December 2025 Regulatory Updates

What Changed

There are no main regulatory changes, new requirements, or policy updates in this announcement; it is solely a personnel departure notice with no substantive regulatory implications.

Suggested Considerations

• related delays and monitor for successor announcements via https://www.sec.gov/newsroom/press-releases.

Key Dates

References

• [1] sifma.org/people/nekia-hackworth-jones-esq
• [2] sec.gov/newsroom/press-releases/2025-146-deputy-director-...
• [3] securitiesdocket.com/2025/12/30/deputy-director-of-enforc...
• [4] sec.gov/newsroom/press-releases/2020-304
• [5] ali.org/profile/3204
• [6] jonesday.com/en/news/2026/01/former-sec-deputy-director-n...

What Changed

The circular explicitly states that no substantive changes have been made to the survey process compared to previous quarters. The only modifications are administrative: the reference date (December 31, 2025) and the submission deadline (January 30, 2026). The specifications for data collection, definitions of covered and eligible deposits, and reporting methodologies remain unchanged from prior circulars, particularly Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35.

Suggested Considerations

• *Calculate covered deposits as defined in Article 163 of the 2015 law, including balance and accrued interest (even if not yet due)
• *Report eligible deposits after applying exclusions under Article 172 of the 2015 law, including exclusions for financial institutions and life insurance products
• *Distinguish deposit types by reporting:
• Total eligible deposits (field 201)
• Eligible deposits in omnibus accounts, fiduciary accounts, trusts, sub-accounts, and segregated accounts (field 0226)

Key Dates

References

• [1] cssf.lu/wp-content/uploads/CSSF_CPDI_2549eng.pdf
• [2] cssf.lu/en/Document/circular-cssf-cpdi-25-49/
• [3] cssf.lu/wp-content/uploads/newsletter300.pdf
• [4] fgdl.lu/en/473/
• [5] cssf.lu/en/protection-of-depositors-and-investors/
• [6] cssf.lu/en/regulatory-framework/page/2/
• [7] cssf.lu/en/regulatory-framework/
• [8] cssf.lu/en/keyword/terrorism/page/5/

What Changed

• - VA Dealer Regime: Introduces licensing for VA dealing activities (e.g., VA conversions, broker-dealer services at physical outlets or otherwise), excluding tokenized securities/derivatives...
• VA Custodian Regime: Targets entities safeguarding private keys or enabling unilateral VA transfers (e.g., capturing staking providers but exempting non-custodial wallets or delegating top-layer...
• Exemptions Under Consideration: Aligns partially with Type 1 exemptions, including principal/intra-group transactions, VA use as payment for goods/services, chaperone via SFC-regulated dealers, VA...
• Further Consultations: New regimes for VA advisory (aligned with Type 4) and asset management (aligned with Type 9), without deeming provisions for pre-existing entities; VA managers may face custody...

Suggested Considerations

• Pre-Application Engagement: Contact SFC immediately for discussions on VA custodian licensing, especially for existing VATPs/banks holding keys.
• License Applications: Prepare applications for VA dealer/custodian licenses once regimes commence; appoint responsible officers/managers-in-charge meeting fit-and-proper criteria, implement cold wallet infrastructure, private key controls, insurance, audits, and business continuity plans.
• Custody Segregation: Existing intermediaries/VA dealers must transition client VA custody to SFC-licensed VA custodians; cease use of non-compliant overseas providers.
• Compliance Mapping: Review operations against Type 1/Type 13 financial resources, core function authorizations, and exemptions; assess staking/MPC services for custody capture.
• Monitor Further Consults: Track incoming VA advisory/management regimes and adjust for no deeming provisions.

References

• [1] tannerdewitt.com/aspire-looking-back-and-ahead-on-the-reg...
• [2] slaughterandmay.com/insights/new-insights/hong-kong-proce...
• [3] gibsondunn.com/hong-kong-concludes-consultations-on-regul...
• [4] reedsmith.com/articles/fstb-and-sfc-consult-on-proposed-l...
• [5] sidley.com/en/insights/newsupdates/2026/01/hong-kong-to-f...
• [6] fstb.gov.hk/fsb/en/publication/consult/doc/VAdealing_cons...
• [7] kwm.com/hk/en/insights/latest-thinking/hong-kong-virtual-...
• [8] info.gov.hk/gia/general/202512/24/P2025122400265.htm

What Changed

• - ESMA welcomes the European Commission's 4 December 2025 legislative package on market integration, emphasizing robust governance and market infrastructure for deeper EU capital markets.
• Announcement of selected applicant for the equity consolidated tape provider (CTP), advancing MiFIR transparency for equity markets by improving post-trade data consolidation and access.
• Publication of ESMA's final report on Regulatory Technical Standards (RTS) for non-equity transparency, clarifying pre- and post-trade transparency rules for bonds, derivatives, and other non-equity...
• Launch of a Common Supervisory Action (CSA) on MiFID II conflicts of interest requirements to promote supervisory convergence and governance across Member States.
• European Supervisory Authorities (ESAs) designate critical ICT third-party providers under DORA, enhancing oversight of key outsourcing risks.

Suggested Considerations

• Review the final non-equity transparency RTS and assess impacts on trading and reporting systems for compliance by any upcoming application dates (not specified).
• Evaluate MiFID II conflicts of interest policies in preparation for the CSA; conduct internal audits and enhance training/staff attestations on identification and mitigation.
• Monitor equity CTP rollout for changes to post-trade data access and costs; update vendor contracts if applicable.
• For DORA-impacted firms, map exposures to designated critical ICT providers and strengthen due diligence, contractual clauses, and exit strategies.
• Asset managers: Audit fund names against guidelines and review UCITS distribution practices for cost transparency.

