individuals, companies, and organizations made on December 9, 2025. It matters because these changes are directly applicable in Switzerland, requiring financial intermediaries to immediately block affected assets and report business relationships to SECO to ensure compliance with UN sanctions. Failure to act risks enforcement by FINMA under its supervisory mandate.
Key dates
Immediate (as of December 10, 2025) Deadline
- Financial intermediaries must block assets and report to SECO without delay, per automatic application of UN sanctions
December 9, 2025
- UN Sanctions Committee decision amending the Iraq sanctions list
December 10, 2025
- SECO publishes update on its website and updates SESAM database; changes enter into force immediately in Switzerland
Suggested considerations
Screen against SESAM database: Immediately rescreen client portfolios, transactions, and business relationships against the updated Iraq sanctions list via SECO's SESAM tool (https://www.seco.admin.ch/sesam).
Asset freeze: Block and freeze any assets, funds, or economic resources belonging to newly sanctioned parties; do not dispose of or make available.
Report to SECO: Notify SECO of any matches or business relationships via the designated reporting channel within required timelines (typically immediate for freezes).
Internal review: Update compliance systems, screening tools, and policies; conduct targeted audits for Iraq/Middle East exposure; train staff on implementation.
Document compliance: Maintain records of screening, freezes, and reports for FINMA audits.
What changed
- The UN Sanctions Committee modified the sanctions list targeting persons, companies, and organizations related to Iraq on December 9, 2025; this amendment was published by SECO on its website and...
Switzerland automatically applies UN sanctions lists without delay per the Federal Council's Ordinance of March 4, 2016, making the update immediately binding.
Financial intermediaries must implement prohibitions, freeze assets of newly listed or adjusted entities, and notify SECO of any impacted business relationships, consistent with prior Iraq sanctions...
Compliance impact
Urgency: High - Automatic and immediate effect heightens breach risk, with FINMA enforcement powers including fines, reputational damage, or license revocation for non-compliance. It matters due to Switzerland's direct implementation of UN sanctions, amplifying AML/financial crime exposure amid ongoing global sanctions volatility (e.g., Iraq-related terrorism financing risks).
The Securities and Exchange Commission today charged Canadian citizen Nathan Gauvin and three entities he controls—Blackridge, LLC, Gray Digital Capital Management USA, LLC, and Gray Digital Technologies, LLC—with orchestrating two fraudulent securities…
Why this matters
This regulatory update from the SEC involves charges against a Canadian citizen for fraudulent securities schemes targeting retail investors on the Discord platform.
The Securities and Exchange Commission today announced the agenda and panelists for its Dec. 16, 2025, roundtable on Rule 611 of Regulation NMS and other associated rules and regulatory requirements.The roundtable will be held at the University of Austin…
Why this matters
This regulatory update from the SEC relates to Rule 611 of Regulation NMS, which governs order protection and market transparency requirements for broker-dealers.
Good evening. Thank you for the invitation to join you today. This evening I want to talk about economic resilience, what it is and whether we have enough of it. I spoke about economic resilience in my first speech as Governor – 6 years ago – and wrote to the Minister for Finance about it in early February this year…
Why this matters
This speech by the Governor of the Central Bank of Ireland discusses economic resilience, which is relevant to the banking, investment management, and wealth management sectors.
As part of its 2025-2026 work programme, the Basel Committee is advancing various supervisory initiatives related to the digitalisation of finance.
AI Analysis
The Basel Committee has published its Principles for the sound management of third-party risk, setting a common baseline for banks and supervisors as firms become more dependent on third-party service providers. The publication matters because it broadens the supervisory lens beyond traditional outsourcing to a wider range of third-party arrangements, with implications for governance, due diligence, contracts, monitoring, and exit planning.
Key dates
2025-12-10
Basel Committee publication date for the Principles for the sound management of third-party risk
Suggested considerations
Compliance teams may wish to map all third-party arrangements against the new lifecycle expectations, including non-traditional outsourcing and intra-group or technology-enabled arrangements.
Firms should consider whether board-approved third-party risk appetite, tolerance for disruption, and reporting lines are documented clearly and align with current governance arrangements.
Banks may wish to review due diligence, contracting, onboarding, monitoring, continuity, and exit procedures to confirm they address the principle-based expectations across the full relationship lifecycle.
Supervisory liaison teams may wish to assess whether concentration risk, critical provider dependencies, and cross-border coordination issues are adequately captured in existing risk registers and escalation frameworks.
What changed
The document sets out 12 principles covering the full third-party service provider lifecycle, divided between bank-facing expectations and supervisor-facing expectations. For banks, the principles cover governance and strategy, board and senior management oversight, risk assessment, due diligence, legally binding contracts, onboarding, ongoing monitoring, business continuity, and termination/exit management.
Compliance impact
The publication is a material supervisory signal rather than a binding rule, but it raises the expected standard for how banks identify, manage, and oversee third-party dependencies. Institutions that rely heavily on external providers may face closer supervisory scrutiny of governance, resilience, and concentration risk, especially where critical services are involved.
The Basel Committee has published principles for the sound management of third-party risk in the banking sector. The principles establish a common baseline for banks and supervisors for the sound management of third-party risk. The Committee will continue to monitor developments related to the digitalisation of…
AI Analysis
The Basel Committee published final principles for the sound management of third-party risk in the banking sector on 2025-12-10. The publication matters because it creates a common prudential baseline for banks and supervisors and explicitly supersedes the Basel/Joint Forum 2005 outsourcing paper for banking-sector purposes.
