October 2026 Regulatory Updates

Key dates

2026-11-30 Deadline

Consultation period for ADGM FSRA Consultation Paper No. 5 of 2026 closes; comments may be submitted to [email protected].

Suggested considerations

• Compliance teams may wish to review the proposed Guidance and submit written comments to [email protected] by 2026-11-30, particularly on operational feasibility, proportionality and the treatment of permissionless protocols.
• Firms should consider inventorying current and planned DeFi activity, including protocol use, liquidity provision, staking, lending, borrowing, decentralised exchange activity, smart-contract interaction and client-facing exposure.
• Firms should consider mapping each DeFi activity to existing ADGM permissions and identifying activities that may require a variation of permission, additional controls or discontinuation.
• Risk and compliance functions may wish to assess whether existing governance arrangements clearly assign senior accountability for DeFi, approve protocols and counterparties, set exposure limits and address conflicts of interest.
• Firms should consider enhancing due diligence for protocol code, governance structures, upgrade and administrative privileges, oracle dependencies, bridge and composability risks, concentration, liquidity, sanctions exposure and the availability of legal recourse.
• AML and financial-crime teams may wish to assess transaction-monitoring, wallet-screening, sanctions-screening, blockchain analytics, travel-rule and suspicious-activity escalation controls for DeFi-related activity, taking account of limited visibility into beneficial ownership and counterparties.
• Operations and technology teams should consider whether incident-management procedures cover smart-contract exploits, oracle failures, governance attacks, de-pegging, bridge compromise, protocol insolvency, loss of access and material service disruption.
• Client-asset teams should review segregation, custody, ownership, valuation, reconciliation and disclosure arrangements where client assets interact with DeFi protocols or are exposed to protocol failure.

What changed

The proposed Guidance sets supervisory expectations for identifying, assessing, monitoring and managing risks arising from engagement with DeFi protocols and venues. It covers governance and accountability, risk assessments, due diligence, exposure and control measures, ongoing monitoring, financial-crime controls, incident escalation, recordkeeping, auditability, competence and client-asset safeguards. The proposal is guidance under consultation and does not itself introduce binding new rules at this stage.

Key dates

2016-06-17

Saad became an authorised representative of Interprac Financial Planning, according to ASIC's background information.

2021-02-01

ASIC alleges the relevant advice period began, during which Saad advised retail clients to roll over superannuation into First Guardian.

2021-12-31

Saad's authorised-representative relationship with Interprac Financial Planning ended, according to ASIC's background information.

2026-10-07

ASIC commenced Federal Court civil penalty proceedings against Osama Saad.

Suggested considerations

• Compliance teams may wish to review adviser remuneration, referral, marketing and lead-generation arrangements for direct or indirect benefits linked to product recommendations, including payments made through related entities or third parties.
• Licensees should consider testing whether any benefit could reasonably influence the choice of financial product or advice strategy, and whether the arrangement falls within the conflicted-remuneration prohibitions in Part 7.7A Division 5 of the Corporations Act 2001.
• Advice businesses should consider targeted file reviews involving rollovers from superannuation into high-risk, illiquid or complex products, including assessment of best-interests compliance under section 961B, appropriateness under section 961G and the client-interest priority obligation under section 961J.
• Firms should consider tracing the full economic flow of adviser remuneration, referral fees, marketing funding and related-party payments rather than limiting testing to amounts shown on adviser or licensee invoices.
• Australian financial-services licensees may wish to reassess oversight of authorised representatives, referral partners and externally generated leads, including conflicts registers, product research, statements of advice and evidence supporting the client's circumstances and objectives.
• Relevant businesses should consider reviewing controls against ASIC Regulatory Guide 246, Conflicted and other banned remuneration, and preserving records that demonstrate why payment structures do not circumvent the statutory prohibitions.
• Product issuers and superannuation trustees may wish to review distribution and surveillance data for First Guardian, Shield and comparable products, and consider whether affected clients require remediation or referral to the appropriate complaints process.
• Compliance teams should monitor the Federal Court proceedings and ASIC's broader First Guardian and Shield enforcement program, noting that the allegations are unproven until determined by the Court.

What changed

This is an enforcement action rather than a new rule or amended requirement. ASIC alleges that Atlas Marketing and United Capital received benefits from entities connected with First Guardian and Shield, including payments allegedly used for personal benefit and to fund marketing and lead-generation businesses that referred prospective clients to advice firms.

Key dates

2027-01-17 Deadline

The current transitional regime for certain third-country CSD notary and central maintenance services is scheduled to expire; ESMA says access should nevertheless not be prevented after this date pending finalisation of the legislative extension.

Suggested considerations

• Firms should identify securities, issuer programmes, custody chains and settlement arrangements that depend directly or indirectly on a third-country CSD, including arrangements involving DTC or other non-EU infrastructure.
• Compliance and operations teams may wish to document reliance on the transitional regime and assess the consequences of a delayed or unsuccessful legislative extension, including possible suspension, removal of securities from a CSD system, settlement disruption and trading interruption.
• Issuers should consider confirming with their third-country CSD, depositary, registrar, paying agent, custodian and trading venues how access is expected to be maintained after 17 January 2027 and what contingency arrangements exist.
• Firms should distinguish ESMA's policy statement from a binding legislative amendment or formal recognition decision and avoid treating it as confirmation that every third-country CSD may provide services indefinitely without satisfying CSDR requirements.
• Legal and regulatory teams may wish to monitor the final text and commencement date of the Market Integration and Supervision Package, together with any European Commission equivalence decisions and ESMA recognition decisions relevant to the CSDs used by the firm.
• Firms should review contractual, disclosure and operational-resilience documentation so that any dependency on third-country CSD access, alternative settlement routes or potential service suspension is appropriately reflected.

What changed

ESMA has provided a supervisory and market-access clarification that EU market participants should not be prevented from accessing the relevant notary and central maintenance services of third-country CSDs solely because the current transitional regime reaches its scheduled end on 17 January 2027. The clarification is intended to apply during the period after that date and until the EU finalises the proposed legislative extension under the Market Integration and Supervision Package.

Key dates

2025-10-22

The SFC published its consultation paper on proposed amendments to the UT Code.

