Global Regulatory Updates for Financial Services

What Changed

The guidance does not introduce new binding rules but clarifies AI as ICT systems requiring DORA-compliant treatment, including: AI strategy: Management-approved, aligned with overall strategy, defining responsibilities, competencies, and interdisciplinary collaboration for critical functions. ICT risk management integration: Cover identification, protection, detection, response, recovery, training; apply to AI lifecycle (data acquisition, development, operation, retirement). Development and tes

What You Need To Do

• Develop and approve AI strategy integrated with ICT roadmap and governance
• Embed AI in existing ICT risk framework, ensuring lifecycle coverage with safeguards (e
• Conduct third-party due diligence and contractual reviews for AI/cloud providers, including exit/portability testing
• Implement AI-specific testing, documentation, and incident processes proportionate to criticality
• Ensure management accountability for oversight, training, and interdisciplinary controls

Key Dates

References

• [1] regulationtomorrow.com
• [2] jonesday.com
• [3] banking.vision
• [4] natlawreview.com
• [5] bakertilly.de
• [6] babl.ai

What Changed

The primary regulatory change is a downward adjustment of the Russian crude oil price cap: Previous cap: USD 47.6 per barrel New cap: USD 44.1 per barrel Effective date: February 1, 2026 This modification targets Russia's shadow fleet and circumvention mechanisms. As context, Switzerland previously expanded its sanctions framework on December 12, 2025, subjecting 116 vessels—primarily tankers in Russia's shadow fleet—to purchase, sale, and service prohibitions specifically to prevent evasion o

What You Need To Do

• *Implement price cap enforcement
• *Asset freezing
• *Reporting obligations
• *Enhanced due diligence
• *Suspicious activity reporting

Key Dates

References

• [1] finma.ch
• [2] hub.hslu.ch
• [3] ad-hoc-news.de
• [4] finma.ch
• [5] de.euronews.com
• [6] finma.ch
• [7] finma.ch
• [8] finma.ch

What Changed

This is not a regulatory change or new requirement but an enforcement precedent highlighting existing obligations under the AML/CFT Law: Mandatory annual submission of the CSSF financial crime questionnaire by supervised entities, including registered AIFMs, as part of the cooperation duty in Article 5(1). Fines determined per Article 8-4(1), (2)(f), and (3)(a), considering circumstances under Article 8-5(1), with publication assessed for proportionality under Article 8-6(1). No new rules introd

What You Need To Do

• Immediate verification
• Procedural enhancements
• Training and testing
• Engagement protocol
• Policy updates

Key Dates

References

• [1] cssf.lu
• [2] cms.law
• [3] regulatoryandcompliance.com
• [4] practiceguides.chambers.com
• [5] cliffordchance.com
• [6] cssf.lu
• [7] mondaq.com
• [8] assets.kpmg.com

What Changed

This is not a mandatory regulatory change but a voluntary testing service launched by the FCA; no new enforceable requirements are imposed. Key elements include a holistic focus on the AI system (model + deployment context, risks, governance, human-in-the-loop, evaluation, input/output controls) rather than isolated foundation models. The program features three phases: Discovery, Framework validation, and AI system testing (quantitative/qualitative), emphasizing live monitoring, governance, and

What You Need To Do

• Review FCA's Terms of Reference (PDF) for eligibility, focusing on mature POCs and enterprise-level AI systems
• Submit application form via FCA portal by 2 March 2026 if ready for live testing; contact suptech@ fca
• Prepare documentation on AI system components (model, context/risks, governance, human oversight, evaluation, controls) for three-phase process
• Assess internal governance, data, risk frameworks, and monitoring for AI readiness; consider non-participation but monitor for future FCA expectations
• Firms not selected should use insights from first cohort (e

Key Dates

References

• [1] fintechnews.ch
• [2] plenitudeconsulting.com
• [3] jdsupra.com
• [4] fca.org.uk
• [5] fca.org.uk
• [6] corporate-adviser.com
• [7] finextra.com
• [8] lewissilkin.com

What Changed

The primary regulatory modification addresses a single-day exception to standard options exercise procedures: CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025. Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date. OCC Processing Unchanged: The Options Clearing Corporation's proc

What You Need To Do

• *Update Internal Procedures
• *System Configuration
• *Staff Communication
• *Customer Notification
• *Submission Coordination

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

The Section 31 fee rate drops from $27.80 per million dollars to $0.00 per million dollars for covered securities transactions on exchanges and over-the-counter markets, applicable to trade dates (charge dates) of May 14, 2025, or later.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] The assessment on security futures transactions remains unchanged at $0.0042 per round turn transaction.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] FINRA wil