Key Dates

References

• [1] esma.europa.eu/press-news/esma-news/esma-publishes-latest...
• [2] jdsupra.com/post/fileServer.aspx?fName=81a62b9b-3256-4cec...
• [3] cyprus-mail.com/2025/12/31/esma-highlights-drive-for-deep...
• [4] esma.europa.eu/news-publications/newsletter
• [5] esma.europa.eu/sites/default/files/2025-12/Newsletter_Nov...
• [6] regulationtomorrow.com/france/eu-policy-regulatory-legisl...
• [7] esma.europa.eu/lt
• [8] esma.europa.eu/de/press-news/esma-news

What Changed

• - Updates to Descriptive Report and Self-Assessment Questionnaire: Refines content, format, and submission requirements for support PFS's annual submissions, emphasizing more detailed disclosures on...
• Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for...
• Management Letter and Separate Report: Establishes detailed rules for auditors to issue an annual management letter (addressing findings, recommendations, and remediation) and a separate report for...
• Enhanced Documentation and Evidence: Requires support PFS and auditors to provide verifiable evidence (e.g., checklists, testing samples) supporting self-assessments, with stricter CSSF validation...

Suggested Considerations

• *Review and Update Processes: Support PFS must map current reporting against new templates in CSSF 25/903 and revise internal procedures for descriptive reports and self-assessments.
• *Engage/Confirm Auditors: Select or confirm approved statutory auditors compliant with new engagement rules; execute updated engagement letters incorporating circular requirements by Q4 2025.
• *Implement Templates and Testing: Adopt CSSF-provided templates for reports, management letters, and separate reports; conduct sample-based testing of controls as specified.
• *Training and Governance: Train compliance/audit teams on changes; ensure board approval of self-assessments and auditor findings.
• *Submit on Time: Prepare and file all documents by 30 April deadlines, retaining evidence for CSSF inspections.

Key Dates

What Changed

• - Repeal of prior circulars: Circular CSSF 19/731 and its amendment via Circular CSSF 19/710 are fully repealed, eliminating the fixed list of annual submission documents.
• Shift to website-based guidance: The updated list of required documents, affected entity categories, electronic submission channels, and deadlines is now published on the CSSF’s Prudential reporting...
• Ongoing obligations: The requirement to submit documents annually remains unchanged; only the reference source and potential content updates via the website are modified.

Suggested Considerations

• Review the CSSF Prudential reporting webpage (https://www.cssf.lu/en/prudential-reporting-credit-institutions/) and summary table (https://www.cssf.lu/en/Document/summary-of-documents-to-be-submitted-on-an-annual-basis/) to identify current document lists, categories, channels, and deadlines.
• Update internal reporting processes, templates, and workflows to reference the website instead of the repealed circular.
• Confirm ongoing annual submissions via specified electronic channels; test interactive table for applicability to the institution's profile.
• Archive references to Circular CSSF 19/731 in policies and train staff on the change.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/cssf25_902eng.pdf
• [2] bakermckenzie.com/en/insight/publications/2026/01/luxembo...
• [3] cssf.lu/wp-content/uploads/newsletter300.pdf
• [4] cssf.lu/en/Document/circular-cssf-25-902/
• [5] cssf.lu/en/prudential-reporting-credit-institutions/
• [6] cssf.lu/en/regulatory-framework/
• [7] cssf.lu/en/Document/summary-of-documents-to-be-submitted-...

What Changed

• - Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management,...
• Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separate report confirming...
• Amendments via CSSF 25/903: Updates clarify submission procedures, expand self-assessment criteria (e.g., adding cybersecurity and outsourcing risk questions), and refine auditor independence...
• Frequency and Scope: Annual submissions required without exceptions; scope limited to support PFS (not primary PFS), emphasizing substance over form in service descriptions.

Suggested Considerations

• Annual Reporting Cycle: 1. By year-end, conduct internal self-assessment using the prescribed questionnaire template (available via CSSF portal).
• February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report.
• Governance Updates: Review and update internal policies on risk assessment, auditor selection, and remediation of management letter findings; ensure board oversight of submissions.
• Auditor Coordination: Verify auditor qualifications per CSSF register; implement any remediation plans from prior-year management letters before next cycle.
• Record-Keeping: Maintain 5-year audit trail of all supporting documentation for CSSF inspections.

Key Dates

What Changed

• This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
• Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
• Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and the 10% single-issuer bond exposure cap. No new...

Suggested Considerations

• Conduct gap analysis: Review depositary control frameworks against AMF expectations for verifying AMC investment monitoring, unlisted asset valuations, and prospectus compliance (e.g., 10% issuer limits, ratings).
• Enhance oversight processes: Implement robust, documented checks on AMC systems, including independent testing of ratios, legality of investments, and derivatives.
• Training and audits: Train staff on UCITS depositary duties; perform internal audits of ongoing fund oversight, prioritizing illiquid/unlisted exposures.
• Monitor appeals: Track any CACEIS appeal, as outcomes could set precedents; update policies if upheld.
• Reporting: Ensure timely escalation of suspected AMC breaches to AMF if identified.

Key Dates

References

• [1] amf-france.org/en/news-publications/news-releases/enforce...
• [2] finascope.fr/english/reglementation/la-commission-des-san...
• [3] amf-france.org/sites/institutionnel/files/pdf/77659/en/Th...
• [4] amf-france.org/en/news-publications/news-releases/enforce...
• [5] amf-france.org/en/news-publications/news-releases/amf-new...
• [6] amf-france.org/en/news-publications/news-releases/enforce...
• [7] opalesque.com/712831/AMF_Enforcement_Committee_fines_depo...
• [8] amf-france.org/sites/institutionnel/files/pdf/77587/en/AM...

What Changed

• This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include:
• Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA).
• Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal.
• No new requirements are introduced, but the FCA emphasises its ongoing monitoring and willingness to intervene, including via the Financial Promotions Regime (effective from 7 October 2023 for all...

Suggested Considerations

• Immediate verification: Check client-facing promotions, websites, and advisor scripts for any reference to holiday lodge/park schemes; ensure no endorsement of unauthorised products.
• Client communication review: Audit advice processes to flag and reject high-risk, unregulated collective schemes; document refusals.
• Training and monitoring: Update firm-wide training on CIS definitions (per COLL sourcebook) and unauthorised promotion risks; enhance surveillance of emails, social media, and third-party referrals.
• Internal reporting: Escalate any suspected unauthorised promotions to the FCA via Connect or the unauthorised firms reporting form (https://www.fca.org.uk/consumers/report-scam-unauthorised-firm).
• Due diligence: For authorised firms, implement pre-approval checks under the financial promotions regime (PERG 8 guidance) to confirm partner schemes are not CIS.