2026-01-21

The consultation period closed.

2026-10-16

The revised UT Code and consequential revised PRF, MPF, ILAS and REIT codes are scheduled to be gazetted.

2026-11-01

The revised UT Code and consequential revised PRF, MPF, ILAS and REIT codes become effective.

2027-11-01 Deadline

The generally applicable 12-month transitional period for existing SFC-authorised funds is scheduled to end.

Suggested considerations

• Compliance teams may wish to map each SFC-authorised fund’s current derivative exposure methodology against the revised UT Code and assess whether adopting relative or absolute VaR would be operationally and commercially appropriate.
• Fund managers considering VaR may wish to validate reference-portfolio selection, VaR models, calibration, stress testing, back-testing, independent validation, governance approvals, limit monitoring and escalation procedures against the final revised UT Code and forthcoming SFC guidance.
• Managers may wish to review liquidity-risk frameworks, redemption terms, asset-liability liquidity matching, stress-testing scenarios, anti-dilution tools and disclosures, particularly for funds with exposure to less liquid assets.
• Money market fund managers may wish to test compliance with the 7.5% daily-liquid-assets and 15% weekly-liquid-assets thresholds and document monitoring of investor concentration, redemption behaviour, asset liquidity, days to trade, cost to trade and maturity profiles.
• Product, legal and disclosure teams may wish to update offering documents, constitutive documents, investment-management agreements, risk disclosures, derivatives policies and fund supplements where the revised requirements affect a fund’s strategy or operating model.
• Managers may wish to assess whether existing UCITS or other overseas risk-management documentation can be leveraged while confirming that Hong Kong-specific requirements and SFC-authorised-fund classifications are satisfied.
• Trustees, custodians and oversight committees may wish to confirm their revised oversight responsibilities, reporting arrangements and escalation processes before the transition period expires.
• Firms may wish to monitor the SFC’s forthcoming supplementary guidance, frequently asked questions and revised templates and incorporate them into implementation plans.

What changed

The revised UT Code will permit eligible retail funds to manage derivative exposure using either the existing net derivative exposure approach or a VaR approach. The proposed VaR framework uses a relative VaR limit of 200% of the VaR of a designated unleveraged reference portfolio or an absolute VaR limit of 20% of the fund’s NAV, together with associated governance, risk-management and monitoring requirements.

Key dates

2026-10-07

PRA consultation CP13/26 opens.

2027-02-07 Deadline

PRA consultation CP13/26 closes and responses are due.

2031-07-01

First proposed automatic threshold update would take effect, subject to the consultation outcome and final rules.

Suggested considerations

• Compliance teams may wish to review CP13/26 and identify which of the 128 proposed thresholds currently determine the firm's prudential categorisation, reporting obligations or application of specific rules.
• Firms should consider submitting consultation responses by 7 February 2027, particularly on the suitability of nominal UK GDP as the index, the five-year adjustment interval, the treatment of thresholds near business-planning boundaries and the thresholds excluded from the main proposal.
• Banks and building societies may wish to model how the proposed mechanism could affect future eligibility for the Small Domestic Deposit Takers regime and detailed capital-reporting requirements, while recognising that no 2031 value has been specified in the publication.
• Insurers may wish to assess potential future effects on Solvency UK scope and related governance, reporting and capital-planning assumptions.
• Credit unions may wish to inventory member-related monetary thresholds, including the £7,500 threshold, and assess whether systems and monitoring processes can accommodate future indexed values.
• Regulatory change teams should track the outcome of CP13/26 and the parallel Section 4 discussion on excluded and FCA-joint thresholds rather than treating the proposed increases as current law.
• Firms operating across UK and non-UK regimes may wish to consider potential divergence between UK automatic indexation and static or differently indexed thresholds in other jurisdictions.

What changed

CP13/26 proposes that 128 thresholds determining which PRA rules apply, how those rules apply and what firms must report should be indexed to nominal UK GDP published by the Office for National Statistics. The proposed indexation cycle is every five years, using nominal GDP because it captures both price changes and real economic growth.

Key dates

2027-02-07 Deadline

Deadline for responses to CP13/26 and the associated discussion-paper section.

2031-07-01

Proposed effective date for the first automatic update of in-scope thresholds, subject to finalisation of the framework.

Suggested considerations

• Consider submitting responses on the proposed framework, the proposed in-scope threshold list, the methodology and the separate discussion-paper thresholds by 2027-02-07.
• Map the firm's current and forecast assets, exposures, liabilities, lending and reporting metrics against relevant PRA thresholds, including proposed thresholds that may be revised before finalisation.
• Assess whether nominal GDP indexation could move the firm out of, or into, a threshold-defined prudential treatment from 2031 onwards, while recognising that firms growing faster than nominal GDP would still be expected to cross thresholds.
• Review regulatory reporting, capital, liquidity, governance, risk-management and policy systems that hard-code fixed threshold values or effective dates, and consider designing controlled update mechanisms for future indexed values.
• Assess the effect of the proposed five-year update cycle on business planning, acquisitions, balance-sheet growth, lending strategies and group-structure decisions.
• Consider providing quantitative evidence to the PRA on implementation costs, cliff-edge effects, reporting impacts and whether additional discussion-paper thresholds should be included.
• Monitor the final PRA policy statement, the final automatic-indexation statement of policy and the consolidated threshold list before treating any proposed uprating as a binding change.

What changed

The PRA proposes to replace the current predominantly ad hoc threshold-review process for eligible fixed nominal thresholds with a rules-based framework. In-scope thresholds would be indexed using UK nominal GDP, based on data produced by the Office for National Statistics, on a common five-year cycle; the first automatic update would take effect on 1 July 2031, subject to final policy.

Key dates

2026-02-09

AMLA opened the public consultation on the draft RTS concerning business relationships, occasional and linked transactions, lower thresholds, and customer due diligence.

2026-04-16

AMLA opened the public consultation on the draft RTS concerning group-wide requirements and additional measures for subsidiaries and branches in third countries.

2026-05-08

Public consultation closed for the business-relationship, transaction and customer-due-diligence draft RTS.

