The Securities and Exchange Commission today announced the appointment of Demetrios (Jim) Logothetis, as Chairman, and Mark Calabria, Kyle Hauptman, and Steven Laughton, as Board members, of the Public Company Accounting Oversight Board (PCAOB). George…
The Federal Financial Supervisory Authority (BaFin) has issued its “Guidance on ICT Risks in the Use of Artificial Intelligence at Financial Entities”. The guidance will help entities manage ICT risks in accordance with the requirements under DORA.
AI Analysis
BaFin's "Guidance on ICT Risks in the Use of Artificial Intelligence at Financial Entities," published December 18, 2025, provides non-mandatory advice to help financial entities manage ICT risks from AI under DORA across the AI lifecycle. It matters because it integrates AI explicitly into existing ICT risk frameworks, emphasizing security, resilience, and third-party risks for supervised institutions, aligning with RTS on ICT risk management (EU 2024/1774) and subcontracting (EU 2025/532). This clarifies supervisory expectations amid growing AI adoption in finance, reducing ambiguity in DORA compliance.
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 testing: Robust standards, documentation, testing proportionate to criticality; special focus on generative AI/LLMs, open-source, and code generation risks.
Develop and approve AI strategy integrated with ICT roadmap and governance.
Embed AI in existing ICT risk framework, ensuring lifecycle coverage with safeguards (e.g., testing, monitoring, decommissioning).
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
01 February 2024
- Related BaFin/Bundesbank supervisory notice on cloud outsourcing (contextual reference)
18 December 2025
- Guidance issuance date
Compliance Impact
Urgency: High – DORA is live (effective Jan 17, 2025), and AI use is widespread; this guidance operationalizes ICT requirements for AI, exposing non-compliant firms to supervisory scrutiny, fines, or remediation orders under CRR/Solvency II. It heightens focus on third-party/cloud risks amid EU AI Act rollout, demanding immediate gap assessments to avoid operational resilience failures.
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
AI Analysis
On January 29, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) reduced the price cap on Russian crude oil from USD 47.6 to USD 44.1 per barrel, effective February 1, 2026. This adjustment tightens existing sanctions enforcement and requires Swiss financial intermediaries to immediately implement updated compliance controls and reporting obligations under the Ukraine Sanctions Ordinance (SR 946.231.176.72).
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.
Suggested Considerations
*Implement price cap enforcement: Update transaction monitoring systems to flag and block crude oil transactions exceeding USD 44.1 per barrel from Russian sources
*Asset freezing: Continue blocking assets of sanctioned persons and entities; verify no new transactions circumvent the lower threshold
*Reporting obligations: Report affected business relationships to SECO in accordance with the Sanctions Ordinance
*Enhanced due diligence: Beyond SECO reporting, conduct additional investigations under Article 6 of the Money Laundering Act (GwG) when suspicious indicators arise
*Suspicious activity reporting: If enhanced due diligence cannot resolve suspicions, file reports with the Financial Intelligence Unit (FIU) under Article 9 GwG without delay
Key Dates
January 29, 2026
– SECO publishes amended Annex 28 of the Sanctions Ordinance
February 1, 2026
– New oil price cap (USD 44.1) becomes effective and binding
ImmediateDEADLINE
– Financial intermediaries must implement updated prohibitions and screening procedures
Administrative sanction imposed on a registered alternative investment fund manager (“AIFM”)
AI Analysis
The CSSF imposed an administrative fine of EUR 10,000 on registered alternative investment fund manager (AIFM) C5 S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties and serves as a warning to supervised entities on the consequences of non-compliance with supervisory requests. It matters because it demonstrates the CSSF's willingness to publish names and impose fines for procedural lapses, potentially signaling increased scrutiny on AIFMs' AML/CFT obligations amid broader regulatory focus on financial crime risks.
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 introduced;...
Suggested Considerations
Immediate verification: Confirm timely submission of 2025 financial crime questionnaire (likely due April 2026 for 2025 data); review internal processes for CSSF reminders and automate alerts.
Procedural enhancements: Implement robust tracking systems for supervisory questionnaires, designate a responsible senior manager for AML cooperation, and document all responses or justifications for delays.
Training and testing: Conduct firm-wide training on AML/CFT Law Article 5(1) obligations; perform mock audits of reporting workflows, especially for registered AIFMs managing non-CSSF authorized funds.
Engagement protocol: Respond promptly to CSSF reminders; request in-person meetings if needed before fines escalate; review cooperation history to mitigate fine severity.
Policy updates: Align with CSSF Circular 25/894 for expanded AIFM reporting on unauthorized funds (notification within 10 working days for registered AIFMs).
Key Dates
4 April 2025DEADLINE
- Deadline for submission of the annual financial crime questionnaire covering the year ending 31 December 2024
11 September 2025
- Date CSSF imposed the EUR 10,000 administrative fine on the AIFM for non-submission
9 January 2026
- Publication date of the sanction decision
30 January 2026
- Publication of the queried sanction notice (noting minor title discrepancy possibly referencing a separate but analogous case).[user provided]
Compliance Impact
Urgency: High – This sanction, though modest at EUR 10,000, exemplifies CSSF's proactive use of fines and public naming for AML reporting failures, with potential for higher penalties up to EUR 500,000 or 0.5% of turnover. It heightens risks for registered AIFMs amid CSSF's 2025-2026 priorities on financial crime, sanctions, and expanded reporting (e.g., Circular 25/894), where procedural lapses can trigger investigations, reputational damage, and barriers to remediation. Firms must prioritize to avoid escalation, especially post-publication on 30 January 2026.