What Changed

• The enforcement action clarifies BaFin's expectations regarding fair and clear marketing communications for investment services:
• Investment services providers must explicitly and unambiguously disclose all material costs, including processing fees, when advertising services as "free"
• Marketing materials must present both benefits and risks of services in a balanced manner, with relevant risks highlighted alongside advantages
• These obligations apply across all marketing channels, including company websites
• The requirements are grounded in the WpHG and further specified in EU regulations and MiFID II guidance The violation centered on flatexDEGIRO's failure to clearly indicate that regular processing...

Suggested Considerations

• *For flatexDEGIRO Bank AG (already completed):
• Modify marketing materials to clearly and explicitly disclose all material costs and fees
• Ensure balanced presentation of benefits and risks across all marketing channels
• *For all investment services providers (preventive compliance):
• *Audit marketing materials across all channels (websites, social media, advertisements, promotional materials) to identify any claims of "free" or "no-cost" services that lack explicit fee disclosures

Key Dates

References

• [1] fxnewsgroup.com/forex-news/regulatory/german-regulator-im...
• [2] financemagnates.com/forex/bafin-fines-flatexdegiro-560k-o...
• [3] financemagnates.com/forex/bafin-fines-flatexdegiro-105m-w...
• [4] tradingview.com/news/reuters.com,2025:newsml_FWN3XR024:0-...
• [5] fxnewsgroup.com/forex-news/regulatory/bafin-imposes-e45m-...

What Changed

• The December 19, 2025 Q&A publication covers several regulatory domains:
• AIFMD Exclusion Criteria: New guidance on the UNGC/OECD Guidelines exclusion (Q&A 2734), clarifying when alternative investment fund managers must apply exclusion-related requirements
• ESG Rating Activities: Updated Q&As addressing regulatory requirements for ESG rating providers, including clarification on group-affiliated small ESG rating activities
• Sustainable Finance: Continued development of guidance under SFDR and related sustainability disclosure frameworks
• Digital Finance and Innovation: Guidance supporting implementation of digital finance rules

Suggested Considerations

• *Immediate (0-30 days):
• *Short-term (1-3 months):
• level information
• advertised securities per Annex 21 requirements

Key Dates

References

• [1] mazantipulse.com/updates/impactandesg/updated-qa-from-esm...
• [2] mayerbrown.com/en/insights/publications/2025/06/esma-publ...
• [3] regulationtomorrow.com/france/esma-publishes-new-micar-qa...
• [4] esma.europa.eu/press-news/esma-news/esma-updates-its-qas-...
• [5] esma.europa.eu/press-news/esma-news/new-qas-available-24
• [6] esma.europa.eu/press-news/esma-news/new-qa-available
• [7] esma.europa.eu/publications-and-data/questions-answers
• [8] esma.europa.eu/press-news/esma-news/new-qas-available

What Changed

• - Risk Transfer Validation: Firms must demonstrate that SPV risk transfers provide genuine economic risk transfer (ERT), not just accounting or regulatory capital relief, with PRA emphasizing...
• Capital Relief Criteria: Introduces stricter tests for recognizing capital relief, including full collateralization requirements, independent third-party guarantees, and prohibitions on circular...
• Governance and Documentation: Mandates robust board-level oversight, detailed transaction documentation (including stress testing and scenario analysis), and pre-transaction PRA notification for...
• SPV Oversight: SPVs must be structured to operate independently, with PRA reserving rights to challenge approvals if governance is inadequate or conflicts of interest arise.
• Alignment with Solvency II: Builds on existing rules (e.g., Article 211-213) but provides PRA-specific interpretations, including updated expectations on limited risk appetite and post-transfer...

Suggested Considerations

• Immediate Review (by Q1 2026): Conduct gap analysis of all existing SPV portfolios against SS2/25 criteria, documenting ERT evidence and collateral adequacy.
• Governance Updates: Enhance board policies for SPV approvals, including mandatory stress testing (e.g., 1-in-200 year events) and independent validation by external actuaries.
• Pre-Transaction Processes: Implement PRA notification templates for transfers >10% SCR; prepare deal packs with legal opinions on SPV independence.
• Reporting Enhancements: Update internal systems for RFR disclosures on SPV exposures; train Senior Insurance Managers (SIMs) on accountability under SIMR.
• Remediation: For non-compliant legacy SPVs, unwind or restructure by June 2027, notifying PRA of plans by March 2027.

What Changed

• - Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to...
• SICAR-specific rules: Confirms risk capital investments (e.g., equity, mezzanine) must align with development objectives, exceed mere market risk, and deploy incoming cash into eligible assets;...
• Borrowing: For retail-exposed SIFs/Part II UCIs, investment borrowing capped at 70% of assets/commitments; no hard cap for sophisticated investor funds if disclosed, with SICARs limited to risk...
• Derivatives and techniques: Permits use if economically appropriate (e.g., risk/cost reduction), with risk-spreading via diversified underlyings/collateral; counterparty risk limited if...
• Disclosures: Mandates detailed sales document coverage of investment policy, risks, UCIs/vehicles (including supervision status, fees, risk-spreading), borrowing limits, subscription/redemption...

Suggested Considerations

• Review and update fund documents (e.g., sales documents, instruments of incorporation) to include mandated disclosures on investment strategy/limits, risks, UCIs/vehicles, borrowing, liquidity tools, and retail-specific warnings.
• Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified.
• Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries.
• For retail-marketed funds: Limit investments/UCIs to 25%, cap borrowing at 70%, add prominent risk warnings for illiquids/long-duration.
• Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts.