Key dates
2025-12-10
Basel Committee published the principles for the sound management of third-party risk
2024-10-09 Deadline
Comment deadline for the consultative version of the principles
Suggested considerations
Compliance teams may wish to compare existing outsourcing and third-party risk frameworks against the new 12-principle baseline to identify gaps in governance, lifecycle controls, and supervisor-facing documentation.
Firms may wish to review board and senior management oversight arrangements for third-party risk to ensure responsibilities, risk appetite, escalation, and reporting are clearly assigned.
Banks should consider whether their third-party inventories, risk assessments, due diligence files, contracts, monitoring processes, and exit planning are aligned to a full lifecycle model rather than a narrow outsourcing model.
Supervisory relations teams may wish to map the principles against home and host jurisdiction requirements to identify where local rules are already aligned or where additional supervisory engagement may be needed.
Operational resilience teams may wish to test whether critical third-party dependencies, including cloud and technology providers, are sufficiently captured in business continuity and termination planning.
What changed
The Basel Committee replaced the older 2005 Joint Forum outsourcing guidance with a new 12-principle framework focused on third-party service provider arrangements in banking. The framework is broader than traditional outsourcing and is designed to cover the larger, more diverse third-party ecosystem created by digitalisation and financial technology.
Compliance impact
The practical impact is broad for banking-sector third-party risk management because the publication updates the prudential benchmark supervisors may use when assessing governance, controls, and resilience. The Committee does not describe legal sanctions, but firms that lag the baseline may face supervisory challenge, remediation expectations, or pressure to strengthen third-party oversight and lifecycle controls.
New report outlines the Central Bank’s approach to more effective and efficient regulatory and supervisory framework, reducing complexity and improving clarity while maintaining resilience and important protections in the system. This work builds on the Central Bank’s strategy to transform regulation and supervision…
AI Analysis
The Central Bank of Ireland published a comprehensive multi-year roadmap on December 10, 2025, aimed at streamlining its regulatory and supervisory framework across four pillars: supervision, regulation, gatekeeping, and reporting. This initiative represents a strategic shift toward more effective and efficient oversight while explicitly maintaining resilience standards and consumer protections, responding to EU calls for regulatory reform to enhance competitiveness.
Key dates
January 2025
- New integrated supervisory model became effective
2025
- Strategic review of Industry Funding Levy approach (consultation expected during 2025)
2026
- Public consultation on new Regulatory Impact Assessment Framework
2026 to first half of 2028
- Multi-year programme implementation period for all roadmap initiatives
Suggested considerations
*Immediate actions for compliance professionals:
*Monitor consultation releases: Track the Central Bank's website for the 2026 RIA Framework consultation and respond with firm-specific impact assessments
*Assess rulebook changes: Review how proposed updates to insurance regulations, banking rules, credit union handbook, and fund regulations affect your firm's compliance framework
*Evaluate supervisory engagement: Understand how the new integrated supervisory model affects your firm's supervisory relationship and reporting lines
*Prepare for gatekeeping changes: Anticipate enhanced consistency and transparency requirements in authorisation and Fitness & Probity processes
What changed
The roadmap encompasses four major reform areas:
Supervision: Implementation of a new integrated, risk-based supervisory approach introduced in January 2025, consolidating multidisciplinary teams...
Insurance: Major compatibility review to eliminate duplication with Solvency II reforms and review of 2021 Recovery Planning Regulations
Banking: Review of domestic banking rules predating CRD V/CRR to ensure consistency with updated EU standards
Credit Unions: Updates to the Credit Union Handbook following simplification of the Lending Framework
Funds: Changes to AIF rulebook and UCITS regulation with full review of the Fund Service Provider Framework
The Prudential Regulation Authority’s (PRA) update to the Prime Minister on work to support economic growth.
Why this matters
This appears to be a general update from the PRA to the Prime Minister on their work to support economic growth, which would be relevant for a range of financial services firms across the banking, investment management, and wealth management sectors.
This regulatory update from the CFTC involves enforcement action against a precious metals and foreign currency pool fraud, which impacts firms across the banking, investment management, and capital markets sectors. The key topics covered are consumer protection, anti-money laundering, and reporting requirements.
Application of the Guidelines of the European Banking Authority on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (EBA/GL/2025/03)
AI Analysis
Circular CSSF 25/899 mandates the application of EBA Guidelines (EBA/GL/2025/03) on Acquisition, Development, and Construction (ADC) exposures to residential property under Article 126a of Regulation (EU) 575/2013 (CRR), specifying conditions for reducing the risk weight from 150% to 100% on qualifying exposures. This matters for Luxembourg credit institutions as it directly impacts capital requirements for real estate lending, promoting safer lending practices while aligning with Basel III standards via CRR3 implementation.
Key dates
4 November 2025
- EBA Guidelines (EBA/GL/2025/03) apply across EU (two months post-publication on 27 June 2025 in all official languages)
Review and classify ADC exposures against EBA-defined criteria (e.g., contract thresholds, equity levels, monitoring standards) to determine eligibility for 100% risk weight.
Update internal policies, risk assessment models, and credit approval processes to incorporate "sound lending standards" and EBA specifications, including social housing carve-outs.