What You Need To Do

• Update internal billing, invoicing, and financial reporting systems to reflect the $0
• Review and adjust any automated fee calculations or client pass-through mechanisms for transactions on or after the effective date
• Contact FINRA's Amanda Rath for finance questions ((240) 386-6637) or SEC's Robert McNamee/Faisal Sheikh for legal/interpretive issues; monitor SEC website for updates
• Test systems for security futures (unchanged rate) and confirm no inadvertent charging of Section 31 fees post-effective date

Key Dates

References

• [1] ez-xbrl.com
• [2] cooleypubco.com
• [3] sec.gov
• [4] finra.org
• [5] nelsonmullins.com
• [6] infomemo.theocc.com
• [7] sec.gov
• [8] federalregister.gov

What Changed

Termination of Fee 2025-1: No longer applied to transactions after June 30, 2025, per FINRA Rule 6897(b)(1)(D), which requires notice upon replacement by a subsequent fee. Implementation of Fee 2025-2: New fee recovers FINRA's ~$7.27 million share of budgeted CAT costs for July 1–December 31, 2025; monthly invoicing begins for July 2025 transactions. Distinction from CAT LLC fees: Unrelated to "CAT Fee 2025-1" (assessed by CAT LLC, rate $0.000022 per transaction, remains in effect). #

What You Need To Do

• Verify internal systems stop applying Fee 2025-1 post-June 30, 2025, and prepare for Fee 2025-2 invoicing starting July transactions
• Review and pay final Fee 2025-1 invoice (due August 2025) per Rule 6897(b)(2)
• Update budgeting/forecasting models for Fee 2025-2 (covers H2 2025 CAT costs); monitor FINRA notices for rate details via SR-FINRA-2025-010
• Contact Amanda Rath ((240) 386-6637) or Faisal Sheikh ((202) 728-8379) for questions
• Distinguish FINRA fees from CAT LLC fees to avoid double-counting in financial controls

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] federalregister.gov
• [4] sec.gov
• [5] finra.org
• [6] findknowdo.com
• [7] catnmsplan.com
• [8] compliance-risk.com

What Changed

Effective January 1, 2023, amendments to FINRA Rule 1240 mandate annual completion of both Regulatory Element and Firm Element for all registered persons, per CE Council recommendations.[https://www.finra.org/rules-guidance/notices/information-notice-20250814] Launched July 1, 2024, the Financial Learning Experience (FLEX) serves as an optional centralized catalog for Firm Element e-learning courses to support written training plans.[https://www.finra.org/rules-guidance/notices/information-notic

What You Need To Do

• Registered persons
• Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions

Key Dates

References

• [1] stcusa.com
• [2] nasaa.org
• [3] finra.org
• [4] questce.com
• [5] finra.org
• [6] finra.org

What Changed

Removal of Settle Prep Day: NSCC Rule 50 amended to eliminate the settlement preparation stage from ACATS, effective October 17, 2025, streamlining the process for all securities transfers.[original notice] Mutual Fund/Options Synchronization: Eliminates the extra day for processing mutual funds and options via Fund/SERV, aligning their settlement with other assets; also removes the second day of Fund/SERV pending acknowledgment.[original notice] Overall Timeline Reduction: Full ACATS transfers

What You Need To Do

• Operational Readiness
• Exception Handling
• System Updates
• Contact FINRA/NSCC

Key Dates

References

• [1] ftfnews.com
• [2] finra.org
• [3] advisorfinder.com
• [4] finra.org
• [5] sec.gov
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

No new regulatory requirements or rule amendments; this is guidance providing a pre-calculated Filing Schedule for 2026 to prevent errors in the REX system. It emphasizes using schedule dates around holidays when exchanges or banks close, and confirms fixed SEA Rule 15c3-3 deadlines (e.g., 30th/45th calendar days post-settlement, 10th business day for (m) possession/control, regardless of foreign settlement cycles). #

What You Need To Do

• Access and reference the 2026 Filing Schedule on FINRA's website (via https://www
• Input schedule-specific dates for extensions, particularly around 2026 holidays when exchanges/banks close, to avoid automatic denials
• File SEA Rule 15c3-3 extensions on exact due dates listed above, even for foreign-traded securities
• Contact Theresa Reynolds (646-315-8567 or email) for questions
• Update internal compliance calendars, training, and systems to integrate the schedule

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] federalregister.gov

What Changed

Electronic Filing Mandates: All specified filings must be submitted electronically via FINRA Gateway; SEC no longer accepts paper Annual Reports, requiring EDGAR PDF submissions under amended SEA Rule 17a-5(d)(6)(i). https://www.finra.org/rules-guidance/notices/information-notice-20251110 SEC Interactive Data Compliance Dates: Annual reports and supplements must be filed as Interactive Data Files per Rule 405 of Regulation S-T; firms with net capital ≥$250,000 (as of Dec 31, 2025) comply for fi