References

• [1] cssf.lu/wp-content/uploads/cssf25_901eng.pdf
• [2] pwc.lu/en/newsletter/2026/cssf-circular-25-901.html
• [3] aoshearman.com/en/insights/cssf-circular-25-901-a-simplif...
• [4] maples.com/knowledge/cssf-circular-25-901-key-changes-for...
• [5] cssf.lu/en/Document/circular-cssf-25-901/
• [6] debevoise.com/insights/publications/2025/12/cssf-circular...
• [7] bakermckenzie.com/en/insight/publications/2026/01/luxembo...
• [8] cssf.lu/wp-content/uploads/cssf25_901_recueil_eng.pdf

What Changed

• This is not a policy change or new rule; it is an enforcement investigation announcement with no immediate regulatory amendments. It highlights ongoing enforcement of existing rules:
• UK Listing Principles and Rules: These require listed issuers to act with integrity, provide accurate and timely information, and maintain effective systems for compliance (e.g., Principle 2 on...
• Disclosure and Transparency Rules (DTRs): Specifically, DTR 4 mandates inside information disclosures via Regulatory Information Service (RIS), DTR 5 on periodic financial reporting, and DTR 2 on...

Suggested Considerations

• For WH Smith PLC: Cooperate fully with FCA requests for documents/interviews; conduct internal review of disclosure processes; prepare for potential enforcement outcomes (e.g., financial penalties under FSMA s.91 for listing rule breaches or DTR violations).
• For other listed firms: 1. Review disclosure policies against DTR 4 (inside information) and Listing Rule 9; stress-test recent announcements (post-19 Nov 2025).
• announcement sign-off processes involving legal/compliance/IR.
• plan profit warnings or material updates, documenting decision trails.

Key Dates

What Changed

• - Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs.
• Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with...
• Borrowing Limits: New limits for SIFs/Part II UCIs (e.g., 70% of net assets, excluding temporary borrowings tied to commitments); tailored by investor type.
• Enhanced Disclosures: Offering documents must detail investment policies, risks (especially private equity for retail), subscription/redemption processes, liquidity tools, gates, and amendment...
• SICAR Risk Capital: Modernizes definition to include equity, loans, bonds, mezzanine; clarifies direct/indirect investments with three cumulative elements (risk of total loss, no redemption rights,...

Suggested Considerations

• Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e.g., gates, notice periods), redemption processes, and investor-specific warnings.
• Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications.
• Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified.
• For SICARs: Ensure risk capital investments meet modernized criteria; apply look-through for limits.
• Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance.

References

• [1] pwc.lu/en/newsletter/2026/cssf-circular-25-901.html
• [2] bakermckenzie.com/en/insight/publications/2026/01/luxembo...
• [3] ashurst.com/en/insights/the-cssf-updates-the-rules-for-si...
• [4] ogier.com/news-and-insights/insights/cssf-circular-25901-...
• [5] aoshearman.com/en/insights/cssf-circular-25-901-a-simplif...
• [6] arendt.com/news-insights/news/new-cssf-circular-and-conce...
• [7] debevoise.com/insights/publications/2025/12/cssf-circular...
• [8] cssf.lu/en/Document/circular-iml-91-75/

What Changed

• The original Circular CSSF 08/356 (2008) transposed UCITS III requirements on eligible techniques like securities lending and repos.
• Expanded collateral rules: Collateral must now include sustainable assets meeting SFDR criteria, with daily marking-to-market and haircuts adjusted for liquidity and credit risk (Section 3).
• Counterparty exposure limits: Net exposure to a single OTC counterparty capped at 10% of net asset value (NAV), down from previous thresholds in some cases, with mandatory collateralization (Section...
• Operational safeguards: Mandatory use of triparty agents for repos, enhanced segregation of collateral, and annual stress testing disclosures (Section 5, as amended).
• Reporting enhancements: Quarterly reports to CSSF on transaction volumes, risks, and revenues from these activities (Annex 1, updated). These align with ESMA guidelines (e.g., ESMA/2012/832 on OTC...

Suggested Considerations

• *Policy Review & Update: Revise fund prospectuses, KIIDs, and risk management policies to reflect amended limits (e.g., counterparty caps, ESG collateral) within 3 months of 01 January 2026.
• *Risk Management Systems: Implement or upgrade systems for daily collateral valuation, stress testing, and exposure monitoring; conduct gap analysis against Section 4 requirements.
• *Counterparty Due Diligence: Reassess OTC counterparties for eligibility (e.g., EMIR clearing thresholds); negotiate ISDA/CSA agreements with updated haircuts.
• *Operational Setup: Appoint triparty agents where required; ensure collateral segregation complies with Section 5.
• *Reporting & Disclosure: Prepare for new quarterly CSSF filings (template in Annex 1); disclose revenues/reinvestments from techniques in annual reports (Article 14 UCITS Law).

Key Dates

What Changed

The final rule introduces the following substantive amendments: Exceptions for Swaps Intended to be Cleared (ITBC Swaps) Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution.

Suggested Considerations

• *Immediate Actions (Pre-Implementation)
• *Implementation Actions (Upon Effective Date)
• trade disclosure systems to remove PTMMM generation and delivery requirements
• based operations, review implications of superseded Staff Letter No. 23-01
• *Ongoing Compliance

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/9157-25
• [2] cftc.gov/media/12866/federalregister121825/download
• [3] isda.org/2025/11/18/isda-and-sifma-comment-on-cftc-propos...
• [4] gibsondunn.com/derivatives-legislative-and-regulatory-wee...
• [5] sifma.org/advocacy/letters/revisions-to-business-conduct-...
• [6] skadden.com/insights/publications/2025/09/cftc-proposes-e...

What Changed

• This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
• Improving claims handling through reviews of firms' processes.
• Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
• Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns, as...

Suggested Considerations

• Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews.
• Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data.
• Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers.
• Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness.
• Retain records, respond to FCA data requests, and invest in governance/MI for supervision.

Key Dates

References

• [1] tcc.group/blog/2025/12/18/2026-regulatory-priorities/
• [2] ukgicompliance.com/what-the-fca-five-year-direction-means...
• [3] tlt.com/insights-and-events/insight/simplifying-the-insur...
• [4] grantthornton.co.uk/insights/top-themes-for-the-insurance...
• [5] skillcast.com/blog/fca-compliance-priorities
• [6] fca.org.uk/publication/policy/ps25-21.pdf
• [7] iqeq.com/insights/the-five-biggest-compliance-risks-for-2...
• [8] mondaq.com/uk/reinsurance/1734168/uk-insurance-regulation...