Recalculate capital requirements under standardized credit risk approach; report changes via CRR disclosures.
Maintain documentation proving compliance (e.g., deposit proofs, equity valuations) for supervisory audits by CSSF.
Institutions must "make every effort to comply" per EBA Regulation Article 16(3).
What changed
- Introduces precise definitions for CRR Article 126a(2) terms, enabling 100% risk weight (instead of 150%) for ADC exposures to residential property if conditions are met: at least 50% of total...
Mandates "sound standards for lending and credit monitoring" alongside these criteria.
Accounts for social housing/public not-for-profit lending specificities, with tailored rules for regulated entities serving long-term tenant housing.
Replaces prior "particularly high-risk exposure" class with dedicated ADC class under CRR3.
Compliance impact
Urgency: High – Firms with significant ADC portfolios face immediate capital relief opportunities (50bp risk weight reduction) but risk non-compliance penalties if processes aren't updated by early 2026, especially post-CRR3 rollout; misclassification could inflate capital needs amid ongoing Basel implementation.
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) geändert.
AI Analysis
On December 9, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 2 of the Sudan Sanctions Ordinance (SR 946.231.18), requiring Swiss financial intermediaries to implement changes to their sanctions screening and compliance procedures. This update reflects ongoing international coordination on Sudan sanctions enforcement and requires immediate implementation by all Swiss-regulated financial institutions.
Key dates
December 9, 2025, 23:00 UTC
- Effective date of the urgent amendment to Annex 2 of SR 946.231.18; SECO updated the SESAM database on this date
Immediate Deadline
- Financial intermediaries required to implement changes according to SR 946.231.18 regulations
Suggested considerations
*Sanctions List Update: Immediately download and integrate the updated SESAM sanctions database into all transaction screening systems and customer due diligence (CDD) procedures.
*System Screening: Conduct full rescreening of existing customer relationships, beneficial owners, and transaction counterparties against the updated Annex 2 designations.
*Transaction Review: Review all pending and recent transactions (typically 30-90 days prior) to identify any that may have involved newly designated persons or entities.
*Blocked Assets: If any blocked persons or entities are identified in existing customer relationships, immediately freeze accounts and file required reports with SECO.
*Staff Training: Update compliance and front-office staff on the specific changes to ensure proper application of the updated sanctions regime.
What changed
The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries.
The timing of this update aligns with broader international sanctions activity on Sudan.
Obelisk Wealth - 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 and wealth management sectors, which raises consumer protection concerns and requires prompt action.
This speech from the ECB discusses evidence-based supervision and addressing evolving risks to maintain resilience, which is relevant for banking, investment management, and wealth management firms from a prudential, operational, and technology perspective.
The Board of Directors of the Swiss Financial Market Supervisory Authority FINMA has appointed Hedwig Ulmer Busenhart as the new Head of the Insurance division. The qualified mathematician and actuary has over 25 years of management experience in the insurance sector and will take up her position on 1 April 2026. She…
Why this matters
This regulatory update announces the appointment of a new Head of the Insurance division at FINMA, the Swiss financial regulator. This is relevant for insurance firms operating in Switzerland, as it involves a key leadership change at the regulatory body overseeing the insurance sector.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Operations Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
Why this matters
This regulatory update relates to the operations of the London Foreign Exchange Joint Standing Committee, which involves market participants, infrastructure providers, and UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
Why this matters
This regulatory update from the Bank of England covers the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee meeting, which is relevant to banking, capital markets, and payments firms.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC), which is a forum for discussion of the wholesale foreign exchange market. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
Why this matters
This regulatory update discusses the London Foreign Exchange Joint Standing Committee (FXJSC), which is a forum for discussion of the wholesale foreign exchange market. The FXJSC includes market participants, infrastructure providers, and UK financial regulators.
PS27/25 finalizes the PRA's policy to delete 37 redundant banking regulatory reporting templates (34 FINREP, 2 COREP, and PRA109) as the first phase of the Future Banking Data (FBD) programme, aiming to reduce reporting burdens while maintaining supervisory data quality. This matters for PRA-regulated banks as it delivers immediate cost savings and signals broader regulatory simplification, aligning with the PRA's secondary competitiveness and growth objective.
Key dates
11 November 2025 Deadline
- Q3 2025 remittance deadline (precedes PS publication, so no concession for early non-reporting)
8 December 2025
- Publication of PS27/25, finalizing policy and responses to CP21/25 consultation
31 December 2025
- Effective date for revised rules, amended SS34/15, and deletions; applies to reporting reference dates falling on or after this date (avoids 2025 Q4 submissions where relevant)
Suggested considerations
Review and update internal reporting systems, processes, and controls to cease submission of the 37 deleted templates for reference dates from 31 December 2025 onwards.
Confirm applicability of consolidated FINREP scoping rules (Chapters 5A–5F) and adjust scoping for remaining templates, incorporating clarified conditions.
Assess eligibility for individual FINREP waivers under the updated framework if part of a UK consolidation group; apply to PRA if criteria met (90-95% asset contribution).
Update compliance policies and training to reflect SS34/15 amendments and aligned remittance deadlines.
Review Pillar 3 disclosure obligations for any ongoing requirements tied to deleted templates and prepare for potential future changes.
What changed
- Deletion of 37 whole reporting templates identified as duplicative, outdated, or low-value: 34 FINREP templates, 2 COREP templates (C05.01 and C05.02, now obsolete), and PRA109.
