A&O Shearman | FinReg | Blog
Financial Regulatory Developments Focus
This links to the home page

Filters
The following posts provide a snapshot of selected UK, EU and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructures, asset managers and corporates.
  • FSB and IOSCO publish reports on implementation of global crypto-asset regulatory frameworks
    16 October 2025

    The Financial Stability Board (FSB) has published a thematic peer review report assessing the implementation progress of its 2023 global regulatory framework for crypto-asset activities. As of August of this year, the review shows that while many jurisdictions have made notable progress in regulating crypto-asset activities, there has been slower progress in finalising their global stablecoin arrangements (GSCs). Even where regulatory frameworks have been finalised, alignment with FSB recommendations remains limited, especially regarding stablecoin arrangements and crypto-asset service providers (CASPs). These gaps could pose risks to financial stability and to the development of a resilient digital asset ecosystem.

    In response to the concerns, the report sets out eight recommendations to address outstanding issues in the following key areas set out below.

    Read more.
    Topic : FinTech
  • BoE publishes terms of participation for new Synchronisation Lab to launch in spring 2026
    16 October 2025

    The Bank of England (BoE) has published the terms of participation for its upcoming Synchronisation Lab which will support the testing and refinement of a proposed synchronisation capability for the UK's renewed Real-Time Gross Settlement (RTGS) service, RT2. Synchronisation would allow for atomic settlement in central bank money: the conditional settlement of funds in RT2 against assets on a variety of external asset ledgers, meaning that funds in RT2 will settle if and only if the external asset also settles. The Lab is being launched as a platform to simulate the synchronisation interface enabling prospective synchronisation operators (Lab Participants), to develop and demonstrate viable propositions across multiple use cases.

    The Lab is scheduled to launch in Spring 2026 and will run for approximately six months across four six-week testing and development phases. In each phase, Lab Participants will showcase end-to-end synchronised transaction flows and interact with synchronisation users. Lab findings will inform the design and delivery of a potential future live RT2 synchronisation capability. Participation is by invitation by the BoE and based on an application process. Technical onboarding will begin roughly one month before launch. Demonstrations and a final report summarising key learnings will follow the Lab's conclusion.
  • ESMA publishes second consolidated report on sanctions for 2024
    16 October 2025

    The European Securities and Markets Authority (ESMA) has published its second consolidated report on sanctions and measures imposed by national competent authorities in Member States in 2024. The report reveals that over 970 administrative sanctions and measures were issued in financial sectors under ESMA's remit, with the total aggregated value of administrative fines exceeding EUR100 million, an increase compared to 2023. The highest number of administrative sanctions and measures were imposed under the Market Abuse Regulation (MAR), the Markets in Financial Instruments Directive (MiFID) and the Markets in Financial Instruments Regulation (MiFIR).

    The highest amounts of administrative fines for 2024 were imposed under MAR. The more granular data shows that over 60% of all administrative sanctions and measures imposed in 2024 were administrative fines, and 10% were issued using settlement procedures. ESMA also reports that no sanctions or measures were imposed under the Securities Financing Transactions Regulation (SFTR) or the Markets in Crypto-Assets Regulation (MiCAR), while a measure was issued for the first time under the European Crowdfunding Service Providers Regulation. ESMA highlights discrepancies in sanctioning powers across jurisdictions, including differences in the amounts of fines, number and types of sanctions and measures, and use of settlements.
  • BoE publishes approach to responsible innovation in AI, DLT and quantum computing
    15 October 2025

    The Bank of England (BoE) has published its approach to supporting responsible innovation across artificial intelligence (AI), distributed ledger technology (DLT) and quantum computing. Recognising these as potentially transformative technologies, the BoE emphasises its role in enabling safe adoption while safeguarding monetary and financial stability. The BoE acknowledges that these technologies will significantly impact the work it does, from setting interest rates, to maintaining financial stability, to operating the UK's core payments infrastructure. It also highlights its responsibility to understand and manage the risks and opportunities these innovations present.

    To foster a resilient and innovation-friendly environment, the BoE sets out the following three key regulatory levers.

    Read more.
  • EBA publishes 2024 annual report on supervisory convergence
    15 October 2025

    The European Banking Authority (EBA) has released its 2024 annual report on the convergence of supervisory practices across the EU. The report outlines the EBA's ongoing efforts to strengthen the alignment of supervisory approaches across Member States and across key areas of its activities, including prudential, resolution, digital finance, consumer protection and until the end of this year anti-money laundering/counter-terrorist financing (AML/CFT). In the area of prudential regulation, the report reflects on findings from its 2024 European Supervisory Examination Programme focused on liquidity and funding risk, interest rate risk and hedging, and recovery operationalisation. The report notes that risk levels in these areas remain stable, though challenges persist around data quality, stress testing scenarios and modelling assumptions. The EBA will continue monitoring risks related to online deposit platforms and compliance with Supervisory Outlier Tests in 2025.

    Read more.
  • UK FCA consults on progressing fund tokenisation
    14 October 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/28, accompanied by a press release, outlining proposals to accelerate the adoption of tokenisation and tokenised funds in the UK. The proposals apply to authorised funds but the FCA's discussion and roadmap sections may be of wider interest to fund and asset managers, including managers of non-authorised funds. The FCA's proposals address fund tokenisation, and do not address unbacked assets such as cryptocurrencies.