2026-06-15

Public consultation closed for the group-wide arrangements and third-country legal-impediment draft RTS.

2026-10-01

AMLA announced that it had finalised the three draft RTS and submitted them to the European Commission for formal adoption.

2026-10-07

CSSF published its communiqué drawing Luxembourg professionals’ attention to the draft RTS and recommending preparatory gap analysis and control work.

Suggested considerations

• Compliance teams may wish to complete a gap analysis against the AMLA final reports, particularly for customer and beneficial-owner information, verification sources, electronic identification, non-face-to-face onboarding and PEP screening.
• Firms should consider mapping current customer journeys and transaction-monitoring logic to the proposed distinction between business relationships, occasional transactions and linked transactions.
• Firms may wish to identify products, sectors and transaction types that could be affected by lower CDD thresholds for higher-risk activities, while avoiding reliance on unfinalised monetary thresholds.
• Financial groups should consider reviewing group-wide AML/CFT governance, risk assessments, policies, internal controls, training and secure information-sharing arrangements, including structures involving common ownership, management, compliance control, networks or partnerships.
• Groups with branches or subsidiaries in third countries should consider inventorying legal impediments to applying EU AMLR and group policies and preparing escalation, risk-mitigation and supervisory-response procedures.
• IT and operations teams may wish to assess changes needed for customer-data fields, linked-transaction detection, identity-verification evidence, electronic identification and intra-group information exchange.
• Firms should monitor the European Commission’s adoption process and the Official Journal publication because the final text, effective date and any amendments remain unknown; preparatory work should be calibrated to the proposed six-month transition period rather than treated as a current binding deadline.

What changed

The draft RTS under Article 19(9) of Regulation (EU) 2024/1624 would establish criteria for distinguishing business relationships, occasional transactions and linked transactions, and would identify high-risk obliged entities, sectors or transactions for which lower CDD thresholds should apply. The draft RTS under Article 28(1) would specify information and verification requirements for standard, simplified and enhanced CDD, including reliable and independent verification sources, electronic identification means, qualified trust services, non-face-to-face verification, and relevant treatment...

Key dates

2026-10-07

AFM and DNB published their joint policy statement and exploration on tokenisation of securities in the Netherlands.

2023-03-23

Applications became available under the EU DLT Pilot Regime as implemented and supervised in the Netherlands; this is relevant background for firms assessing DLT market-infrastructure models, not a new deadline arising from the AFM and DNB publication.

Suggested considerations

• Firms should classify each proposed tokenised instrument by its legal and regulatory characteristics, distinguishing securities or other MiFID II financial instruments from crypto-assets covered by MiCA and from non-financial crypto-assets.
• Compliance and legal teams may wish to document whether the proposed arrangement is native tokenisation or a hybrid model, identify which record constitutes the legally authoritative record, and assess the resulting title, transfer, custody, settlement and insolvency risks under Dutch law.
• Market infrastructures and investment firms considering a DLT model should assess whether Regulation (EU) 2022/858 and the Dutch DLT Pilot Regime are available, including the need for specific permission and the eligibility limits applicable to DLT financial instruments and operators.
• Firms should continue applying existing requirements, including MiFID II conduct and organisational rules, the Prospectus Regulation where applicable, Regulation (EU) No 596/2014 on market abuse, Regulation (EU) No 909/2014 on central securities depositories where applicable, and relevant custody, client-asset and investor-protection controls; the AFM and DNB statement does not disapply them.
• Issuers, custodians, trading venues and service providers may wish to participate in or monitor the proposed government-supervisor-market follow-up and prepare concrete use cases that identify where statutory clarification, contractual documentation or a Dutch legislative amendment would be needed.
• Firms operating cross-border should compare the Dutch position with jurisdictions that have introduced specific legal recognition for electronic or DLT-based securities, while avoiding reliance on another jurisdiction's legal treatment without confirming Dutch offering, custody, settlement and investor-protection implications.
• Governance functions may wish to update technology, legal, operational-resilience and outsourcing risk assessments to account for the possibility that infrastructure and issuance activity migrate to jurisdictions offering greater legal certainty.

What changed

No legislation, regulatory technical standard, authorisation requirement or immediate compliance deadline was introduced. AFM and DNB jointly identified a legal gap: although EU and Dutch law do not generally prohibit DLT, market participants are commonly forced to maintain both a DLT-based record and a traditional legal administration, creating uncertainty about the legal significance of the token and limiting efficiency gains.

Key dates

2026-10-07

MAS published its written parliamentary reply stating that LIA’s next review of severe-stage critical illness definitions will commence in 2027 and that updated definitions will apply to new products sold.

2027-01-01

The LIA review is expected to commence during 2027; the publication does not specify an exact commencement date or impose a firm for firms to act by this date.

2025-10-01

The LIA Critical Illness Framework 2024 was required to be adopted for new products no later than this date, according to independent industry and LIA-related materials; this is relevant background rather than a new deadline created by the MAS reply.

Suggested considerations

• Compliance teams may wish to monitor the LIA’s 2027 review, consultation materials, final framework amendments, implementation dates, and any MAS communications that follow.
• Insurers should consider mapping current severe-stage definitions to the procedures and clinical severity criteria that may be affected, including identifying products whose claims triggers are particularly dependent on a named surgical procedure.
• Product governance, actuarial, underwriting, claims, legal, and compliance functions may wish to assess how alternative disease- and severity-based triggers could affect coverage scope, expected claims frequency, reserves, reinsurance, and pricing.
• Firms should consider documenting whether existing policy wordings can continue to be administered consistently with their contractual terms and should avoid treating any future framework revision as automatically applicable to in-force policies.
• Insurers developing new products should consider preparing customer disclosures explaining the relevant disease, severity, diagnostic evidence, exclusions, waiting periods, and any procedure-independent claims criteria.
• Compliance teams may wish to review product approval and change-control processes so that future LIA definition changes are reflected consistently in policy documents, benefit illustrations, sales materials, claims manuals, staff training, and complaint-handling procedures.
• Actuarial and product teams should consider reassessing premiums and claims assumptions before launching products using revised definitions, since MAS expressly notes that premiums depend on the probability of claims materialising.