Consolidation of remaining FINREP scoping provisions into a single section of the PRA Rulebook (new Chapters 5A–5F of the Reporting (CRR) Part), with clarifications to unclear or duplicative...
Alignment of FINREP remittance deadlines to 30 business days for reports under Article 430(3), Article 11(2), and new Chapters 5A–5F.
Updates to Supervisory Statement SS34/15 – Guidelines for completing regulatory reports to reflect deletions and consolidations.
Refinements to the waiver framework for individual UK FINREP reporting in UK consolidation groups (excluding ring-fenced groups), allowing waivers if a single entity contributes 90-95% of group...
Compliance impact
Urgency: Medium – Changes are simplificatory (deletions reduce burden), with immediate effect from 31 December 2025, but no new requirements or penalties for non-compliance with deleted items; firms must act promptly to decommission processes and avoid erroneous submissions. This matters as it lowers ongoing costs (especially for larger reporters) and sets precedent for FBD phases targeting further efficiencies, but smaller firms see limited benefit without broader reforms.
The Securities and Exchange Commission today announced that Lori J. Schock, who has served as the Director of the Office of Investor Education and Assistance (OIEA) since 2009, will retire from the agency at the end of December.“I have known Lori for…
Why this matters
This regulatory update announces the departure of the Director of the SEC's Office of Investor Education and Assistance, which is relevant to investment management firms, broker-dealers, and wealth managers in terms of consumer protection, reporting, and governance.
In line with the Bank's transition to a repo-led, demand-driven operational framework for providing reserves, the Bank is today announcing a reduction in the spread to Bank Rate of the Operational Standing Facility (OSF). This Market Notice confirms the new, recalibrated spread of the OSF at Bank Rate +15bps for the…
Why this matters
This regulatory update from the Bank of England is relevant to banks, wealth managers, and asset managers as it announces changes to the Operational Standing Facility, which is a key part of the central bank's monetary policy framework.
Good morning and welcome everyone. I am delighted to address the eighth meeting of this Forum. When the Forum was established three years ago, the goal was to bring together participants from across Ireland to build a shared approach to understanding and managing the systemic risks that climate change poses, while…
Why this matters
This speech by the Governor of the Central Bank of Ireland discusses the Forum's work on understanding and managing climate-related systemic risks, as well as supporting the transition to net zero.
This regulatory update covers a range of topics relevant to the banking, investment management, and capital markets sectors, including AML/financial crime, prudential requirements, and technology/cyber risks.
Informs insurers on the amendments of Notice 133 and Notice FHC-N133 to include the additional criteria to recognise capital instruments issued by insurers as AT1 or Tier 2 Capital under the RBC 2 framework, subject to the condition that such capital instruments are sold only to persons who are not retail investors in…
AI Analysis
MAS Circular ID 15/25 announces amendments to Notice 133 and Notice FHC-N133, introducing additional criteria for insurers to recognize capital instruments as Additional Tier 1 (AT1) or Tier 2 Capital under the RBC 2 framework. These changes enhance capital quality standards while restricting issuance to non-retail investors in Singapore, effective 1 January 2026, to strengthen insurer resilience and policyholder protection.
Key dates
1 January 2026
- Effective date; capital instruments subject to new criteria and non-retail restriction
Suggested considerations
Review and update capital instruments: Assess existing and planned AT1/Tier 2 issuances against new criteria; amend terms if needed to qualify under RBC 2.
Implement distribution controls: Establish processes to ensure instruments are sold exclusively to non-retail investors in Singapore (e.g., accredited investors, institutions); update investor eligibility checks, prospectuses, and distribution agreements.
Update internal policies: Revise capital management, valuation, and reporting procedures per amended Notice 133/FHC-N133; integrate into RBC 2 calculations.
Board/ senior management oversight: Document compliance gap analysis, remediation plans, and training for finance/treasury teams.
Reporting: Monitor and report capital positions under RBC 2, notifying MAS of material changes.
What changed
- Amendments add additional criteria for capital instruments to qualify as AT1 or Tier 2 Capital, aligning with international prudential standards under RBC 2 (Risk-Based Capital 2 framework).
Key condition: Instruments must be sold only to persons who are not retail investors in Singapore, prohibiting retail distribution to mitigate risks from less sophisticated investors.
Updates apply to valuation and capital requirements in Notice 133 (for licensed insurers) and Notice FHC-N133 (for Designated Financial Holding Companies).
Follows MAS review of consultation feedback, proceeding with proposed enhancements originally outlined in the March 2025 Consultation Paper.
Compliance impact
Urgency: High – With effectiveness less than one month away (as of February 2026), non-compliance risks capital disqualification, regulatory capital shortfalls, enforcement actions, or RBC 2 breaches. Matters critically for capital-constrained insurers planning issuances, as it limits funding flexibility while elevating standards; proactive remediation is essential to avoid supervisory intervention.
This regulatory update from the ECB relates to an asset quality review of Raiffeisen-Holding Niederösterreich-Wien, which is a bank. The topics covered include prudential and capital requirements, operational resilience, and reporting and disclosure, which are relevant for the banking sector.
The Basel Committee on Banking Supervision has issued a consultation on Machine-readable Pillar 3 disclosure. The consultation proposes to make the data disclosed by banks (so-called Pillar 3 disclosures) available in a machine-readable format.