What You Need To Do

• Submit all filings electronically via FINRA Gateway by 11:59 p
• For 30-day extension
• Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable
• Prepare for Interactive Data
• Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] ria-compliance-consultants.com
• [7] fairviewinvest.com
• [8] thinkadvisor.com

What Changed

Electronic Filing Mandate: SEC no longer accepts paper submissions of annual reports (Form X-17A-5 Part III), supplemental reports under SEA Rule 17a-5(k), and Form 17-H; all must be filed on EDGAR in PDF format.[https://www.finra.org/rules-guidance/notices/information-notice-20251114] Electronic Signatures Permitted: Allowed for all SEA Rule 17a-5 reports (including annual and FOCUS Reports) via specified processes, e.g., Adobe Acrobat digitally signed certificates with document locking; FOCUS

What You Need To Do

• Implement electronic signature processes (e
• Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization)
• Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance)
• Direct questions to firm's Risk Monitoring Analyst

Key Dates

References

• [1] quadrantregulatory.com
• [2] finra.org
• [3] pkfod.com
• [4] finra.org
• [5] quadrantregulatory.com
• [6] finra.org
• [7] capmktsreg.org

What Changed

National options exchanges will close at 1:00 p.m. ET on November 28, 2025, triggering a modified exercise cut-off under FINRA Rule 2360(b)(23)(A)(viii): deadline is 1 hour 30 minutes after close (i.e., 2:30 p.m. ET), overriding the standard 5:30 p.m. ET. Firms may set earlier internal deadlines for accepting exercise instructions but cannot accept any after 2:30 p.m. ET per FINRA Rule 2360(b)(23)(A)(vi). Reiterates standard procedures: in-the-money options auto-exercise under OCC Rule 805 (Exer

What You Need To Do

• Update client communications
• Configure systems and procedures
• Train staff
• Monitor and record
• Contact FINRA contacts (James Turnbull or Matthew Vitek) for clarification

Key Dates

References

• [1] finra.org
• [2] davispolk.com
• [3] finra.org
• [4] gtlaw.com
• [5] mayerbrown.com
• [6] finra.org
• [7] sec.gov
• [8] carltonfields.com

What Changed

Amendments to five technical notes: FCA/TN/506.2 (Periodic financial information and inside information), Primary Market/TN/507.1 (Structured digital reporting for IFRS annual statements, reflecting new ESEF taxonomy per DTR 4.1.15R), UKLA/TN/520.2 (Delaying disclosure/dealing with leaks and rumours), UKLA/TN/521.3 (Assessing and handling inside information), and UKLA/TN/542.2 (Issuer's obligations on position disclosures). Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2

What You Need To Do

• Review blacklined amendments in GC25/1 and PMB 55; submit feedback by 15 May 2025 if impacted
• Update internal policies, training, and procedures to reflect finalised notes (e
• Until finalised, interpret existing guidance in light of UKLR; monitor for TN/710 update in future PMB
• For digital reporting, prepare for new ESEF taxonomy in annual IFRS statements

Key Dates

References

• [1] regulationtomorrow.com
• [2] jdsupra.com
• [3] fca.org.uk
• [4] hsfkramer.com
• [5] fca.org.uk
• [6] equiniti.com
• [7] lexisnexis.co.uk
• [8] linklaters.com

What Changed

This is not new rulemaking but illustrative guidance applying existing Consumer Duty rules from FG 22/5 and PRIN 2A.5.3R, which mandate communications that are clear, fair, not misleading, meet retail customers' information needs, are understandable, and support effective decisions. Key emphases include pre-transaction disclosure of: amount remitted (GBP), applied exchange rate (explaining markups as consumer costs), recipient amount (local currency), variable/fixed fees, total fees, and interme

What You Need To Do

• Review and update pre-transaction communications (e
• Ensure markups are framed as consumer costs, not obscured (e
• Monitor communication effectiveness regularly under Consumer Duty to confirm good outcomes, enabling cost comparisons and informed choices
• Apply principles to all channels; proactively disclose fee variability and third-party impacts

Key Dates

References

• [1] hoganlovells.com
• [2] regulationtomorrow.com
• [3] fca.org.uk
• [4] financialregulation.linklaters.com
• [5] jdsupra.com
• [6] lexisnexis.co.uk
• [7] regulatoryandcompliance.com

What Changed

Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and Payment Services Return (PSR)) with one unified return to reduce duplication and improve comparability. Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities. Simplified nil returns: Proportionate approach allows upfront sel