What changed

No immediate statutory requirement, product withdrawal, or mandatory amendment to existing policies was introduced. LIA’s 2027 review will consider procedure-neutral or less procedure-dependent definitions for certain medical conditions, while retaining the use of procedures where they provide objective evidence of severity, recovery duration, and financial impact. Any resulting changes will apply to new products sold; existing policies remain governed by their contractual definitions and terms.

Key dates

2026-10-07

MAS published the written parliamentary reply and stated that approximately 4,000 households could face cash shortfalls under the severe stress scenario.

Suggested considerations

• Compliance and consumer-credit teams may wish to confirm that mortgage portfolios have documented processes for identifying deteriorating repayment performance and other early indicators of financial stress.
• Banks should consider reviewing whether frontline and collections staff consistently contact borrowers early, assess individual circumstances, and record the rationale for any restructuring, refinancing, forbearance, or other assistance offered.
• Mortgage lenders may wish to test whether vulnerable segments identified by the MAS stress test, including lower-income middle-aged HDB borrowers and borrowers with sizeable private-housing loan balances, are adequately represented in portfolio monitoring and scenario analysis.
• Firms should consider maintaining clear customer communications directing borrowers who anticipate repayment difficulty to contact the lender before arrears arise.
• Banks and relevant agencies may wish to review referral arrangements with HDB, Credit Counselling Singapore, and appropriate social-service agencies, including escalation and hand-off procedures.
• Risk committees may wish to retain evidence that severe interest-rate, income-reduction, unemployment, and liquidity-buffer scenarios are considered in mortgage portfolio risk management, while distinguishing scenario-based vulnerabilities from actual current borrower distress.
• Firms should avoid describing the approximately 4,000-household figure as a forecast of current arrears or as an individually identified list of affected customers.

What changed

No binding regulatory requirement, threshold, reporting obligation, or enforcement measure was introduced by this parliamentary reply. MAS confirmed that financial institutions monitor repayment performance and engage borrowers showing signs of financial stress, with assistance tailored to individual circumstances. HDB-financed borrowers may approach HDB for restructuring discussions, bank-financed borrowers may approach their banks, and borrowers already experiencing debt repayment difficulties may seek counselling and debt-management guidance from Credit Counselling Singapore.

Key dates

2026-10-07

MAS issued the Guidelines on Artificial Intelligence Risk Management following its November 2025 consultation.

2027-10-07 Deadline

The Guidelines take effect. FIs should meet the expectations in Sections 3 and 4 from this date.

2027-10-07

MAS intends to consult the financial sector during 2027 on what additional guidance on agentic AI would be useful.

2028-10-07 Deadline

FIs should meet the expectations in Sections 5 and 6 by this date under the phased implementation timetable.

Suggested considerations

• FIs should establish or update an enterprise inventory of AI systems, models, embedded AI functionality and third-party AI services, using a level of granularity appropriate to their risk profile.
• Compliance and risk teams may wish to classify individual AI use cases by materiality, including potential effects on customers, prudential soundness, operational resilience, other financial institutions and the wider financial system.
• Boards and senior management should consider documenting AI risk appetite, ownership, escalation routes and the allocation of responsibilities across business, risk, compliance, technology, cybersecurity, data and model-governance functions.
• FIs should map existing AI controls across the lifecycle, including data governance, development and validation, testing, human oversight, cybersecurity, monitoring, incident management and change management, and identify gaps against the Guidelines.
• Procurement, outsourcing and third-party-risk functions should consider adding AI-specific due diligence, assurance, contractual rights, performance monitoring, incident notification and exit or substitution arrangements for external AI providers.
• FIs should assess whether existing governance committees and risk frameworks provide sufficient cross-functional oversight, rather than assuming that a new dedicated AI committee is necessary.
• FIs may wish to define evidence that supports proportionality decisions, including why basic policies and procedures are adequate for lower-materiality AI use cases.
• Implementation planning should distinguish the expectations in Sections 3 and 4, which should be met from 7 October 2027, from Sections 5 and 6, which should be met by 7 October 2028.

What changed

The Guidelines introduce an enterprise- and use-case-level framework for managing AI risk. Boards and senior management are expected to oversee AI risk, define accountabilities, set risk appetite, and maintain suitable risk-management frameworks, policies and procedures; existing governance structures may be used and a dedicated AI committee is not required solely for compliance.

Key dates

2021-01-01

Beginning of the alleged cherry-picking period involving delayed allocations and disproportionate assignment of first-day gains and losses.

2023-10-31

End of the alleged cherry-picking period, described by the SEC as running through October 2023.

2024-11-01

The SEC filed its prior litigated district-court complaint against Leech; the source identifies November 2024 but does not specify the filing day.

2026-06-05

The SEC settled administrative proceedings against Western Asset, imposing a $100 million penalty, censure, cease-and-desist order, and Fair Fund process.

2026-10-06

The SEC announced its motion for entry of a consent final judgment against Leech; the judgment remains subject to court approval.

Suggested considerations

• Compliance teams may wish to review whether trade timestamps, allocation timestamps, order-entry records, and market settlement-price data permit detection of allocations made after material price movements are known.
• Firms should consider testing allocation controls for fairness and consistency across strategies, accounts, clients, and affiliated portfolios, including review of first-day gains and losses and unexplained deviations among portfolio managers.
• Firms should consider validating that written allocation, reallocation, and error-correction procedures are implemented in practice, with documented approvals, exception handling, and independent oversight.
• Compliance teams may wish to assess whether portfolio-manager trading and allocation practices diverge materially from peers or from client disclosures, and whether those differences trigger escalation, surveillance, or enhanced supervision.
• Investment advisers should consider reviewing supervisory arrangements for senior investment personnel, including evidence that surveillance alerts, exception reports, and known control weaknesses are investigated and remediated.
• Firms should consider preserving records sufficient to reconstruct the timing and rationale of trade placement, allocation, reallocation, and approval decisions, and reviewing whether disclosures accurately describe fair and equitable allocation practices.
• Affected firms may wish to monitor the court’s decision on the proposed Leech judgment and the administration of Western Asset’s Fair Fund; no general compliance deadline is stated in the publication.