AI Analysis
The Basel Committee issued a consultation proposing a standard for machine-readable Pillar 3 disclosures, aimed at making banks’ quantitative prudential disclosures easier to aggregate, process, and compare across jurisdictions. The proposal matters because it adds technical format requirements without changing the underlying disclosure content, signaling a move toward standardized supervisory data infrastructure.
Key dates
2025-12-05
Basel Committee publishes the consultation on machine-readable Pillar 3 disclosure
2026-03-05 Deadline
Deadline for comments on the consultative document
Suggested considerations
Compliance teams may wish to review current Pillar 3 disclosure production processes and determine whether quantitative disclosures can be generated in a machine-readable format.
Banks may wish to map any existing PDF-based Pillar 3 outputs against likely technical data structure requirements, including whether disclosures could be published on a website or via a central repository.
Supervisors and policy teams may wish to assess how local disclosure arrangements align with the proposed global standard and whether current formats already satisfy the envisaged approach.
Firms subject to overlapping regional disclosure regimes may wish to compare current machine-readable standards with the Basel Committee proposal to identify expected implementation gaps.
What changed
The consultation proposes a new standard for machine-readable quantitative Pillar 3 disclosures across Basel Committee member jurisdictions. It would introduce both a requirement and technical specifications for producing disclosures in a machine-readable format, while leaving the substantive disclosure obligations unchanged. The consultation also contemplates that national supervisors would choose whether disclosures are posted on banks’ own websites or in a central repository.
Compliance impact
The Basel Committee describes the issue as a practical transparency and data-usability problem, because many banks currently publish Pillar 3 information only in PDF format, making cross-bank comparison difficult. The proposal is not a new prudential capital requirement, but it could materially affect disclosure production, data governance, and supervisory reporting processes for affected banks.
In this blog, Governor Gabriel Makhlouf writes about the development of the Digital Euro and how central banks foster trust and safety in the financial system and in the implementation of projects like the Digital Euro.
Why this matters
This regulatory update discusses the development of the Digital Euro, which is relevant for banking, payments, and digital asset firms. It covers consumer protection, prudential requirements, and technological aspects, making it informational in nature.
05 DEC 2025, 02:37 PM
Notice of Amendments to Legislation December 2025
Why this matters
The regulatory update announces amendments to the DFSA Rulebook, including changes to the Markets Law and Regulatory Law. This impacts banking, investment management, and capital markets firms operating in the DIFC, with implications for prudential requirements, licensing, and reporting.
The Basel Committee has published a consultation on a standard format for machine-readable disclosures by banks. The proposed standard format would make existing disclosure by banks more accessible and easier to aggregate. Comments on the proposals are requested by 5 March 2026.
AI Analysis
The Basel Committee has opened a consultation on adding a standard format for machine-readable Pillar 3 disclosures by banks. The proposal is designed to make existing disclosure data easier to access, process, aggregate, and compare across banks, without changing the underlying disclosure requirements.
Key dates
2025-12-05
Basel Committee publishes the consultative document on machine-readable Pillar 3 disclosures
2026-03-05 Deadline
Deadline for comments on the proposed additions to the disclosure standard
Suggested considerations
Compliance teams may wish to review the consultative document and assess whether current Pillar 3 publication processes could support machine-readable output.
Banks with existing machine-readable disclosure regimes may wish to map their current approach against the proposed global standard to identify any gaps or duplication.
Supervisory affairs teams may wish to consider whether disclosures are currently hosted on bank websites or through a central repository model, since the proposal leaves that implementation choice to national supervisors.
Stakeholders may wish to evaluate the technical specifications for the required machine-readable formats and the associated data taxonomy requirements.
Interested firms may wish to submit comments by the consultation deadline if they want to influence the final standard.
What changed
The Committee is proposing additions to its disclosure standard that would require quantitative Pillar 3 disclosures to be available in standardised machine-readable formats across member jurisdictions. The proposal includes technical specifications for producing machine-readable disclosures, while leaving the substantive disclosure content unchanged. National supervisors would decide whether banks publish the machine-readable disclosures on their own websites or through a centralised data repository.
Compliance impact
The consultation is materially relevant for banks because it could change the format in which Pillar 3 disclosures must be published, including technical delivery and accessibility requirements. The Basel Committee says the goal is not to change substantive disclosure obligations, but it does expect more standardisation and broader comparability across jurisdictions.
The Securities and Exchange Commission’s Crypto Task Force has announced the agenda and panelists for its rescheduled Roundtable on Financial Surveillance and Privacy.“New technologies give us a fresh opportunity to recalibrate financial surveillance…
Why this matters
This regulatory update from the SEC's Crypto Task Force focuses on financial surveillance and privacy, which are key topics for banking, investment management, and crypto/digital asset firms.
The Securities and Exchange Commission today announced it will hold the second in its series of compliance outreach events regarding the 2024 adoption of amendments to Regulation S-P. The event, for transfer agents, is a webinar scheduled for December 17…
Why this matters
This regulatory update from the SEC is relevant for transfer agents, which are typically broker-dealers and asset managers. It covers reporting and disclosure requirements under Regulation S-P, as well as authorization and licensing for these firms.