    The FCA's proposals include:
    • Guidance for operating a tokenised fund under the Blueprint model.
    • Rules and guidance for an alternative, streamlined dealing model for conventional and tokenised authorised funds, referred to as 'direct to fund' (D2F). D2F has wider application than just to tokenised funds, but the FCA thinks allowing this new dealing model will enable tokenisation.
    • A roadmap to advance fund tokenisation and address key barriers.
    • A discussion on future tokenisation models that use DLT to provide tokenised portfolio management at retail scale and how regulation may need to change to be fit for the future.

    The deadline for responses to the consultation proposals is 21 November, except for the discussion chapter on future tokenisation models, which is 12 December. The FCA expects to publish a policy statement with final rules in the first half of 2026.
  • UK FCA announces partnership to accelerate delivery of open finance in UK
    13 October 2025

    The UK Financial Conduct Authority (FCA) has announced a major new partnership and the launch of two TechSprints aimed at accelerating the delivery of open finance in the UK. The announcement follows the FCA's January letter to the Prime Minister which reaffirmed the FCA's commitment to promote digital innovation, particularly in small and medium-sized enterprise (SME) lending. To support this vision, the FCA commissioned KPMG and Europe Economics to carry out work to assess the potential benefits of open banking and open finance for consumers and the financial services sector.

    As part of its broader innovation strategy, the FCA confirms that its recently launched Smart Data Accelerator, an extension of the FCA's sandbox, will enable the testing of real uses of open finance in practice. The FCA is also collaborating with Raidiam to use its testing environment, which will provide Smart Data Sprint participants with access to a stable environment that mirrors real-world conditions. Following the FCA's Open Finance Sprint held in March, and the publication of the FCA's outcomes report in July, the two upcoming TechSprints will take place between 17 November and 12 February 2026, with separate focuses on mortgages and finance for SMEs. The sprints are now open for registration until 2 November. The FCA will set out a roadmap for open finance by March 2026.
    Topic : FinTech
  • EBA issues opinions on amendments to draft RTS on prudential matters under MiCAR
    10 October 2025

    The European Banking Authority (EBA) has published two opinions in response to the European Commission's (EC) proposed amendments to the draft regulatory technical standards (RTS) concerning the composition and liquidity requirements of the reserve of assets under the Markets in Crypto-Assets Regulation (MiCAR). The EBA considers the EC's proposed changes to be inconsistent with the prudential framework established by MiCAR. The first opinion (EBA/Op/2025/13) addresses amendments to the final draft RTS on liquidity requirements of the reserve of assets. The second opinion (EBA/Op/2025/14) concerns amendments to the final draft RTS on the highly liquid financial instruments (HLFI) with minimal market risk, credit and concentration risk.

    Read more.
    Topic : FinTech
  • UK DRCF launches new Thematic Innovation Hub and publishes call for views on agentic AI
    10 October 2025

    The Digital Regulation Cooperation Forum (DRCF) has announced the launch of its new Thematic Innovation Hub. Building on the success of the AI and Digital Hub pilot, the Thematic Hub will provide tailored regulatory advice on priority topics, with its first thematic focus centred on agentic AI – AI systems capable of autonomous decision-making and initiating actions without direct human prompts. As part of this new approach, the DRCF has also published a "call for views" seeking input on the regulatory challenges and opportunities associated with agentic AI. The call for views consists of six questions that stakeholders may choose to respond to or share other insights that they believe are relevant.

    The deadline for submissions is 6 November. The DRCF clarifies that it does not intend to issue advice or guidance in response to submissions; the aim is to gather insights to inform future thematic work. Accompanying the launch, the DRCF has published an insights paper that shares learnings from the pilot phase of its AI and Digital Hub.
  • EBA publishes report on tackling ML/TF risks in crypto-asset services
    9 October 2025

    The European Banking Authority (EBA) has published a report addressing money laundering and terrorist financing (ML/TF) risks in crypto-asset services, including issuance, trading and service provision. Drawing on lessons from recent supervisory cases across the EU and engagement with national supervisors, the report identifies vulnerabilities in the sector and offers guidance to strengthen compliance and oversight. It examines strategies used by certain crypto-asset service providers and issuers to side-step national AML/CFT supervision, including through unauthorised operations, forum shopping and improper use of certain regulatory exemptions. The report also outlines safeguards introduced by MiCAR and the AML/CFT regime, stating that effective implementation will depend on proactive monitoring of unauthorised activities, continuous risk identification and strong cross-border cooperation, amongst others.
  • Delegated Regulation under MiCAR on liquidity management for ARTs and EMTs published in OJ
    3 October 2025

    Delegated Regulation 2025/1264 supplementing Regulation (EU) 2023/1114 (Markets in Crypto Assets Regulation) has been published in the Official Journal of the European Union. The Delegated Regulation (adopted by the European Commission on 27 June) sets out regulatory technical standards (RTS) specifying the minimum contents of the liquidity management policy and procedures for certain issuers of asset-referenced tokens and e-money tokens. The RTS aim to ensure that issuers maintain robust liquidity frameworks capable of withstanding both normal and stressed market conditions. The Regulation enters into force on 23 October.
    Topic : FinTech
  • ESMA publishes 2026 annual work programme
    3 October 2025

    The European Securities and Markets Authority (ESMA) has published its 2026 annual work programme, guided by its 2023-2028 strategy.