What changed

This publication does not establish a new generally applicable rule; it advances a case-specific consent judgment, subject to court approval, against Leech. The proposed judgment includes a $3 million penalty, a permanent injunction against violations of the federal securities-law antifraud provisions, an officer-and-director bar, and a forthcoming associational bar. The related June 5, 2026 administrative settlement against Western Asset imposed a $100 million civil penalty, censure, and cease-and-desist order, with the penalty deposited into a Fair Fund for harmed investors.

Key dates

2026-10-06

Vice Chair Bowman delivered the speech announcing the Federal Reserve's planned five-region supervisory realignment and outlining proposed modernization initiatives.

2026-07-01

The revised Community Bank Leverage Ratio framework took effect, lowering the ratio from 9 percent to 8 percent.

2025-12-01

The FFIEC issued a request for information on streamlining the Call Report.

Suggested considerations

• Compliance teams may wish to monitor Federal Reserve, FDIC, OCC, and FFIEC proposals arising from the speech, particularly any proposal to index fixed-dollar thresholds, revise community-bank classifications, modify large-bank tailoring, or amend Regulation O.
• Community banks should consider assessing how a future increase in the Community Bank Leverage Ratio eligibility threshold or broader community-bank treatment could affect capital planning, reporting, examination scope, and supervisory expectations; the speech does not yet establish eligibility changes beyond the 8 percent ratio already effective July 1, 2026.
• Banks preparing mergers may wish to document the competitive effects of credit unions, nonbank lenders, Farm Credit institutions, branchless banks, and other local competitors in anticipation of possible changes to Federal Reserve merger analysis.
• Prospective de novo applicants should consider reviewing business plans, initial and ongoing capital assumptions, governance arrangements, and expected approval timelines against existing federal and state requirements while awaiting any clarification of standards or conditional-approval practices.
• Call Report filers may wish to review the December 2025 FFIEC request for information and preserve data on duplicative, low-value, or operationally burdensome reporting items for future comment opportunities.
• Banks may wish to map current supervisory issues and examination findings to material financial risks, recognizing that the Statement of Supervisory Operating Principles emphasizes prompt escalation and proportionate action rather than checklist-driven process findings.
• Community banks should consider comparing their third-party risk-management programs with the Federal Reserve's community-bank third-party risk-management guide and documenting due diligence, contract oversight, ongoing monitoring, and escalation practices.
• Boards and senior management may wish to track forthcoming CAMELS revisions and assess potential effects on management-rating governance, examination preparation, remediation prioritization, and communications with directors.

What changed

The Federal Reserve announced that it is beginning to realign its supervisory function into five geographic regions led by regional leaders accountable for all supervisory activity in each region, while retaining existing Reserve Bank staff and footprints. The speech states that the Board will later in 2026 consider increasing fixed-dollar asset thresholds in its regulations and establishing a five-year adjustment mechanism tied to inflation and economic growth.

Key dates

2026-05-13

MAS published its consultation on proposed TLAC requirements for Singapore DSIBs and draft amendments to the Financial Services and Markets Act 2022.

2026-06-04

The published consultation materials stated the proposed external TLAC level of 14% of risk-weighted assets for local-bank DSIBs; the consultation period ran through June 2026.

2026-09-08

The Financial Services and Markets (Amendment) Bill 2026 was introduced for first reading in Parliament.

2026-10-06

Second reading speech delivered by Alvin Tan on behalf of the Minister-in-charge of MAS.

Suggested considerations

• DSIBs should consider mapping existing capital, subordinated debt, eligible senior unsecured debt and other potentially qualifying resources against the proposed TLAC eligibility criteria, without assuming that consultation proposals are final.
• DSIBs should consider modelling the potential impact of the consulted 14% of risk-weighted assets external-TLAC level, including the proposed exclusion of capital conservation buffer CET1 from double-counting and any applicable leverage or internal-TLAC requirements.
• DSIBs should consider reviewing funding, issuance and investor-distribution strategies because instruments issued to Singapore retail investors may not qualify as TLAC under the consulted framework.
• DSIBs should consider preparing systems and governance for TLAC reporting, public disclosure, data ownership, instrument eligibility attestations and eventual implementation-period tracking.
• All MAS-supervised financial institutions should consider refreshing proliferation-financing risk assessments, customer and transaction-screening controls, escalation procedures and management information so that controls clearly address proliferation-financing risks separately from money laundering and terrorism financing.
• Compliance teams should consider reviewing information-sharing and supervisory-cooperation procedures for requests involving proliferation-financing supervision by MAS, Singapore authorities or foreign counterpart authorities.
• Legal and regulatory teams should monitor Parliament's passage of the Bill, subsidiary legislation, MAS notices or regulations, and the Gazette commencement notification before treating the proposed obligations as legally effective.

What changed

The Bill would insert a new Division 3 in Part 7 of the Financial Services and Markets Act 2022, empowering MAS to require notified Division 6 financial institutions, including Singapore DSIBs, to maintain a minimum level of TLAC. The framework is expected to address the required TLAC level, eligible instruments and other financial resources, public disclosures, reporting and implementation timing.

Key dates

2026-10-06

The proposed rule was published in the Federal Register at 91 FR 63676 and the comment period opened.

2026-12-07 Deadline

Comments on the proposed rule are due to the SEC.

Suggested considerations

• Compliance teams may wish to determine whether existing or proposed fund products could use the regulated-fund performance-compensation pathway and map each arrangement against the proposed 20% net-gains cap, specified-period methodology, governance requirements, and board-determination condition.
• Advisers and fund sponsors should consider inventorying current performance-fee arrangements and identifying clients who could become eligible under the proposed accredited-investor route, without treating the proposal as authority to implement changes before adoption and an applicable compliance date.
• Fund sponsors may wish to assess the operational and disclosure impact of separately reporting performance-based compensation in Forms N-1A, N-2, and N-CSR, including fee-table, prospectus, financial-reporting, and board-material changes.
• Adviser compliance programs should consider reviewing Rule 205-3 eligibility controls, investor-classification procedures, accredited-investor evidence, client look-through analysis, and controls for the related Rule 203A-3, Rule 204-3, and Form ADV amendments.
• Fund boards and advisers may wish to evaluate how performance-fee proposals would affect fiduciary-duty analysis, conflicts management, valuation, incentive alignment, investor communications, and approval documentation.
• Affected firms should consider submitting comments by December 7, 2026, particularly on the 20% cap, specified performance period, governance conditions, disclosure design, accredited-investor eligibility, and transition or compliance-period issues.