What Changed

This is an enforcement case, not a regulatory change; no new rules, requirements, or amendments to the SFO or Listing Rules were introduced. It exemplifies ongoing application of existing insider dealing prohibitions under SFO sections 270-271, where individuals with inside information (e.g., on privatization failure from proxy forms) must not deal in relevant securities. The court's emphasis on "immediate custodial sentence" for professionals in positions of trust signals stricter sentencing norms for such offenses.

Suggested Considerations

• Enhance insider dealing training: Mandate annual refreshers for staff handling corporate actions, emphasizing SFO prohibitions on dealing with inside information (e.g., voting outcomes, privatization status).
• Strengthen information barriers: Implement robust Chinese walls between operational teams (e.g., proxy coordinators) and personal trading, with pre-approval for staff trades in client-related securities.
• Monitor personal trading: Require disclosure and review of employees' holdings in companies involved in serviced transactions; automate alerts for unusual trading pre-announcements.
• Conduct insider lists and attestations: Maintain accurate lists of insiders during corporate events; require signed attestations of non-dealing.
• Audit workflows: Review processes for proxy form handling and voting scrutiny to prevent incidental access to inside information.

Key Dates

References

• [1] fxnewsgroup.com/forex-news/regulatory/former-vp-of-comput...
• [2] fxnewsgroup.com/forex-news/regulatory/hk-court-convicts-f...
• [3] timothyloh.com/insights/latest-news/former-vice-president...
• [4] complianceone.hk/news/complianceone-newsletter-december-2025
• [5] apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announce...
• [6] hubbis.com/news/former-vice-president-of-computershare-re...
• [7] hubbis.com/news/sfc-obtains-order-to-freeze-101-million-b...
• [8] caproasia.com/2025/12/19/hong-kong-court-sentenced-ex-com...

What Changed

• - Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or...
• FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; removes legislative obligations on users to only...
• Overseas benchmarks: Replaces equivalence/endorsement with Overseas Recognition Regime (ORR); designated overseas administrators may avoid dual regulation if ORR-eligible.
• No opt-in: Non-designated benchmarks/administrators unregulated; contributor obligations shift to FCA rules.
• Enhanced FCA powers: Potential extension to intervene/wind-down designated benchmarks and direct firms to restrict usage; may cover non-price data like ESG metrics.

Suggested Considerations

• Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios.
• Participate in HMT consultation (responses via gov.uk) and prepare for FCA consultation on rules.
• Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance.
• Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility.
• Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules.

Key Dates

References

• [1] regulationtomorrow.com/eu/benchmarks-regime-reform-propos...
• [2] fca.org.uk/news/statements/fca-welcomes-reform-uk-benchma...
• [3] financialregulation.linklaters.com/post/102ly45/uk-consul...
• [4] gov.uk/government/consultations/future-regulatory-regime-...
• [5] pwc.co.uk/industries/financial-services/understanding-reg...
• [6] globalfinregblog.com/2025/12/hm-treasury-proposes-to-sign...
• [7] lw.com/admin/upload/SiteAttachments/10-Key-Focus-Areas-fo...
• [8] taylorwessing.com/en/insights-and-events/insights/2026/01...

What Changed

• - Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses...
• Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authorisation remains...
• Clarifies scope for eligible entities (e.g., UCIs, IFMs, management companies under Luxembourg law) performing one or more of three UCI administration functions (defined in point 10); mandates...
• Aligns ICT outsourcing with DORA (effective January 2025) for in-scope UCIAs (credit institutions, investment fund managers, investment firms, certain support professionals), referencing Circular...
• Strengthens delegation rules (section 3.5): prior CSSF notification for critical/important tasks, ongoing monitoring by UCI/IFM, and remediation plans for shortcomings.

Suggested Considerations

• Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations.
• Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025.
• Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750).
• For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/cssf25_900eng.pdf
• [2] blog.uit.lu/circular-cssf-25-90
• [3] ogier.com/news-and-insights/insights/luxembourg-cssf-circ...
• [4] cssf.lu/en/Document/circular-cssf-25-900/
• [5] cssf.lu/en/2025/12/reform-of-circular-cssf-22-811-changes...
• [6] cssf.lu/en/uci-administration/
• [7] harneys.com/our-blogs/regulatory/cssf-circular-25-900-upd...

What Changed

• This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including:
• Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints.
• Formalized due diligence prior to allocating investment projects to funds. No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completeness and documentation,...

Suggested Considerations

• Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e.g., alignment with fund policies), and formalized pre-allocation due diligence; test for operationality via internal audits.
• Document all processes rigorously: Maintain evidence of checks and due diligence to demonstrate skill, care, and diligence in line with authorization conditions.
• Conduct gap analysis against AMF expectations: Cross-reference with similar cases (e.g., operational procedures, AML/CFT); remediate deficiencies promptly.
• Senior manager training: Reinforce personal accountability for firm compliance; update governance frameworks.
• Appeal monitoring: If similarly positioned, prepare for potential appeals to Conseil d’État.

Key Dates

References

• [1] amf-france.org/en/news-publications/news-releases/enforce...
• [2] amf-france.org/en/news-publications/news-releases/enforce...
• [3] amf-france.org/en/news-publications/news-releases/enforce...
• [4] amf-france.org/sites/institutionnel/files/pdf/77488/en/Th...
• [5] amf-france.org/en/news-publications/news-releases/enforce...
• [6] amf-france.org/en/news-publications/news-releases/enforce...
• [7] amf-france.org/en/news-publications/news-releases/enforce...
• [8] amf-france.org/en/news-publications/news-releases/enforce...

What Changed

• - Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure;...
• Scope of UCI Administration: Defines three core functions—registrar, NAV calculation/accounting, and client communication—requiring only one designated service provider per function per UCI (or...
• Governance and Controls: Mandates sound governance principles, control frameworks, escalation processes for errors/incidents, adequate resources (human, ICT), business continuity, and compliance with...
• Delegation Rules: Delegation of tasks allowed but not of monitoring/oversight; requires written contracts, due diligence, and prior CSSF notification (3 months generally, 1 month for certain agents);...
• Contracts and Reporting: Written contracts between UCI administrator and UCI/IFM; annual activity reporting due 5 months after financial year-end, starting from financial years ending post-30 June...