The Central Bank of Ireland has today (5 December) launched a public consultation on the implementation of our new Access to Cash responsibilities. Deputy Governor Vasileios Madouros said: “Amid a rapidly evolving payments landscape, the Central Bank of Ireland is committed to making sure that cash continues to be…
AI Analysis
The Central Bank of Ireland has launched a public consultation on implementing new **Access to Cash** responsibilities under the Finance (Provision of Access to Cash Infrastructure) Act 2025, which commenced on 30 June 2025. This consultation addresses two critical areas: identifying local deficiencies in cash infrastructure and establishing minimum ATM service standards. The initiative reflects regulatory commitment to ensuring cash remains readily available as payment preferences shift toward digital channels.
Key dates
30 June 2025
– Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced
5 December 2025 – 4 March 2026
– Public consultation period for local deficiency guidelines and ATM service standards
Early 2026
– First publication of quarterly cash infrastructure data expected
2026
– Central Bank to publish final ATM service standards regulations
Q1 2026
– Direct engagement with consumers, people with disabilities, older people, and SMEs
Suggested considerations
*For designated credit institutions:
Monitor consultation developments and prepare for compliance with minimum cash infrastructure maintenance levels once regulations are finalized
Prepare to provide quarterly data on ATM numbers, locations, and availability hours
*For ATM operators:
Engage with the consultation process to provide feedback on proposed service standards
What changed
The consultation covers two primary regulatory components:
1. Local Deficiency Guidelines
The Central Bank will establish procedures for identifying geographical areas where individuals and SMEs...
EPC Finance Limited - Central Bank of Ireland Issues Warning on Unauthorised Firm
Why this matters
This warning from the Central Bank of Ireland relates to an unauthorized firm operating in the banking, investment management, and wealth management sectors. It raises concerns around financial crime, consumer protection, and the need for proper licensing and authorization, which are critical issues for firms in these...
LiteLoans4U - 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 consumer lending and mortgage sectors, which raises consumer protection concerns.
Wealthbayy - 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 and wealth management sectors, which raises consumer protection concerns and requires prompt action.
A raft of new measures designed to support the growth of the mutuals sector have been announced today by the financial regulators. They include a review of credit union regulations and the launch of a Mutual Societies Development Unit by the Financial Conduct Authority (FCA).
Why this matters
This regulatory update announces measures to support the growth of the mutuals sector, including a review of credit union regulations and the launch of a Mutual Societies Development Unit.
Given at Bayes Business School for the 6th Research Workshop on The Future of Financial Mutuals
Why this matters
This speech discusses the evolving landscape of UK financial mutuals, which are banking and investment firms with a mutual ownership structure. The key topics covered include consumer protection, prudential requirements, and authorization/licensing - all of relevance to banks, wealth managers, and the broader...
The Prudential Regulation Authority (PRA) has issued PS26/25, finalizing the withdrawal of Supervisory Statement (SS) 20/15, which previously set prescriptive expectations for building societies' treasury and lending activities, effective immediately upon publication on 5 December 2025. This deregulatory move reduces administrative burdens, enhances proportionality across deposit takers, and promotes competition by aligning building societies more closely with banks, while relying on existing tools like the PRA Rulebook, SMCR, and routine supervision for risk management. It matters for compliance teams as it eliminates specific guidance often misinterpreted as binding requirements, freeing firms to tailor risk frameworks but requiring vigilance on broader prudential expectations.
Suggested considerations
Review and update policies: Building societies must confirm internal treasury/lending frameworks align with remaining requirements (e.g., PRA Rulebook, Building Societies Act 1986, ICAAP/SREP under amended SS31/15); remove any SS20/15-specific references or processes.
Assess risk management: Evaluate use of derivatives or treasury tools for compliance with non-prescriptive expectations; ensure SMCR accountability and board oversight.
Update governance documents: Revise ICAAP/SREP processes per SS31/15 amendments; document rationale for tailored approaches to demonstrate proportionality.
Engage supervisors: No immediate reporting mandated, but proactive dialogue recommended for firms previously on extensions or complex approaches.
Monitor related reforms: Track Strong and Simple framework (e.g., PS4/26, PS20/25) for SDDT capital/liquidity simplifications referencing this change.
What changed
- Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports objectives of safety,...
No new rules imposed: PRA deems existing tools sufficient, including Building Societies Act 1986 restrictions, PRA Rulebook, SMCR, and supervision; derivatives permitted only for risk management...
Compliance impact
Urgency: Medium – Effective immediately (5 December 2025), but deregulatory nature reduces burdens rather than imposing new obligations; critical for year-end 2025/early 2026 planning to avoid legacy SS20/15 misapplication. Matters as it shifts from prescriptive "hard limits" (often treated as rules) to principles-based supervision, enabling flexibility but heightening reliance on firm-specific risk assessments amid PRA's focus on competition and growth; non-compliance risks arise from over-reliance on withdrawn guidance or inadequate tailoring.
This report has been informed by the PRA and FCA’s ongoing regulation and supervision of mutuals and by direct engagement with mutuals and their trade associations in sessions around the country throughout 2025.
Why this matters
This report provides an overview of the mutual landscape, informed by the PRA and FCA's ongoing regulation and supervision. It is likely to be informational in nature, providing insights into the mutual sector rather than announcing any new regulatory changes.
Financial disclosures & corporate financing Journalists Listed companies and issuers The Autorité des Marchés Financiers takes note of the Cour de Cassation ruling in the Vivendi SE case
Why this matters
This regulatory update from the Autorité des Marchés Financiers (AMF) relates to a court ruling involving Vivendi SE, a listed company. It touches on financial disclosures, corporate financing, and market abuse issues that are relevant for banks, broker-dealers, and asset managers operating in the capital markets and...