    Key priorities include: (i) continuing to build on existing priorities under the savings & investments union (SIU) strategy particularly by aligning supervisory practices across Member States, enhancing market data capabilities and contributing to upcoming reforms designed to create a more integrated and globally competitive EU financial system; (ii) continuing support for key legislative files such as the revised European Market Infrastructure Regulation (EMIR 3) and the European Single Access Point. Other legislative files that may warrant ESMA's involvement include the Retail Investment Strategy, along with the reviews of the Packaged Retail and Insurance-Based Investment Products Regulation, Sustainable Finance Disclosure Regulation and the Securitisation Regulation; and (iii) driving data innovation and market integration through the rollout of the ESMA Data Platform and the development of AI-powered supervisory tools. ESMA will also continue to focus on the effective implementation of the Markets in Crypto Assets Regulation, particularly on the authorisation and supervision of crypto-asset service providers and coordinate closely with market participants on the T+1 settlement cycle towards the agreed implementation date of 11 October 2027.

    Alongside the work programme, ESMA has published its simplification and burden reduction document, outlining upcoming publications expected in Q1 and Q2 2026 aimed at streamlining regulatory requirements and reducing compliance burdens.
  • EBA 2026 work programme for a more efficient EU regulatory and supervisory framework
    1 October 2025

    The European Banking Authority (EBA) has published its 2026 work programme, setting out its key priorities and planned initiatives. The programme is driven by three overarching priorities: (i) developing a rulebook to foster a resilient and efficient financial single market, with proposals to simplify rules, improve public sector coordination and assess the framework's impact. This includes continuing work on the EU banking package and advancing proposals on the forthcoming revised Payment Services Directive 3, the Payment Services Regulation and the Financial Data Access Act; (ii) strengthening risk assessment capabilities through improved data, methodologies and oversight under the Digital Operational Resilience Act (for critical ICT third-party providers), Markets in Crypto-Assets Regulation (for supervision of crypto-asset issuers) and European Market Infrastructure Regulation (for validation of initial margin models); and (iii) advancing innovation and technological capacity across the financial sector, with a focus on AI and machine learning, including its contribution to the implementation of the EU AI Act. In parallel, the EBA has published a report (EBA/REP/2025/26) proposing ways to streamline the EU's regulatory and supervisory framework, following a comprehensive review earlier this year of four key areas: level 2 and 3 measures, reporting burdens on financial institutions, the EBA's role in the prudential framework and its internal processes. The review resulted in 21 recommendations which are set out in the report.
  • HMT and U.S. Treasury establish a "Transatlantic Taskforce for Markets of the Future"
    22 September 2025

    HM Treasury has announced the formation of a "Transatlantic Taskforce for Markets of the Future", jointly established by UK Chancellor Rachel Reeves and U.S. Treasury Secretary Scott Bessent. The Taskforce aims to strengthen collaboration between the UK and U.S. financial systems, particularly in capital markets and digital assets. Reporting back with recommendations to both ministries through the UK-U.S. Financial Regulatory Working Group (FRWG), the Taskforce will explore short- and long-term opportunities on digital assets while legislation and regulatory regimes are still developing, and in wholesale digital markets innovation. It will also assess ways to reduce cross-border capital-raising burdens and enhance market competitiveness in both UK and U.S. markets. The Taskforce is expected to deliver its recommendations within 180 days.
  • UK FCA consults on rules and guidance for regulated cryptoasset activities
    17 September 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/25 (CP), alongside a press release, setting out its proposed regulatory framework for cryptoasset activities under the Financial Services and Markets Act 2000 (FSMA). This follows HM Treasury's (HMT) draft statutory instrument (SI) to bring qualifying cryptoasset activities within the scope of the Regulated Activities Order 2001 (RAO) and under the FCA's remit. Qualifying cryptoasset activities will include issuing qualifying stablecoins, safeguarding qualifying cryptoassets and specified investment cryptoassets, operating a qualifying cryptoasset trading platform (CATP), intermediation and staking. Firms and individuals undertaking these activities will require FCA authorisation before operating by way of business in the UK.

    Read more.
  • Two EU Regulations on ART authorisation applications published in OJ
    15 September 2025

    Two Commission Regulations supplementing the Markets in Crypto-Assets Regulation have been published in the Official Journal of the European Union (OJ), namely the:
    Both Regulations enter into force on the 20th day following publication in the OJ and apply from 5 October.
    Topic : FinTech
  • Wolfsberg Group issues guidance on the provision of banking services to fiat-backed stablecoin issuers
    8 September 2025

    The Wolfsberg Group has published comprehensive guidance on managing financial crime risks for financial institutions (FIs) that provide banking services to fiat-backed stablecoin issuers. While recognising the legitimate benefits of stablecoins, such as pseudonymity, rapid settlement and global reach, the Group also highlights that these same benefits introduce unique risks. The guidance therefore introduces a risk-based framework for assessing and monitoring relationships with issuers operating in regulated jurisdictions. It notes that although existing financial crime risk management principles remain applicable, existing controls may require adapting to address the specific risks posed by stablecoin issuers. The guidance introduces the relevant terminology used by the Group on stablecoins and describes the typical fiat-based services an FI may offer to a stablecoin issuer, highlighting how financial crime-related controls may require adjustment. It also explains how, under a risk-based approach, an FI may evaluate the issuer's compliance obligations on the blockchain. Ultimately, the Group's view is that the approach to banking a stablecoin issuer mirrors that of any customer relationship: firstly to identify and understand the risks associated with both the customer and the nature of the relationship, as well as evaluate how the issuer manages those risks; secondly to determine whether the issuer's risk profile and mitigation strategies align with its own risk appetite; and finally, the FI should implement a proportionate risk management framework that enables ongoing monitoring of the issuer's behaviour and supports timely corrective action when necessary.
  • HMT publishes draft SI consulting on targeted changes to MLRs
    2 September 2025

    HM Treasury (HMT) has published the draft Money Laundering and Terrorist Financing (Amendment and Miscellaneous Provision) Regulations 2025, accompanied by a policy note, for technical consultation. This follows HMT's 2024 consultation on improving the effectiveness of the UK Money Laundering Regulations (MLRs), with the government's response published in July this year. The consultation identified key weaknesses in the UK's anti-money laundering (AML) regime, including issues with pooled client accounts, trust registration, cryptoasset regulation and the practicalities of customer due diligence (CDD). The draft statutory instrument (SI) proposes targeted amendments to the MLRs 2017 and related legislation to address these concerns. The key changes are set out below.