Suggested Considerations

• Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated.
• Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function.
• For delegations: Conduct due diligence, execute written contracts detailing roles/obligations, notify CSSF in advance, retain oversight without delegating monitoring.
• Conclude written contracts with UCI/IFM; submit annual UCIA activity reports.
• UCIs/IFMs: Supervise coordinators, ensure information exchange/cooperation with administrators.

References

• [1] cssf.lu/wp-content/uploads/cssf22_811eng.pdf
• [2] lexnow.lu/blog/articles-4/cssf-circular-22-811-uci-admini...
• [3] cssf.lu/en/uci-administration/
• [4] stibbe.com/publications-and-insights/new-cssf-circular-on...
• [5] cssf.lu/wp-content/uploads/FAQ_UCIA_Circular.pdf
• [6] cssf.lu/en/Document/circular-cssf-22-811/
• [7] ey.com/en_lu/insights/wealth-asset-management/circular-cs...
• [8] simmons-simmons.com/en/publications/cl3lg5am617hn0a74c5aa...

What Changed

• - Updated Reporting Template: FIs must use the new FI Incident Reporting Template (65.8 KB) for submitting details of reportable incidents on MAS-Tx, replacing prior formats.
• Dual Reporting Process: Initial notification required "as soon as possible, but no later than the timeline prescribed" in relevant acts, regulations, notices, circulars, or guidelines; followed by...
• Platform Mandate: All subsequent reports must be filed through MAS-FI Transactions Platform (MAS-Tx), streamlining MAS oversight.

Suggested Considerations

• Review and familiarize with the updated FI Incident Reporting Template (downloadable from MAS site).
• Integrate MAS-Tx platform access and training for compliance, IT, and risk teams to handle submissions.
• Update internal incident response plans to ensure initial notifications occur "as soon as possible but no later than prescribed timelines" under relevant rules (e.g., Technology Risk Management Notices), followed by template-based reports via MAS-Tx post-1 February 2026.
• Conduct gap analysis against related TRM Notices (e.g., FSM-N05 for banks, FSM-N25 for trust companies) to align incident detection and reporting. https://panorays.com/blog/mas-trm-compliance/
• Test processes via simulations, as recommended in TRM guidelines for incident response readiness. https://panorays.com/blog/mas-trm-compliance/

Key Dates

References

• [1] twobirds.com/en/insights/2025/singapore/mas-takes-robust-...
• [2] mas.gov.sg/regulation/circulars/circular-on-financial-ins...
• [3] mas.gov.sg/-/media/mas/regulations-and-financial-stabilit...
• [4] panorays.com/blog/mas-trm-compliance/
• [5] finreg-e.com/regulatory-changes-financial-markets-week-42/
• [6] state.gov/reports/2024-investment-climate-statements/sing...
• [7] globallegalinsights.com/practice-areas/fintech-laws-and-r...
• [8] kroll.com/en/publications/financial-compliance-regulation...

What Changed

There are no new regulatory changes, requirements, or rules introduced by this publication. The statement solely announces the closure of an existing investigation with no identified breaches by Mirabella, maintaining the status quo on AR oversight obligations under FCA rules such as SUP 12 (Appointed Representatives). The FCA reserves the right to reopen if new information emerges, but no policy shifts or guidance updates are provided.

Key Dates

References

• [1] fca.org.uk/news/statements/closure-investigation-mirabell...
• [2] international-adviser.com/fca-closes-investigation-into-c...
• [3] gtreview.com/news/europe/uk-regulator-reveals-active-trad...
• [4] financialinstitutionsnews.com/2025/12/15/fca-closes-inves...
• [5] acaglobal.com/managed-services/regulatory-compliance-supp...

What Changed

• No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
• Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
• Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
• Examples from insurance (e.g., stolen vehicle claims yielding £200m redress; home emergency cover improvements reducing complaints by 61%).

Suggested Considerations

• Embed proactive monitoring: Regularly review customer outcomes under Consumer Duty, acting on foreseeable harm (e.g., communication barriers, vulnerable customer support).
• Respond swiftly to FCA contact: Engage with supervision teams on identified issues; prepare for tools like skilled person reviews or voluntary restrictions.
• Improve practices market-wide: Use FCA guidance (e.g., good/poor examples) to self-assess; ensure clear information, fair value, and accessible support.
• Evidence compliance: Map business to Consumer Duty, monitor biases, and demonstrate senior manager oversight via SM&CR.
• Facilitate redress: Identify and pay compensation promptly when issues arise, as seen in FCA interventions (£200m vehicle claims; £350k home insurance).

References

• [1] cms.law/en/gbr/publication/fca-consumer-duty-implementati...
• [2] fca.org.uk/news/blogs/using-our-full-toolkit-help-consumers
• [3] thepfs.org/learning/consumer-duty/
• [4] fca.org.uk/publications/corporate-documents/our-approach-...
• [5] tlt.com/insights-and-events/insight/recent-fca-focus-on-i...
• [6] cliffordchance.com/insights/resources/blogs/regulatory-in...
• [7] complianceconcourse.willkie.com/resources/insider-trading...
• [8] youtube.com/watch?v=v9nMTZIRd5I

What Changed

• The total revision introduces several critical regulatory shifts: Scope Expansion: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803,...
• Sale or supply of key energy sector equipment
• Gold, precious metals, and diamonds transactions
• Specific maritime equipment
• Designated software exports

Suggested Considerations

• *Immediate (Completed by December 12, 2025):
• related transactions and accounts for compliance with expanded prohibitions
• *Short-term (By January 1, 2026):
• September 30, 2025 contracts under legacy exemption provisions
• related transactions

Key Dates

References

• [1] finma.ch/de/news/2025/12/20251215-sr-946-231-143-6/
• [2] news.admin.ch/de/newnsb/ML0cUymNp0kYO9UTn4nAy
• [3] efd.admin.ch/de/newnsb?publisherIDs=all&topicIDs=all&news...
• [4] finma.ch/de/news/2025/10/20251021-sr-946-231-143-6/
• [5] ihk.de/regensburg/fachthemen/international/nachrichten-in...
• [6] wko.at/aussenwirtschaft/sanktionen-iran
• [7] finma.ch/de/dokumentation/internationale-sanktionen-und-t...
• [8] finma.ch/de/news/

What Changed

• - Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists.
• Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans.
• Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector.
• Financial transaction bans: Five Russian banks and four branches of Russian banks in third countries banned from transactions, especially those using Russian payment systems; eight third-country...