The Bank of England (the Bank) has today launched its second system-wide exploratory scenario (SWES) exercise. This will focus on how the private markets ecosystem operates under stress and the potential implications for UK financial stability and the UK real economy.
Why this matters
This regulatory update from the Bank of England focuses on how the private markets ecosystem operates under stress and the potential implications for UK financial stability and the real economy.
CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.
Key dates
4 December 2025
- PRA published CP22/25 consultation paper
31 December 2025
- Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date
31 December 2025
- Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date
55 business days after quarter Deadline
end; - Deadline for quarterly QMC.01 submission (internal model firms)
100 business days after financial year Deadline
end; - Deadline for annual AoC.01 submission (internal model firms and groups)
Suggested considerations
*Immediate Actions (January-February 2026):
*Review consultation paper: Obtain and analyze CP22/25 in full to understand proposed amendments
*Assess applicability: Determine which reporting requirements apply to your firm (internal model status, portfolio types, reporting obligations)
*Identify gaps: Compare current reporting processes against PRA expectations outlined in the supervisory statement (SS4015)
*Engage supervisory contacts: Discuss any planned changes to reporting methodology (e.g., accident vs. underwriting year classification) with PRA supervisory contacts prior to implementation
What changed
The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas:
Reporting Framework Modifications
Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
RBNS claims development: Clarification on reporting of reported but not settled (RBNS) claims and their development patterns.
Internal Model Requirements
Firms using partial or full internal models for Solvency Capital Requirement (SCR) calculation must describe governance information including responsible roles, specific committees, their tasks,...
Mediation Appointment Institutional Other professionals Executive & other private individuals Retail investors Journalists Investment services providers Investment management companies Listed companies and issuers ...
Why this matters
This regulatory update announces the appointment of a new Ombudsman at the French financial markets regulator, the Autorité des Marchés Financiers (AMF). This is an institutional change that impacts various financial services firms under the AMF's jurisdiction, including asset managers, broker-dealers, wealth...
Given at Womble Bond Dickinson, Newcastle, hosted by the North East Chamber of Commerce
Why this matters
This speech by the Bank of England covers topics relevant to banking, investment management, and wealth management firms, focusing on consumer protection, operational resilience, and technology/cyber issues. The content is informational rather than an urgent regulatory update.
This is a Basel Committee assessment report on the UK's implementation of global prudential standards. The content is informational in nature—publishing compliance assessment results rather than imposing new obligations or enforcement actions.
Given at the ISDA Conference on Trading Book Capital
Why this matters
This speech from the Bank of England discusses updates to the Basel 3.1 framework, which sets prudential capital requirements for banks and broker-dealers. It also touches on market risk and surveillance, which are relevant topics for capital markets firms.
PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.
Key dates
3 December 2025
- PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19
Within 6 months (by ~June 2026)
- Firms assess gaps against new expectations and develop remediation plans (industry guidance)
Ongoing
- Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence
Suggested considerations
Conduct gap analysis against SS5/25 within 6 months and remediate (e.g., update governance, risk frameworks, CSA processes).
Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting.
Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures.
Ensure senior accountability and alignment with standards like SS1/21.
What changed
The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a...
Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
Risk management enhancements: Integrate climate risks into existing frameworks/risk registers (supplementary sub-registers allowed); 'accept, manage, avoid' is suggestive, not mandatory; aligns with...
Climate scenario analysis (CSA) advancements: Firms must use CSA strategically for decisions; flexibility on number/type of scenarios, reverse stress/sensitivity analysis, and longer horizons...
Compliance impact
Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid maturing climate risk landscape.
SS5/25 is the PRA's updated supervisory statement, published on 3 December 2025, replacing SS3/19 and setting enhanced expectations for banks and insurers to manage climate-related risks through governance, risk management, scenario analysis, data quality, and disclosures. It matters because it represents a step change from awareness-raising to embedding robust, proportionate practices that integrate climate risks into core prudential processes like ICAAP, ILAAP, ORSA, and capital planning, aligning with the PRA's objectives for firm safety and soundness amid evolving physical and transition risks.
Key dates
April 2025
Consultation paper CP10/25 issued (feedback incorporated in final policy)
Within 6 months of 3 December 2025 (by ~3 June 2026)
Firms assess gaps against new expectations and develop implementation plans
3 December 2025
Publication of PS25/25 and SS5/25; replaces SS3/19 effective immediately
Suggested considerations
Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work).
Integrate into risk frameworks: Update risk registers, ICAAP/ILAAP/ORSA/SCR with quantitative metrics, scenarios, and controls; adjust underwriting/pricing/collateral.
Perform climate scenario analysis: Model impacts on capital/liquidity/solvency using plausible pathways.
Enhance data: Source/assess granular data (e.g., location/sector/hazards), document proxies/limitations.
What changed
- Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit,...
Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without...
Risk management integration: Requires embedding climate risks into existing frameworks with quantitative metrics/limits where material; detailed mapping of risks (e.g., physical/transition via...
Scenario analysis: Firms must conduct climate scenario exercises capturing plausible pathways, impacts on capital/liquidity/solvency, with transparent assumptions and management challenge;...