    Read more.
  • FATF announce the launch of new NRA toolkit for AML/CFT measures
    28 August 2025

    The Financial Action Task Force (FATF) has announced the launch of a new National Risk Assessment (NRA) toolkit aimed at enhancing countries' ability to identify and address money laundering risks. The toolkit supports a risk-based approach aligned with FATF Standards and provides cross-country insights into predicate offences, laundering methods, and proceeds of crime. It focuses on four priority areas that are currently consistently challenging to assess, including: corruption, virtual assets and service providers, legal persons and arrangements, and the informal economy. Quick guides, which include practical examples, have also been published to support risk assessment in each priority area. The toolkit draws on good practices from FATF member jurisdictions and is designed to be flexible and adaptable to country-specific needs. It can be integrated into a full NRA, applied to sectoral or thematic assessments, or used to strengthen broader efforts to improve risk understanding. Coinciding with the launch, on the same day, the FATF has also updated its NRA guidance, to reflect recent changes made to its Recommendation 1 standard and guidance on financial inclusion and anti-money laundering and counter terrorist financing measures.
  • Delegated Regulation regarding RTS on market abuse under MiCAR published in OJ
    20 August 2025

    On 20 August, Commission Delegated Regulation (EU) 2025/885 supplementing the Markets in Crypto-assets Regulation with regard to regulatory technical standards specifying the arrangements, systems, and procedures for persons to prevent, detect, and report market abuse, the templates to be used for reporting suspected market abuse, and the coordination procedures between competent authorities for the detection and sanctioning of market abuse in cross-border market abuse situations, has been published in the Official Journal of the European Union (OJ). The Delegated Regulation enters into force on the twentieth day following its publication in the OJ, being 9 September.
  • EBA publishes final report on draft RTS on the prudential treatment of cryptoasset exposures
    5 August 2025

    The European Banking Authority (EBA) has published its final report containing final draft regulatory technical standards (RTS) on the prudential treatment of cryptoasset exposures under the Capital Requirements Regulation (CRR), as amended by the CRR3. The RTS specify the technical elements necessary for institutions to calculate and aggregate cryptoasset exposures in relation to the prudential treatment of such exposures. The draft RTS, initially consulted on in January, remain largely unchanged. However, in response to consultation feedback, the EBA: (i) removes the requirement for prudent valuation of fair value cryptoasset exposures; and (ii) introduces a provision clarifying how institutions should aggregate long and short positions when determining the exposure limit. Together with the transitional provisions in CRR3, the RTS provide institutions with an interim method to capitalise cryptoasset exposures until a permanent prudential framework is in place, enabling institutions to participate in the rapidly evolving crypto markets.
  • UK FCA announces retail access to crypto ETNs
    1 August 2025

    The UK Financial Conduct Authority (FCA) has announced that effective from 8 October, retail consumers will be permitted to access crypto exchange traded notes (cETNs), marking a significant shift from the current ban. This move is the latest step in the FCA's evolving approach to establishing a regulatory framework for crypto, in line with its crypto roadmap. To ensure investor protection, cETNs must be traded exclusively on an FCA-approved, UK-based Recognised Investment Exchange (RIE). Firms offering these products will be subject to financial promotion rules to avoid offering consumers inappropriate incentives to invest and to ensure consumers are provided with the right information. While the consumer duty will apply to firms offering these products to retail investors, the FCA clarifies that there will not be coverage from the Financial Services Compensation Scheme. Consumers should therefore ensure they understand the risks before deciding to invest. The existing ban on cryptoasset derivatives for retail clients remains in force.
  • UK FCA findings on digital design of loan processes in customers' online journeys
    31 July 2025

    The UK Financial Conduct Authority (FCA) has published the findings from its review on digital design in customers' online journeys when accessing consumer credit, with related press release, identifying good practices and areas for improvement. Although the findings relate to consumer credit providers, other firms with a digital presence may find the examples of good and poor practice useful. The FCA found that some firms' digital design supported good consumer outcomes, such as using simplified language and offering explainer videos. Other firms had less well-designed digital platforms. A particular issue was a lack of "positive friction", meaning consumers were driven towards making quick decisions that did not align with their best interests.