What You Need To Do

• Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points
• Eliminate group-level aggregation; implement entity-level reporting
• Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting
• Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable
• For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture

Key Dates

References

• [1] regulationtomorrow.com
• [2] abc.ukgigroup.com
• [3] fca.org.uk
• [4] finreg.aoshearman.com
• [5] complyport.com
• [6] addleshawgoddard.com

What Changed

Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own funds adequacy, capital resources, and stress-adjusted internal capital assessments. Own Funds and Capital Rules: Firms must hold financial resources adequate in amount and quality, including adjustments for valuation uncertainty, stress realizable values, and interim profits in CET1 capital; supplement

What You Need To Do

• Respond to Consultation
• Assess Applicability
• Prepare Prudential Frameworks
• Engage on Related CPs
• Data and Reporting Readiness

Key Dates

References

• [1] fca.org.uk
• [2] fca.org.uk
• [3] traverssmith.com
• [4] taylorwessing.com
• [5] hoganlovells.com
• [6] lw.com
• [7] ukfinance.org.uk
• [8] actuaries.org.uk

What Changed

Amendments to TN 710.1 (Sponsor Services: Principles for Sponsors): Revisions clarify the scope of 'preparatory work' and sponsor obligations under UKLR 4, building on feedback from PMB 48, 53, and PS24/6; changes marked against PMB 53 version. New TN 638.1 (Guidance on complex financial history and significant financial commitment rules): Updated draft provides detailed guidance for prospectus applications by companies with complex histories (e.g., acquisitive models), including scenarios, exam

What You Need To Do

• Review and respond
• Update policies/processes
• Monitor finalisation
• Implement NSM changes

Key Dates

References

• [1] jdsupra.com
• [2] fca.org.uk
• [3] fca.org.uk
• [4] fca.org.uk
• [5] ukfinance.org.uk
• [6] hoganlovells.com
• [7] lexisnexis.co.uk
• [8] hsfkramer.com

What Changed

Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding £210 million is more likely deemed "significant," while below £45 million is unlikely to meet the threshold unless qualitative factors (e.g., consumer vulnerability, widespread impact) apply. These replace 2013 levels and will be reviewed periodically. No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in

What You Need To Do

• Monitor for triggering events
• Enhance internal reviews
• No direct firm obligations
• Document qualitative factors (e

Key Dates

References

• [1] fca.org.uk
• [2] fca.org.uk
• [3] jdsupra.com
• [4] finreg.aoshearman.com
• [5] slaughterandmay.com
• [6] taylorwessing.com
• [7] lexisnexis.co.uk

What Changed

CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing structures to ensure accessibility and affordability. Data Contributor Obligations: Trading venues and Approved Publication Arrangements (APAs) must provide trade data (e.g., prices, volumes) to the CTP, covering trades across venues and OTC equity transactions. Scope and Outcomes: CT focuses on post-

What You Need To Do

• Respond to Consultation
• Data Readiness
• Monitor Updates
• Engage Stakeholders
• Compliance Mapping

Key Dates

References

• [1] fca.org.uk
• [2] jdsupra.com
• [3] ashurst.com
• [4] regulationtomorrow.com
• [5] fca.org.uk
• [6] content.govdelivery.com
• [7] a-teaminsight.com
• [8] afme.eu

What Changed

The framework introduces several material regulatory changes: *New Specified Activity Status** Targeted support will be designated as a new specified activity under the Regulated Activities Order, meaning only FCA-authorised firms can provide this service. This creates a regulatory boundary distinct from both unregulated guidance and regulated investment advice. *Purpose Statement Refinement** The FCA amended its original purpose statement from "better outcomes" to "better position" to clarify

What You Need To Do

• *Immediate (January–February 2026)
• *Pre-Implementation (March 2026)
• Consumer segment definitions with supporting rationale
• Ready-made suggestion frameworks
• Communication templates explaining the nature of targeted support

Key Dates

References

• [1] fca.org.uk
• [2] riskandcompliance.freshfields.com
• [3] hoganlovells.com
• [4] deloitte.com
• [5] jdsupra.com
• [6] farrer.co.uk

What Changed

COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty, violence) to assess breaches consistently; clarifies only "serious" NFM qualifies, aligned with Equality Act concepts, and excludes trivial/private matters. FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating

What You Need To Do

• Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness
• Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy
• Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA
• Assess current NFM handling for gaps (e
• Firms not to investigate trivial/improbable allegations or overstep privacy laws

Key Dates

References

• [1] fca.org.uk
• [2] traverssmith.com
• [3] regulationtomorrow.com
• [4] osborneclarke.com
• [5] sidley.com
• [6] employmentlawworldview.com
• [7] simmons-simmons.com
• [8] globalfinregblog.com