What changed

Proposed amendments to Investment Advisers Act Rule 205-3 would create an additional route for registered investment advisers to receive compensation based on capital gains or capital appreciation from registered management investment companies and business development companies, collectively referred to as regulated funds.

Key dates

2026-10-06

The proposed rule was published in the Federal Register as 91 FR 63870, covering pages 63870-64103.

2026-12-07 Deadline

Public comments must be received by the SEC on or before this date.

Suggested considerations

• Compliance teams may wish to determine whether client or fund crypto assets are currently held through arrangements that would constitute adviser or regulated-fund self-custody under the proposal, including arrangements involving service providers, private keys, wallets, or decentralized finance protocols.
• Firms should consider mapping proposed requirements for key management, joint authorization, asset segregation, safeguarding expertise, cybersecurity, incident response, annual review, internal control reporting, and client or investor account statements against existing custody, information-security, and operational-resilience controls.
• Advisers and regulated funds may wish to assess whether existing custodians, including state trust companies, could satisfy the proposed authorization, policy, audit, internal-control, and segregation conditions.
• Compliance teams should consider preparing comments for File No. S7-2026-35 by December 7, 2026, particularly on the proposed scope of self-custody, the qualified-custodian determination, treatment of airdropped crypto assets, decentralized finance activity, and the interaction with existing custody arrangements.
• Firms should assess potential changes to Form ADV, Form ADV-E, Form N-CEN, custody records, crypto-network records, audited financial statements, and accountant reports if the proposal is adopted.
• Investment advisers and regulated funds may wish to inventory tokenized private funds and tokenized regulated-fund shares in anticipation of the proposed additional Form ADV and Form N-CEN questions.
• Firms should distinguish proposal-stage planning from current legal obligations because the publication does not itself impose the proposed requirements and does not establish a final compliance date.

What changed

The proposal would add an adviser self-custody framework under proposed Advisers Act rule 223-1(b)(7), allowing an adviser to self-custody client crypto assets only in specified circumstances and subject to conditions addressing safeguarding expertise, documented safeguarding systems, key management, joint authorization, segregation, cybersecurity risk assessment, threat and vulnerability management, incident response and recovery, annual review, an internal control report, and client account statements.

Key dates

2026-09-14

EDGAR Release 26.3 was deployed. LIVE and TEST submissions became available for ANE Exception Notices, withdrawals, Form 1, and specified Form 1 variants; the revised EDGAR functionality and interfaces became operational.

2026-10-06

The final rule became effective, and incorporation by reference of the revised EDGAR Filer Manual Volume II, Version 78, into the Code of Federal Regulations was approved.

2026-12-31 Deadline

Last day on which ANE Exception Notices and withdrawals may be submitted by email.

2027-01-01 Deadline

ANE Exception Notices and withdrawals must be submitted electronically through the EDGAR online interface or by filer-constructed EDGAR submission; email submissions will no longer be accepted.

2027-03-01 Deadline

Last day on which Form 1 and specified Form 1 variants may be filed in paper.

2027-03-02 Deadline

Form 1 and specified variants must be submitted electronically through the EDGAR online interface or by filer-constructed EDGAR submission; paper filings will no longer be accepted.

Suggested considerations

• Compliance teams may wish to identify all ANE Exception Notices and withdrawals that could be submitted between January 1, 2027 and December 31, 2026, and establish procedures using the EDGAR online interface or filer-constructed submissions before the mandatory transition.
• Affected Form 1 filers may wish to obtain or validate EDGAR access, submit Form ID where required, and migrate filing procedures from paper to the EDGAR interface or filer-constructed submissions before March 2, 2027.
• Firms may wish to use the EDGAR test environment and, where applicable, the EDGAR Beta environment to test user access, filer-constructed submissions, validation, acknowledgments, and correction workflows.
• Filing teams may wish to update internal checklists and software templates for the corrected Forms 13F and 13F-CTR reference to Special Instruction 4.
• XBRL filers and filing agents may wish to replace references to the former Volume II XBRL instructions with the EDGAR XBRL Guide and confirm that current taxonomies and technical specifications are being used.
• Firms may wish to retain evidence of successful testing, accepted submissions, filing acknowledgments, and fallback procedures during the transition periods.
• Compliance teams may wish to review EDGAR access credentials, CIK status, delegated filing permissions, and responsible-person coverage for any filer converting from paper to electronic filing.

What changed

EDGAR Release 26.3 was deployed on September 14, 2026, and the SEC adopted the corresponding Filer Manual amendments as Version 78. Technical instructions for submitting XBRL documents were removed from Filer Manual Volume II and relocated to the EDGAR XBRL Guide. EDGAR submission templates for Forms 13F and 13F-CTR were corrected so that the cover-page reference points to Special Instruction 4 rather than Special Instruction 5.

Key dates

2020-12-23

FinCEN published the NPRM at 85 FR 83840 proposing additional reporting, recordkeeping, and identity-verification requirements for certain transactions involving unhosted or otherwise covered wallets.

2026-10-06

FinCEN withdrew the NPRM and stated that it would take no further action on that rulemaking.

Suggested considerations

• Compliance teams may wish to remove implementation workstreams, testing scenarios, and policy language that were created solely for the withdrawn NPRM's proposed $3,000 recordkeeping or $10,000 reporting thresholds.
• Firms should consider documenting that the NPRM was never effective and that its withdrawal does not eliminate existing obligations under the Bank Secrecy Act or applicable implementing regulations in 31 CFR parts 1010, 1020, and 1022.
• Banks and MSBs may wish to reassess whether current controls for transfers involving unhosted wallets remain risk-based and supported by documented AML risk assessments, rather than treating the withdrawn proposal's thresholds as mandatory rules.
• Crypto businesses should continue reviewing applicable customer-identification, customer-due-diligence, suspicious-activity-reporting, recordkeeping, transaction-monitoring, and OFAC sanctions requirements independently of this withdrawal.
• Regulatory-monitoring teams may wish to track whether FinCEN or Treasury develops a replacement digital-asset framework, particularly in light of the stated policy objective that digital-asset regulation be fit for purpose.