    Read more.
  • EBA issues opinion on money laundering and terrorist financing risks across the EU
    28 July 2025

    The European Banking Authority (EBA) has published its fifth opinion on money laundering and terrorist financing (ML/TF) risks. In the report, the EBA highlights the growing vulnerabilities in the EU financial sector arising from the growth of technologies, new financial products such as crypto-assets, and the increasing interconnection of financial products and services across sectors. The EBA states that while tools such as RegTech and AI offer potential for enhanced compliance, their improper implementation (often due to lack of expertise and oversight) has led to serious compliance failures. Competent authorities have reported high or rising ML/TF risks in Fintech firms and crypto-asset service providers linked to weak AML/CFT controls and governance. Additionally, the use of AI by criminals to automate laundering and forge documents is outpacing institutional defences. The EBA notes that supervisory engagement has improved the capability of some sectors to fight financial crime. The EBA emphasises the importance for consistent application of the new EU AML/CFT legal framework.
  • HM Treasury's OFSI warns of crypto sanctions risks in new threat assessment report
    21 July 2025

    The UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, has published a sector-specific threat assessment report highlighting significant compliance risks facing UK cryptoasset firms in relation to financial sanctions. Covering the period from January 2022 to May of this year, the report concludes it is "almost certain" that UK cryptoasset firms have underreported suspected sanctions breaches since being designated as "relevant firms" under the UK sanctions regulations, in August 2022. OFSI identifies inadvertent non-compliance due to direct and indirect exposure to designated persons (DPs) and sanctioned entities such as the Russian exchange Garantex, cyber threats from DPRK-linked hackers exploiting cryptoassets to evade sanctions and transfers to Iranian cryptoasset firms with suspected links to DPs. The report emphasises the importance of timely and accurate reporting, enhanced due diligence and the use of blockchain analytics to detect and mitigate sanctions risks. OFSI urges firms to adopt a risk-based approach, conduct retrospective reviews and report any suspected breaches to OFSI, the UK Financial Conduct Authority and the National Crime Agency.
  • UK NCA and FCA agree priorities to combat economic crime
    21 July 2025

    The National Crime Agency (NCA) and the UK Financial Conduct Authority (FCA) have jointly published a set of nine system priorities to combat economic crime in the UK, in line with the UK's second Economic Crime Plan and the National Risk Assessment. Backed by the Home Office, HM Treasury, the National Economic Crime Centre and UK Finance, the priorities seek to enhance public-private collaboration, enabling regulated firms to allocate resources more effectively while maintaining compliance. Key focus areas include money laundering through UK corporate structures linked to certain jurisdictions; fraud originating from international offenders; exploitation of money mules; and criminal cash consolidation via UK banking channels.

    Additional priorities target terrorist financing; sanctions evasion by professional enablers; abuse of power by overseas Politically Exposed Persons; and the resilience of the cryptoasset ecosystem against criminal abuse. The only predicate offences explicitly listed in these priorities are those which fall under the definition of economic crimes—namely fraud, sanctions evasion and terrorist financing. However, the priorities concerning money laundering methods are intended to apply to all potential predicate offences, including but not limited to organised immigration crime, drug and firearms offences and human trafficking. A newly established System Prioritisation Governance Group will oversee governance of the priorities, with further guidance expected to be published in due course to support firms in aligning with these objectives.
  • ESMA publishes Q&As under MiCAR
    18 July 2025

    The European Securities and Markets Authority (ESMA) has published two Q&As under the Markets in Crypto-assets Regulation (MiCAR), providing further guidance on the application of MiCAR to crypto-asset service providers (CASPs). ESMA_QA_2607 addresses whether MiCAR permits the staking of clients' crypto-assets by CASPs for their own account, and ESMA_QA_2608 considers whether MiCAR allows CASPs to use clients' crypto-assets for pre-funding client orders.
    Topic : FinTech
  • HMT publishes latest NRA of money laundering and terrorist financing risks
    17 July 2025

    HM Treasury has published its latest 2025 National Risk Assessment (NRA) of Money Laundering and Terrorist Financing, offering a comprehensive review of the UK's exposure to financial crime. Building on the 2015, 2017, and 2020 assessments, the 2025 NRA evaluates: (i) the UK's AML/CFT framework and the government's response to the 2020 NRA; (ii) overarching money laundering (ML) risks; (iii) overarching terrorist financing (TF) risks; (iv) sector-specific ML/TF risks under the Money Laundering Regulations (MLRs); and (v) emerging cross-cutting risks outside MLR-regulated sectors.

    Read more.
  • ECB publishes final guide on outsourcing cloud services
    16 July 2025

    The European Central Bank (ECB) has published its final guide on outsourcing cloud services, following from a July 2024 consultation. Feedback on the consultation is set out in an accompanying feedback statement. The guide clarifies supervisory expectations for banks under the ECB's remit in relation to the Digital Operational Resilience Act (DORA). While not legally binding, the guide outlines good practices for effective cloud outsourcing risk management, particularly given growing reliance on a limited number of third-party providers. Key areas covered include governance and risk management strategy, pre-outsourcing analysis, contractual arrangements, exit strategies and termination rights, and ongoing monitoring and oversight. The guide emphasises a risk-based and proportionate approach to outsourcing cloud services, tailored to the diverse structures, activities and risk profiles of ECB-supervised banks. The final version distinguishes more clearly between DORA requirements and ECB-recommended practices.
  • Mansion House: HMT policy paper on wholesale financial markets digital strategy
    15 July 2025

    HM Treasury has published a policy paper on the wholesale financial markets digital strategy. The purpose of the strategy is to ensure the UK benefits from opportunities to improve its wholesale financial markets, by using new technologies effectively. This policy spans trading venues, clearing houses, settlement systems, payment systems and other elements of the UK's financial ecosystem that support the operation of financial markets. The policy is structured as focusing on three areas: (i) market optimisation – which includes removing paper-based and manual processes, and using data effectively; (ii) market transformation – which centres on proactive innovation for new models across the range of market activities and includes taking forwards the issuance of the UK's digital gilt instrument (DIGIT) using distributed ledger technology (please see above for HM Treasury's policy paper for further detail); and (iii) market leadership – where the UK government has committed to working with the sector to develop a cross-cutting approach which will seek to reduce potential fragmentation and regulatory barriers, and to appointing an industry expert "Digital Markets Champion".
  • Mansion House: HMT policy paper with update on the digital gilt instrument (DIGIT) pilot
    15 July 2025