Suggested Considerations

• Immediate screening: Review client lists, transactions, and assets against updated SECO sanctions lists (published by WBF) for matches to 22 persons, 42 entities, 116 vessels, 45 export-controlled firms, 5+4 banks, and 8 third-country firms.
• Asset freezing: Block and freeze any matching assets/funds; prohibit making available.
• Transaction halts: Cease dealings with listed banks, entities, vessels, or sanctioned goods/services.
• Reporting: Notify SECO of frozen assets, blocked transactions, or existing business relationships immediately; conduct additional due diligence on suspicions per Art. (FINMA guidelines).
• Ongoing monitoring: Update compliance systems for dynamic lists; train staff on shadow fleet risks and third-country evasion.

Key Dates

References

• [1] finma.ch/de/news/2025/10/20251031-sr-946-231-116-9/
• [2] bmwet.gv.at/Themen/Exportkontrolle/Export/Embargos-und-Sa...
• [3] finma.ch/de/news/2025/12/20251212-sanktionsmeldung-russla...
• [4] finma.ch/de/news/2025/10/20251030-sr-946-231-176-72/
• [5] vbw-bayern.de/vbw/Themen-und-Services/Au%C3%9Fenwirtschaf...
• [6] seco.admin.ch/seco/de/home/Aussenwirtschaftspolitik_Wirts...
• [7] finma.ch/de/dokumentation/internationale-sanktionen-und-t...
• [8] finma.ch/de/news/

What Changed

• - Upgrade of the reporting taxonomy from XBRL 2.3.0 to XBRL 3.0, introducing technical enhancements for improved data structure and interoperability.
• Validation fixes to address errors in data submission processes.
• Changes to the data point model (DPM), refining how specific data elements are defined and reported.
• These updates align with ongoing refinements to the Banking Statistics Yellow Folder, which contains core definitions for BoE statistical returns.

Suggested Considerations

• Review and update reporting systems to support XBRL 3.0, incorporating validation fixes and DPM changes.
• Participate in the two proposed UAT windows to test submissions under the new taxonomy.
• Subscribe to or amend BoE Statistical Notices circulation list to receive updates.
• Cross-reference against the Banking Statistics Yellow Folder for any definitional impacts on ongoing returns.

Key Dates

References

• [1] chathamfinancial.com/insights/boe-ecb-recap-june-2025
• [2] bankofengland.co.uk/statistics/notice/2025/statistical-no...
• [3] bankofengland.co.uk/statistics/data-collection/statistica...
• [4] einpresswire.com/article/806047941/minutes-of-money-marke...
• [5] bankofengland.co.uk/statistics/data-collection/statistica...
• [6] crediteq.com
• [7] einnews.com/pr_news/875031117/statistical-notice-2025-06-...

What Changed

This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities.

Suggested Considerations

• Conduct internal audits of large loss claim reserving processes to verify compliance with Article 13(1)(a) of the 1994 Regulations, ensuring estimates are accurately recorded in databases without undocumented overrides.
• Review senior management oversight of claims handling; document all approvals and prohibit informal (e.g., in-person or hard-copy only) processes that bypass controls.
• Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios.
• Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines).
• Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments.

Key Dates

References

• [1] centralbank.ie/news/article/press-release-public-statemen...
• [2] irishexaminer.com/business/companies/arid-41759015.html
• [3] lawsociety.ie/gazette/top-stories/2025/december/former-rs...
• [4] insurancetimes.co.uk/news/former-rsa-ireland-chief-execut...
• [5] centralbank.ie/news-media/legal-notices/enforcement-actions
• [6] irishtimes.com/business/2025/12/12/former-rsa-ireland-ceo...
• [7] centralbank.ie/docs/default-source/news-and-media/legal-n...
• [8] centralbank.ie/news-media/legal-notices/inquiries/a-regul...

What Changed

• - The UN Sanctions Committee modified the sanctions list targeting persons, companies, and organizations related to Iraq on December 9, 2025; this amendment was published by SECO on its website and...
• Switzerland automatically applies UN sanctions lists without delay per the Federal Council's Ordinance of March 4, 2016, making the update immediately binding.
• Financial intermediaries must implement prohibitions, freeze assets of newly listed or adjusted entities, and notify SECO of any impacted business relationships, consistent with prior Iraq sanctions...

Suggested Considerations

• Screen against SESAM database: Immediately rescreen client portfolios, transactions, and business relationships against the updated Iraq sanctions list via SECO's SESAM tool (https://www.seco.admin.ch/sesam).
• Asset freeze: Block and freeze any assets, funds, or economic resources belonging to newly sanctioned parties; do not dispose of or make available.
• Report to SECO: Notify SECO of any matches or business relationships via the designated reporting channel within required timelines (typically immediate for freezes).
• Internal review: Update compliance systems, screening tools, and policies; conduct targeted audits for Iraq/Middle East exposure; train staff on implementation.
• Document compliance: Maintain records of screening, freezes, and reports for FINMA audits.

Key Dates

References

• [1] bafu.admin.ch/en/newnsb/qlHPl79jIK8jeS4SVOhSc
• [2] finintegrity.org/august-2025-sanctions-and-export-control...
• [3] finma.ch/it/news/2025/12/20251211-sr-946-206/
• [4] finma.ch/it/news/2025/08/20250813-sr-946-206/
• [5] finma.ch/news/2025/08/20250813-sr-946-206/
• [6] ofac.treasury.gov/recent-actions/20251120
• [7] bakermckenzie.com/-/media/files/insight/publications/2019...
• [8] info4c.net/knowledge/news/2018/12/28/selected-sanctions-n...