What changed

FinCEN withdrew the NPRM published at 85 FR 83840 and stated that it will take no further action on that rulemaking. The withdrawn proposal would have required banks and money services businesses to file reports when a transaction involving an unhosted or otherwise covered wallet exceeded $10,000, or multiple such transactions exceeded $10,000 in 24 hours. It also would have required records, counterparty information, and customer identity verification for covered transactions exceeding $3,000.

Key dates

2023-10-23

FinCEN published the proposed section 311 finding and special measure concerning international CVC mixing at 88 FR 72701.

2026-10-06

FinCEN's withdrawal of the finding and proposed rulemaking became effective upon Federal Register publication at 91 FR 63513.

Suggested considerations

• Compliance teams should discontinue implementation work that was undertaken solely for the withdrawn section 311 CVC-mixing proposal, including plans for the proposal-specific data fields, reporting workflows, and enhanced customer records.
• Firms should not interpret the withdrawal as authorization to process illicit mixer activity without controls; they should continue applying existing risk-based AML, sanctions, transaction-monitoring, escalation, and suspicious activity reporting procedures.
• Crypto exchanges and other covered institutions should review whether current transaction-monitoring scenarios appropriately identify mixer exposure and other indicators of money laundering or terrorist financing under existing requirements, without treating all privacy-preserving activity as inherently suspicious.
• Firms may wish to document the withdrawal in their regulatory inventory, rulemaking-impact assessments, and model or procedure change logs, while preserving controls that address independently applicable BSA or sanctions requirements.
• Compliance teams should monitor future FinCEN notices, section 311 actions, enforcement activity, and interpretive guidance because FinCEN expressly reserved the possibility of future measures concerning mixers.
• Legal and compliance functions should reassess any customer, product, or transaction restrictions adopted specifically in anticipation of the proposed rule and determine whether they remain justified by the firm's risk assessment, other legal requirements, or contractual obligations.

What changed

FinCEN withdrew the proposed rule published at 88 FR 72701 and the underlying section 311 finding concerning international CVC mixing. The proposed special measure one regime would have required covered financial institutions to report specified information for transactions they knew, suspected, or had reason to suspect involved international CVC mixing, including CVC type and amount, mixer and wallet information, transaction hashes, transaction dates, IP addresses, customer-identifying information, and a narrative description.

Key dates

2026-10-05

The CFTC Chairman announced the proposed Regulation CTX and Regulation CAM framework, and independent industry reporting identified the accompanying action as an advance notice of proposed rulemaking.

Suggested considerations

• Compliance teams may wish to monitor the Federal Register for publication of the CTX/CAM ANPRM and calculate the 60-day comment period from the actual publication date rather than from the Chairman’s October 5 statement.
• Affected exchanges should map each product and customer flow against margin, leverage, financing, custody, settlement, and internal-ledger features to determine whether the activity could fall within the proposed CTX concept.
• State-licensed platforms may wish to assess the strategic and operational consequences of pursuing a CFTC registration pathway instead of relying solely on state money-transmitter licenses.
• Firms may wish to review governance, conflicts-of-interest controls, market surveillance, anti-manipulation controls, customer-asset segregation, operational resilience, disclosure, and recordkeeping capabilities against existing CFTC designated contract market and customer-protection expectations.
• Exchanges and service providers may wish to prepare comments addressing the scope of Section 2(c)(2)(D), the treatment of fully paid transactions, the boundary between spot trading and financed transactions, and the interaction between CAM registration and state licensing.
• Legal and compliance functions may wish to inventory crypto assets and classify them consistently with the referenced joint CFTC-SEC interpretation, while preserving separate analysis for assets that may constitute securities or fall outside the proposed framework.
• U.S.-facing offshore platforms should reassess territorial exposure and customer-access controls because the proposal may create a clearer federal compliance pathway without eliminating potential CFTC jurisdiction over unregistered or fraudulent activity.

What changed

The CFTC is proposing to use its existing Commodity Exchange Act authority, including Section 2(c)(2)(D), to develop a purpose-built framework for crypto asset transactions and markets. Regulation CTX would address retail crypto transactions involving margin, leverage, or financing. Regulation CAM would establish a tailored category of CFTC-registered crypto asset market, apparently as a specialized form of designated contract market, for exchanges offering those transactions.

Key dates

2026-10-05

Chairman Michael S. Selig delivered the remarks at the Fordham Law Blockchain Regulatory Symposium and publicly described the CFTC-SEC crypto-asset classification framework and the shift toward formal crypto market regulation.

Suggested considerations

• Compliance teams may wish to inventory each supported token and document its likely classification under the five-category framework, including the facts supporting treatment as a digital commodity, digital collectible, digital tool, stablecoin, or digital security.
• Firms may wish to reassess whether their products involve retail commodity transactions under CEA section 2(c)(2)(D), including transactions involving margin, leverage, financing, or other arrangements that may require execution on or registration with a CFTC-registered venue.
• Crypto exchanges and trading platforms may wish to assess whether their activities could require DCM registration, a future crypto-asset-market registration, SEC registration, or multiple registrations depending on the asset and service provided.
• Issuers and platforms may wish to preserve evidence concerning network functionality, decentralization, token utility, marketing, purchaser expectations, transfer restrictions, and the separation of a crypto asset from any investment contract.
• Firms may wish to maintain controls addressing customer-asset segregation, custody, conflicts of interest, orderly trading, market surveillance, anti-manipulation, recordkeeping, and AML obligations, because the speech criticizes state money-transmission licensing as insufficient to provide federal market protections.
• Legal and regulatory teams may wish to monitor the CFTC and SEC rulemaking dockets and distinguish the Chairman's personal views, the joint interpretation, proposed rules, and any final rules or effective compliance dates.
• U.S. and offshore groups serving U.S. customers may wish to reassess their territorial and solicitation controls because the policy direction is intended to offer a federal pathway without eliminating the risk of CFTC or SEC jurisdiction over offshore conduct.