    HM Treasury (HMT) has published a policy paper on its update on the digital gilt instrument (DIGIT) pilot. The paper follows the Preliminary Market Engagement Notice (PMEN), which closed in April and which was the first stage of the procurement process. The pilot, part of the UK's broader strategy to explore distributed ledger technology (DLT) in sovereign debt issuance, seeks to: (i) enable the UK government to explore applications of DLT across the UK sovereign debt issuance lifecycle; and (ii) support the growth of UK-based DLT infrastructure and its adoption in financial markets. To meet these aims, the PMEN outlined an initial set of designs, including that DIGIT will be digitally native, short-dated, issued on a platform within the Digital Securities Sandbox (DSS) and separate from the government's debt issuance programme. 

    Read more.
    Topic : FinTech
  • ESMA publishes final guidelines under MiCAR for CASP staff providing crypto-asset information
    11 July 2025

    The European Securities and Markets Authority (ESMA) has published its final guidelines under the Markets in Crypto-Assets Regulation (MiCAR) specifying the criteria for assessing the knowledge and competence of staff at crypto-asset service providers (CASPs). Aimed at enhancing investor protection and trust in the crypto-asset sector, the guidelines: (i) outline the minimum professional qualifications and experience required for staff providing information or advice on crypto-assets; (ii) set out the organisational requirements for assessment, maintenance and updating of knowledge and competence; and (iii) address specific risks associated with the crypto-asset market, such as high volatility and cybersecurity, by setting out the assessment criteria for staff knowledge and skills. The guidelines will be translated into all EU languages and will apply six months after publication. Competent authorities must notify ESMA within two months of publication whether they comply or intend to comply with guidelines.
    Topic : FinTech
  • ESMA statement advises CASPs on mitigating investor risks over unregulated products
    11 July 2025

    The European Securities and Markets Authority (ESMA) has issued a public statement addressed to crypto-asset service providers (CASPs) that offer both regulated and unregulated services under the Markets in Crypto-Assets Regulation (MiCAR). ESMA calls on CASPs to avoid creating investor confusion about the regulatory protections that apply to unregulated products and services. To address this risk, ESMA reminds CASPs of their obligation to act fairly, professionally and in the best interests of their clients, to avoid any conduct that can mislead or confuse them. In the statement, ESMA also cautions against CASPs using their regulated status as a marketing tool to promote unregulated services, as this can further contribute to investor misunderstanding. To mitigate these risks, ESMA encourages CASPs to adopt all necessary measures and provides a practical table of "dos and don'ts". This includes measures such as maintaining clear and effective communication with clients at every stage of the sales process, ensuring marketing materials are fair, clear and not misleading and disclosing the absence of MiCAR protections for unregulated services, among others.
  • Amendment to exemption thresholds under UK POCA published
    10 July 2025

    The Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025 has been made and published with an accompanying explanatory memorandum. The legislation increases the financial threshold under sections 339A(2) and 339A(6A) of the Proceeds of Crime Act 2002 (POCA) from GBP1,000 to GBP3,000. These thresholds apply to two key exemptions for regulated businesses, such as banks, electronic money institutions and payment institutions, among others set out in schedule 9 of POCA, enabling them to (i) operate a customer account; or (ii) return funds when terminating a customer relationship, without committing a money laundering offence, even where criminal property is suspected (i.e., property believed to represent the proceeds of crime), provided the amount involved is below the threshold. The change aims to reduce the volume of low-value Defence Against Money Laundering (DAML) Suspicious Activity Reports (SAR), which in 2024 accounted for 23,000 submissions but only 0.1% of assets denied. A DAML SAR can be submitted for transactions above the threshold, which means a criminal offence will not be committed by the regulated entity, although the transaction is frozen pending the outcome of the review of the transaction or the lapse of three months. A review of the exit and pay away exemption introduced via the Economic Crime and Corporate Transparency Act 2023 is scheduled for 2026.
  • ESMA peer review report issuing CASP oversight recommendations under MiCAR
    10 July 2025

    The European Securities and Markets Authority (ESMA) has published a peer review report assessing the authorisation and supervision of a crypto-asset service providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCAR). While the peer review was conducted in Malta and sets out specific recommendations addressed to the Malta Financial Services Authority (MFSA), ESMA also makes broader recommendations which apply to all national competent authorities (NCAs).

    Read more.
    Topic : FinTech
  • Bank of England's FPC publishes July financial stability report
    9 July 2025

    The Bank of England's Financial Policy Committee (FPC) has published its July financial stability report alongside the record of its 27 June meeting. After assessing the risks to the UK financial system, the FPC reports that global financial markets remain vulnerable, with elevated risks stemming from geopolitical tensions, trade fragmentation and sovereign debt pressures.