Data expectations: Critical assessment of data sources/quality (e.g., geographic/sectoral for banks, hazard/vulnerability for insurers); use proxies with documented limitations.
Compliance impact
Urgency: High – Effective immediately with a 6-month window (~June 2026) for gap closure, this demands significant operational uplift (e.g., data, scenarios, integration) amid PRA's shift to enforcement; non-compliance risks supervisory action, given climate risks' materiality to prudential stability and alignment with global standards.
This report describes the Committee's assessment of the implementation of the Basel Committee's large exposures framework (LEX) in the UK. The UK LEX regulations have been assessed as largely compliant.
Why this matters
This is a Basel Committee RCAP assessment report evaluating UK implementation of the large exposures framework. The content explicitly addresses credit risk and supervisory cooperation through a compliance assessment. The report confirms the UK is 'largely compliant' with the Basel Framework's LEX requirements.
This report describes the Committee's assessment of the implementation of the Basel Committee's Net Stable Funding Ratio (NSFR) standard in the UK. The UK NSFR regulations have been assessed as largely compliant.
Why this matters
This is a Basel Committee RCAP assessment report confirming the UK's implementation of the Net Stable Funding Ratio standard. The content is informational and retrospective (assessing past compliance), not prescriptive or imposing new obligations.
This revised version of the Handbook includes specific guidance for the assessments of the Basel III revisions to risk weighted assets and the leverage ratio framework.
AI Analysis
The Basel Committee updated its RCAP Handbook for jurisdictional assessments to reflect how assessors should evaluate domestic prudential rules for consistency and completeness against the Basel framework. The revised handbook matters because it adds specific guidance for assessing the Basel III revisions to risk-weighted assets and the leverage ratio framework, which are core bank capital and leverage standards.
Key dates
2025-12-03
BIS published the revised RCAP Handbook for jurisdictional assessments.
Suggested considerations
Compliance teams may wish to review whether their jurisdiction’s Basel III implementation, especially risk-weighted assets and leverage ratio rules, aligns with the standards that RCAP assessors will evaluate.
Supervisory liaison functions may wish to check the updated handbook when preparing for jurisdictional reviews or responding to RCAP questionnaires and evidence requests.
Prudential policy teams may wish to map any domestic deviations from Basel standards and document the rationale, materiality, and implementation status for possible RCAP scrutiny.
What changed
The publication updates the Handbook that RCAP assessors, assessed jurisdictions, and other experts use to conduct jurisdictional reviews of domestic prudential regulations against Basel minimum requirements. The handbook is a flexible compendium, meaning its guidance and principles are revised or elaborated as RCAP evolves and as lessons from past assessments are incorporated.
This revised version specifically adds guidance for assessments of the Basel III revisions to risk-weighted assets and the leverage ratio framework.
Compliance impact
The publication is procedurally significant because RCAP findings can identify material gaps between domestic prudential rules and Basel minimum standards. It does not itself impose sanctions or deadlines, but it can increase supervisory scrutiny and highlight inconsistencies that jurisdictions may need to address.
This regulatory update from the CSSF provides information on the global situation of undertakings for collective investment at the end of October 2025, which is relevant for investment management and wealth management firms.
Our Financial Policy Committee (FPC) meets to identify risks to financial stability and agree policy actions aimed at safeguarding the resilience of the UK financial system.
Why this matters
This regulatory update from the Bank of England's Financial Policy Committee is relevant to banking, investment management, and wealth management firms. It covers key topics such as prudential requirements, operational resilience, and consumer protection, which are of medium importance for these sectors.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England's Statistical Notice 2025/05 requires all reporting institutions to confirm their confidentiality permissions for publishing aggregate statistical data during the 2026 reporting year. This mandatory review streamlines data publication processes by seeking prior consent for aggregate data where firms are among fewer than three contributors, reducing administrative burden while maintaining data integrity.
Key dates
19 December 2025, 5:00 PM GMT Deadline
– Deadline for completing confidentiality preference survey in BEEDS portal
January–December 2026
– Reporting reference periods covered by granted permissions
Ongoing
– Consent remains valid for these periods unless explicitly withdrawn; applies to resubmissions and late submissions for 2026 reference periods
Suggested considerations
*Log into the BEEDS portal and access the confidentiality permission survey
*Select one of four consent options (blanket, form-by-form, selective, or case-by-case)
*For multi-entity groups: Complete a separate survey for each individual entity
*Review prepopulated firm information and make adjustments as needed
*Submit final preferences via the portal (latest submission version is treated as final)
What changed
The notice introduces a streamlined confidentiality permission framework with four consent options for reporting institutions:
1. Blanket consent – Give prior approval for all statistical forms
2. Form-by-form consent – Approve permissions on individual forms
3. Selective consent – Approve all forms except specified data points
4. Case-by-case opt-out – Require explicit consent for each publication instance
The material change is the Bank's shift toward pre-approval for aggregate data publication where firms represent fewer than three contributors to an aggregate figure.
Exchange of letters between the Governor and the Chancellor
Why this matters
This regulatory update from the Bank of England's Financial Policy Committee is likely to impact banking, investment management, and wealth management firms, with a focus on prudential requirements, operational resilience, and reporting obligations.
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
Why this matters
This regulatory digest covers a range of topics relevant to banking, investment management, and wealth management firms operating in the UK. The low urgency indicates this is informational content summarizing key regulatory news and publications for the month.