What changed

The Chairman described a joint CFTC-SEC interpretation that classifies crypto assets into five categories: digital commodities, digital collectibles, digital tools, stablecoins, and digital securities. The interpretation reportedly provides that digital commodities, digital collectibles, and digital tools are generally not securities; stablecoins may in some circumstances be securities; and digital securities remain subject to the federal securities laws.

Key dates

2026-10-05

CFTC published Release 9307-26 announcing the ANPRM and beginning consultation on a potential framework for crypto asset transactions and crypto asset markets.

Suggested considerations

• Compliance teams may wish to determine whether current or planned products involve retail commodity transactions under CEA Section 2(c)(2)(D), particularly where crypto assets are leveraged, margined, financed, or embedded in derivatives or perpetual-style products.
• Firms should consider mapping their customer-facing crypto activities, order execution arrangements, custody model, financing terms, liquidation processes, conflicts, market-abuse controls, and consumer disclosures against the issues identified in the ANPRM.
• Potential commenters may wish to prepare submissions addressing the scope of CTXs, the proposed treatment of spot versus financed transactions, appropriate registration and supervisory requirements, and the operational feasibility of a crypto asset market category.
• Designated contract markets and prospective applicants should consider assessing whether existing governance, surveillance, listing, liquidity, technology, and risk-management controls could support a future crypto asset market registration framework.
• Firms may wish to preserve evidence of existing controls and industry practices that they regard as effective, because the CFTC is specifically seeking information on crypto-specific contextual guidance and compliance practices.
• Compliance teams should monitor the Federal Register for the ANPRM publication and calculate the 60-day comment period from that publication date rather than from the October 5 press release.
• Firms should continue complying with currently applicable CEA, CFTC, securities, commodities, consumer-protection, AML, and state requirements because the ANPRM does not replace or suspend existing obligations.

What changed

The CFTC has opened a consultation process and is considering future rules referred to in market commentary as Regulation Crypto Asset Transactions (CTX) and Regulation Crypto Asset Markets (CAM). The ANPRM seeks views on preventing abusive practices in crypto asset markets and CTXs, providing crypto-specific context on compliance requirements and industry practices that the Commission considers best practices, and codifying a subcategory of designated contract market registration for crypto asset markets.

Key dates

2024-09-18

The CSSF began the on-site inspection of the manager’s corporate governance framework.

2024-10-10

The CSSF completed the on-site inspection that identified persistent internal-governance and delegation-oversight deficiencies.

2026-07-09

The CSSF imposed the total administrative fine of EUR 71,500.

2026-10-05

The CSSF published the sanction decision anonymously.

Suggested considerations

• Compliance teams may wish to map every delegated portfolio manager to a documented, risk-based periodic due-diligence plan and verify that reviews are renewed at an appropriate frequency under the manager’s risk matrix.
• Firms should consider documenting assessments of each delegate’s legal and contractual compliance, control environment, best-execution procedures, broker-selection processes and relevant reporting capabilities.
• Firms should consider testing whether delegate oversight includes independent verification rather than relying exclusively on confirmations, questionnaires or representations from portfolio managers.
• Management companies may wish to establish measurable monitoring indicators, thresholds, exception escalation and evidence-retention arrangements for best-execution oversight, consistently with the applicable delegation procedures and CSSF Circular 18/698.
• Firms should consider reviewing delegation contracts, governance reporting and action plans to demonstrate that the supervisory framework protects the interests of the funds and investors and that monitoring of delegated activities remains with the manager.
• Compliance teams may wish to benchmark their controls against the CSSF’s broader thematic and enforcement messaging; independent commentary indicates that inadequate delegate supervision, weak quantitative monitoring and insufficient evidence of independent controls are recurring supervisory concerns.

What changed

This is an enforcement action rather than a new rule. The CSSF applied Article 110(1)(b) and (f), and Articles 148(2)(j) and 148(4)(e), of the amended Law of 17 December 2010 relating to undertakings for collective investment, together with Article 18(1)(e) and (f), and Article 51(1) and (2), of the amended Law of 12 July 2013 on alternative investment fund managers. The fine comprised EUR 47,320 under the 2010 Law and EUR 24,180 under the AIFM Law.

Key dates

2026-07-09

DFSA issued Consultation Paper No. 174 for public consultation.

2026-08-24 Deadline

Public-comment deadline identified in independent commentary on CP 174.

2026-10-01

DFSA published the feedback statement and the relevant final rule-making instruments.

2026-10-02

PIB Rule-Making Instrument No. 443 of 2026 came into force, implementing final prudential-reporting amendments.

2027-01-01

COB Rule-Making Instrument No. 444 of 2026 comes into force, implementing final COB amendments relevant to the CP 174 workstream.

Suggested considerations

• Compliance teams may wish to obtain and review PIB Rule-Making Instrument No. 443 of 2026 and its appendices, identifying changes to applicable prudential reporting forms, data fields, validation controls and submission procedures.
• Affected PIB firms should consider testing reporting systems and reconciliations against the amended requirements and documenting ownership for any revised regulatory returns that are already effective.
• Credit rating agencies may wish to map existing independence, conflict-of-interest, employee-related restriction and rating-announcement disclosure controls against COB Rule-Making Instrument No. 444 of 2026 before its 1 January 2027 commencement.
• Firms should distinguish the final PIB and COB amendments from the still-pending Crypto and Investment Token proposals and avoid treating the latter as current DFSA requirements.
• Governance and regulatory-change teams may wish to retain the CP 174 feedback statement, final instruments and archived prior rulebook versions to evidence implementation decisions and change impact assessments.

What changed

The DFSA published final rule-making instruments for amendments arising from CP 174. The PIB Rule-Making Instrument No. 443 of 2026, covering prudential reporting requirements, came into force on 2 October 2026. The COB Rule-Making Instrument No. 444 of 2026, which contains final amendments relevant to the credit rating agency framework, will come into force on 1 January 2027.