    Read more.
  • ESMA publishes new guidelines under MiCAR to prevent and detect market abuse
    9 July 2025

    The European Securities and Markets Authority (ESMA) has published official translations of its guidelines on supervisory practices to prevent and detect market abuse under the Markets in Crypto-Assets Regulation (MiCAR). The guidelines, initially released in April through a final report, outline general principles to promote high-quality and effective supervision of market abuse in crypto-assets, alongside more targeted practices to support national competent authorities (NCAs) in detecting and preventing such abuse. The guidelines will now apply from 9 October, being three months after their publication in all official EU languages. NCA's shall confirm by 9 September whether they comply or intend to comply with the guidelines. If an NCA does not comply or does not plan to comply, it must notify ESMA, providing the reasons for its position. ESMA will subsequently publish this information on its website.
  • ECB and AMLA sign MoU to strengthen EU AML supervision
    3 July 2025

    The European Central Bank (ECB) has published a Memorandum of Understanding (MoU) (dated 27 June) that the ECB has entered into with the European Union's Anti-Money Laundering Authority (AMLA) to enhance cooperation between prudential and anti-money laundering supervision. The MoU establishes practical arrangements for cooperation and information exchange, aiming to enhance supervisory effectiveness, maximise efficiency and avoid duplication of efforts. Under the MoU, the AMLA will directly supervise certain high-risk financial institutions (referred to as "selected obliged entities") that are particularly exposed to cross-border money laundering. These include payment institutions, crypto-asset service providers and, in some cases, banks that also fall under the ECB's prudential supervision. Article 92(3) of the AMLA Regulation requires the AMLA and the ECB to conclude a MoU setting out the practical modalities for cooperation and for exchanging information in the performance of their respective tasks by 27 June.
  • EC adopts Delegated Regulation under MiCAR on liquidity management for ARTs and EMTs
    27 June 2025

    The European Commission has adopted a Delegated Regulation supplementing Regulation (EU) 2023/1114 (Markets in Crypto Assets Regulation) (MiCAR), regarding regulatory technical standards (RTS) specifying the minimum contents of the liquidity management policy and procedures for issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs). The RTS aim to ensure that issuers maintain robust liquidity frameworks capable of withstanding both normal and stressed market conditions.

    Read more.
    Topic : FinTech
  • FATF publishes targeted update and guidance on virtual assets and VASPs
    26 June 2025

    The Financial Action Task Force (FATF) has published its sixth targeted update on the implementation of its standards for virtual assets (VAs) and virtual asset service providers (VASPs), alongside an updated webpage. The report assesses global progress in applying anti-money laundering and counter-terrorist financing (AML/CFT) measures to VAs and VASPs, noting improvements in regulation and enforcement. However, challenges remain and the report sets out key recommendations on: (i) risk assessment and policy approach to VASPs; (ii) licensing/registering and supervising VASPs; (iii) implementation of the Travel Rule; (iv) addressing emerging and increasing risks related to stablecoins and decentralised finance arrangements; and (v) recommendations for the private sector.

    In parallel, FATF has also released Best Practices on Travel Rule Supervision, providing more detailed guidance to assist jurisdictions in effectively supervising compliance with the Travel Rule for VASPs. The guidance offers practical examples and supervisory approaches to address common implementation challenges.
  • ESMA report proposes amendments to DLT pilot regime for permanent adoption
    25 June 2025

    The European Securities and Markets Authority (ESMA) has published a report, accompanied by a press release, on the functioning and review of the Distributed Ledger Technology (DLT) pilot regime. The DLT pilot regime allows certain DLT market infrastructures to operate with exemptions from some EU financial services legislation. The regime has so far received limited uptake, with only three authorised infrastructures and minimal live trading activity. The report identifies operational and legal challenges, such as interoperability issues and restricted access to central bank money and refers to industry feedback, that the thresholds for financial instruments that may be admitted to trading or recorded on DLT market infrastructures may be too restrictive.

    Read more.
    Topic : FinTech
  • UK Government publishes 10-year industrial strategy plan
    23 June 2025

    The UK Government has published a policy paper outlining its industrial strategy. The strategy centres around eight priority sectors (the IS-8), including financial services. The UK government's ambition is to establish the UK as the world's most innovative full-service financial centre by 2035. A dedicated sector plan is expected to be published alongside the mansion house speech on 15 July.

    Key measures to achieve this objective include:
    • Ensuring financial services enables growth across the real economy, with retail banks and wholesale markets providing credit and liquidity.
    • Mobilising pensions capital into the UK.

    Read more.
  • EBA opinion on PSD2 and MiCAR
    10 June 2025

    The European Banking Authority (EBA) has issued an opinion (referred to as the No Action letter) in response to a request from the European Commission (EC) in December 2024, on the interplay between Payment Services Directive (PSD2/3) and Markets in Crypto-Assets Regulation (MiCAR) in relation to electronic money tokens (EMTs). It seeks to clarify how national competent authorities (NCAs) should approach the authorisation and supervision of crypto-asset service providers (CASPs) that engage in EMT-related activities during the transitional period before PSD3 and the Payment Services Regulation (PSR) come into effect. The EBA advises the EC, European Council and European Parliament to avoid long-term dual authorisation requirements and advises NCAs to require PSD2 authorisation only after a transition period ending on 2 March 2026, and only for a defined subset of CASPs—specifically those providing services such as the custody and administration of EMTs or facilitating EMT transfers on behalf of clients. NCAs are encouraged to adopt streamlined authorisation procedures that leverage information already submitted during the MiCAR process. Post-transition, NCAs must ensure entities who are not licensed as a payment service provider (PSP) or have not entered partnership with a PSP, are prevented from providing EMT related services that qualify as a payment service.

    Read more.
  • Further suite of technical standards supplementing MiCAR published in the OJ
    10 June 2025

    Three Commission Delegated Regulations supplementing Regulation (EU) 2023/1114 (the EU Markets in Crypto Assets Regulation) (MiCAR) have been published in the Official Journal of the European Union, namely:
    • Commission Delegated Regulation - 2025/1141 supplementing MiCAR with regards to regulatory technical standards specifying the requirements for policies and procedures on conflicts of interest for issuers of asset-referenced tokens.
    • Commission Delegated Regulation - 2025/1140 supplementing MiCAR with regards to regulatory technical standards specifying records to be kept of all crypto-asset services, activities, orders and transactions undertaken.