What Changed

• The roadmap encompasses four major reform areas: Supervision: Implementation of a new integrated, risk-based supervisory approach introduced in January 2025, consolidating multidisciplinary teams...
• Insurance: Major compatibility review to eliminate duplication with Solvency II reforms and review of 2021 Recovery Planning Regulations
• Banking: Review of domestic banking rules predating CRD V/CRR to ensure consistency with updated EU standards
• Credit Unions: Updates to the Credit Union Handbook following simplification of the Lending Framework
• Funds: Changes to AIF rulebook and UCITS regulation with full review of the Fund Service Provider Framework

Suggested Considerations

• *Immediate actions for compliance professionals:
• *Monitor consultation releases: Track the Central Bank's website for the 2026 RIA Framework consultation and respond with firm-specific impact assessments
• *Assess rulebook changes: Review how proposed updates to insurance regulations, banking rules, credit union handbook, and fund regulations affect your firm's compliance framework
• *Evaluate supervisory engagement: Understand how the new integrated supervisory model affects your firm's supervisory relationship and reporting lines
• *Prepare for gatekeeping changes: Anticipate enhanced consistency and transparency requirements in authorisation and Fitness & Probity processes

Key Dates

References

• [1] centralbank.ie/news/article/press-release-central-bank-of...
• [2] williamfry.com/knowledge/the-central-banks-publishes-its-...
• [3] centralbanking.com/central-banks/financial-stability/7974...
• [4] centralbank.ie/docs/default-source/publications/regulator...
• [5] centralbank.ie/regulation/transforming-regulation-and-sup...
• [6] globallegalinsights.com/practice-areas/banking-and-financ...
• [7] centralbank.ie/docs/default-source/regulation/transformin...
• [8] centralbank.ie/publication/corporate-reports/strategic-plan

What Changed

• - Introduces precise definitions for CRR Article 126a(2) terms, enabling 100% risk weight (instead of 150%) for ADC exposures to residential property if conditions are met: at least 50% of total...
• Mandates "sound standards for lending and credit monitoring" alongside these criteria.
• Accounts for social housing/public not-for-profit lending specificities, with tailored rules for regulated entities serving long-term tenant housing.
• Replaces prior "particularly high-risk exposure" class with dedicated ADC class under CRR3.

Suggested Considerations

• Review and classify ADC exposures against EBA-defined criteria (e.g., contract thresholds, equity levels, monitoring standards) to determine eligibility for 100% risk weight.
• Update internal policies, risk assessment models, and credit approval processes to incorporate "sound lending standards" and EBA specifications, including social housing carve-outs.
• Recalculate capital requirements under standardized credit risk approach; report changes via CRR disclosures.
• Maintain documentation proving compliance (e.g., deposit proofs, equity valuations) for supervisory audits by CSSF.
• Institutions must "make every effort to comply" per EBA Regulation Article 16(3).

Key Dates

References

• [1] banking.vision/en/guidelines-on-adc-exposures-to-resident...
• [2] finanssivalvonta.fi/en/publications-and-press-releases/su...
• [3] regulationtomorrow.com/de/eba-final-report-guidelines-on-...
• [4] cssf.lu/en/Document/circular-cssf-25-899/
• [5] jdsupra.com/legalnews/eba-final-guidelines-on-adc-exposur...
• [6] cssf.lu/en/regulatory-framework/
• [7] cssf.lu/wp-content/uploads/newsletter299.pdf
• [8] eba.europa.eu/publications-and-media/press-releases/eba-p...

What Changed

The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries. The timing of this update aligns with broader international sanctions activity on Sudan.

Suggested Considerations

• *Sanctions List Update: Immediately download and integrate the updated SESAM sanctions database into all transaction screening systems and customer due diligence (CDD) procedures.
• *System Screening: Conduct full rescreening of existing customer relationships, beneficial owners, and transaction counterparties against the updated Annex 2 designations.
• *Transaction Review: Review all pending and recent transactions (typically 30-90 days prior) to identify any that may have involved newly designated persons or entities.
• *Blocked Assets: If any blocked persons or entities are identified in existing customer relationships, immediately freeze accounts and file required reports with SECO.
• *Staff Training: Update compliance and front-office staff on the specific changes to ensure proper application of the updated sanctions regime.

Key Dates

References

• [1] steptoe.com/en/news-publications/international-compliance...
• [2] finintegrity.org/july-2025-sanctions-and-export-controls-...
• [3] ofac.treasury.gov/sanctions-programs-and-country-informat...
• [4] finma.ch/en/news/2025/12/20251209-sr-946-231-18/
• [5] press.un.org/en/2025/sc16266.doc.htm
• [6] gov.im/news/2025/dec/12/sanctions-update-sudan/?iomg-devi...
• [7] finma.ch/en/documentation/international-sanctions-and-com...
• [8] finma.ch/en/news/

What Changed

• - Deletion of 37 whole reporting templates identified as duplicative, outdated, or low-value: 34 FINREP templates, 2 COREP templates (C05.01 and C05.02, now obsolete), and PRA109.
• Consolidation of remaining FINREP scoping provisions into a single section of the PRA Rulebook (new Chapters 5A–5F of the Reporting (CRR) Part), with clarifications to unclear or duplicative...
• Alignment of FINREP remittance deadlines to 30 business days for reports under Article 430(3), Article 11(2), and new Chapters 5A–5F.
• Updates to Supervisory Statement SS34/15 – Guidelines for completing regulatory reports to reflect deletions and consolidations.
• Refinements to the waiver framework for individual UK FINREP reporting in UK consolidation groups (excluding ring-fenced groups), allowing waivers if a single entity contributes 90-95% of group...

Suggested Considerations

• Review and update internal reporting systems, processes, and controls to cease submission of the 37 deleted templates for reference dates from 31 December 2025 onwards.
• Confirm applicability of consolidated FINREP scoping rules (Chapters 5A–5F) and adjust scoping for remaining templates, incorporating clarified conditions.
• Assess eligibility for individual FINREP waivers under the updated framework if part of a UK consolidation group; apply to PRA if criteria met (90-95% asset contribution).
• Update compliance policies and training to reflect SS34/15 amendments and aligned remittance deadlines.
• Review Pillar 3 disclosure obligations for any ongoing requirements tied to deleted templates and prepare for potential future changes.

Key Dates

References

• [1] regulationtomorrow.com/eu/pra-ps27-26-future-banking-data...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] pwc.co.uk/industries/financial-services/understanding-reg...
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