    Read more.
    Topic : FinTech
  • FCA Quarterly Consultation No 48
    6 June 2025

    The UK Financial Conduct Authority (FCA) has published quarterly consultation paper No 48, accompanied by a press release, inviting feedback on proposed amendments to its Handbook. Key proposals include:
    • Amending guidance in SUP 6.4 to reflect legislative changes introduced in section 415AA of the Financial Services and Markets Act 2000 (FSMA); the deadline for comments is 14 July.
    • Streamlining data reporting by decommissioning certain requirements, including changes to REP009 (consumer buy-to-let mortgage aggregated data) reporting frequency and removing nil return requirements for REP008 (notification of disciplinary actions relating to conduct rules staff other than SMF managers); the deadline for comments is 30 June.

    Read more.
  • FCA operation against unauthorised finfluencers
    6 June 2025

    The UK Financial Conduct Authority (FCA) has published a press release on its leading international crackdown on illegal financial influencers (finfluencers) in collaboration with regulators from Australia, Canada, Hong Kong, Italy and the UAE. This operation, which commenced on 2 June and was led by the FCA, resulted in three arrests, criminal proceedings against three individuals, the issuance of fifty warning alerts and seven cease and desist letters in the UK. The warning alerts will result in over 650 takedown requests for unauthorised financial promotions on social media platforms and websites. The FCA warns finfluencers that they must act responsibly and only promote financial products if authorised, otherwise they will face serious consequences for non-compliance.
    Topic : FinTech
  • Law Commission consults on reforming private international law for digital assets
    5 June 2025

    The UK Law Commission has published a consultation on reforms to private international law necessitated by emerging technologies such as decentralised ledger technology (DLT). The Law Commissions state that their project has a particular focus on crypto-tokens, electronic bills of lading and electronic bills of exchange because these assets are prevalent in market practice while also posing novel theoretical challenges to the methods by which issues of private international law have traditionally been resolved. The consultation focuses primarily on wholly decentralised applications of DLT. Among other things, the Law Commission proposes:
     
    1. To create a new free-standing information order to help claimants who have lost crypto-tokens through fraud or hacking, obtain information about the perpetrators or the whereabouts of their tokens without having to go through the existing gateways.
    Read more.
  • European Commission adopts RTS specifying the information in an application for authorisation to offer ARTs to the public or to seek their admission to trading
    5 June 2025

    The European Commission has adopted a Delegated Regulation supplementing Regulation 2023/1114 (MiCAR) with regard to regulatory technical standards (RTS) specifying the information in an application for authorisation to offer asset-referenced tokens (ARTs) to the public or to seek their admission to trading. The RTS detail the list of information specified in Article 18(2) of MiCAR, to be provided in an application by legal persons or other undertakings (other than credit institutions) seeking to obtain authorisation. In particular they prescribe information requirements on: (i) the identification of the applicant issuer; (ii) the programme of operations, including the main features of the intended issuance; (iii) the internal governance arrangements and structural organisation, including information on third-party providers of critical and important functions, and internal control framework; (iv) the liquidity management, reserve of assets and redemptions rights, including a description of the stabilisation mechanism for the asset-referenced token for which the authorisation is sought; (v) suitability of the members of the management body; and (vi) the sufficiently good repute of members of the management body, shareholders or members with direct or indirect qualifying holdings. The delegated regulation is now subject to scrutiny by the Council and the European Parliament.  If neither objects within three months, it will be published in the Official Journal of the European Union, entering into force twenty days after.
    Topic : FinTech
  • FCA consults on stablecoin issuance and custody of cryptoassets
    28 May 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/14 (CP) on stablecoin issuance and cryptoasset custody, accompanied by an updated webpage. This follows the FCA's discussion paper published in November 2023, which outlines the proposed approach to regulating stablecoins. This new CP is part of the FCA's roadmap for crypto regulation and is intended to be read alongside CP25/15, which sets out the proposed prudential regime for cryptoasset firms (and which we discuss here). In CP25/14, the FCA has proposed rules and guidance for the issuance of qualifying stablecoins and the safeguarding of qualifying cryptoassets, including stablecoins. These activities are expected to become regulated activities under the HM Treasury's draft legislation, the Financial Services and Markets Act 2000 (Regulated Activities and Miscellaneous Provisions) (Cryptoassets) Order 2025 subject to its finalisation.

    Read more.
  • FCA consults on proposed prudential regime for cryptoasset firms
    28 May 2025

    The UK Financial Conduct Authority (FCA) has published consultation paper CP25/15 on its proposed prudential regime for cryptoasset firms, also accompanied by an updated webpage. This is intended to be read together with CP25/14 on stablecoin issuance and cryptoasset custody, which we discuss here. In this consultation paper, the FCA has proposed prudential rules and guidance for cryptoasset firms, including those issuing qualifying stablecoins and safeguarding qualifying cryptoassets, including stablecoins. The proposals introduce a new prudential regime to be integrated through two new sourcebooks: (i) COREPRU which will initially apply to firms carrying on regulated cryptoasset activities; and (ii) CRYPTOPRU, which will contain other sector-specific requirements for firms doing regulated cryptoasset activities, with these firms referred to as CRYPTOPRU firms.

    Read more.
View All (500+)