Speech by Sheldon Mills, at the FCA's Supercharged Sandbox Showcase event. Before we begin, take a look around this room. This is the Supercharged Sandbox. 23 firms at the frontier of retail financial services, chosen from 132 applications. If anyone still doubts the pace of AI change in our sector, this room is the answer.The Board has asked me to lead the long-term review into AI and retail financial services. I will report to the FCA Board in the summer, setting out recommendations to help...
AI Live Testing now open for applicationsAt the FCA, we’re providing a structured but flexible space where firms can test AI-driven services in real-world conditions, all with our regulatory support and oversight and help from our technical partner, Advai. Collaboration and communication is at the heart of what we are doing.The first cohort joined AI Live Testing in October last year. We opened a second application window on 19 January 2026 and are now inviting applications.Moving on from 'PO...
AI Analysis
The FCA's AI Live Testing initiative provides a voluntary, structured program for firms with mature AI proofs-of-concept (POCs) to test AI-driven services in controlled real-world environments under regulatory oversight and support from technical partner Advai. This matters because it enables safe progression from 'POC paralysis' to deployment, while helping the FCA gather insights on translating AI principles into consumer and market protections, informing future regulation. Participation enhances firms' governance, risk management, and evaluation frameworks for responsible AI use in financial services.
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 risk management. It complements the FCA's Supercharged Sandbox for earlier-stage AI exploration.
Suggested Considerations
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.org.uk for queries.
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.g., evaluation frameworks) to strengthen internal AI practices.
Key Dates
October 2025
- First cohort began testing (historical reference)
19 January 2026
- Second application window opens
2 March 2026DEADLINE
- Application deadline for second cohort
April 2026
- Testing starts for second cohort
Mid
March 2026; - Notification of successful applicants
Compliance Impact
Urgency: Medium - Voluntary program, but signals FCA's proactive stance on AI oversight; non-participation risks lagging in best practices for Consumer Protection / Conduct and Operational Resilience / Outsourcing as regulator builds evidence for potential rules. Matters for competitive edge in AI deployment and demonstrating alignment with principles-based regulation amid 'POC paralysis'. Early movers gain tailored support, intelligence-sharing on risks, and influence on FCA's evolving AI approach.
ESMA publishes report on cross-border marketing of funds including statistics on notifications 06 January 2026 The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published its third report on marketing requirements and marketing communications under the Regulation on cross-border distribution of funds . For the first time, the report includes statistics on notifications of cross-border marketing of funds. Drawing on input from ...
ESMA signs Memorandum of Understanding with the Reserve Bank of India 27 January 2026 CCP International cooperation The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has signed a Memorandum of Understanding (MoU) with the Reserve Bank of India (RBI) to facilitate cooperation and exchange of information for the recognition of central counterparties (CCPs) established in India and supervised by RBI. This agreement marks a significant step...
In his latest blog, Governor Gabriel Makhlouf argues that economists must adapt their analytical frameworks and expand their focus beyond traditional topics to address emerging challenges—such as geopolitical upheaval and defence spending—in order to provide robust evidence-based policy advice that serves the public interest.
FCA stunt launches new Firm Checker tool as around 700,000 people lose money to investment scams. Morning commuters at London Waterloo got more than their usual caffeine hit today when a mysterious 'ATM' promising to 'give away a fortune' stopped them in their tracks – and revealed an unexpected surprise.As curious passers-by approached the machine, the screen slid open to unveil Emil the Seal, the FCA's finance-friendly mascot, delivering a blunt message about the dangers of investment scams...
The FCA has called on the insurance industry to help more consumers access products that support them and their families if they become critically ill or die. The interim findings of its competition review of pure protection products found that, for those consumers that have taken out protection insurance, the market mostly works well. There are a wide range of products, most consumers can claim when they need to, and the costs of cover have remained stable in the last few years.But 58% of ad...
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti (SR 946.231.139.4) publiziert.
Backgrounder: Final Liquidity Adequacy Requirements Guideline (2026)
AI Analysis
The OSFI Final Liquidity Adequacy Requirements (LAR) Guideline (2026) finalizes revisions to liquidity risk monitoring standards for federally regulated deposit-taking institutions, incorporating feedback from a 2025 consultation to address evolving financial products like partnership deposits and structured notes. It enhances resilience against liquidity stress by clarifying retail funding classifications and aligning with Basel III standards, balancing regulatory burden with institutions' need to innovate and compete. This matters because liquidity ranks as a top risk amid geopolitical tensions, market uncertainty, and rapid cash outflows, directly impacting institutions' ability to meet obligations during stress.
What Changed
- Clarifies classification of deposits as retail funding for favorable liquidity treatment, segmenting partnership deposits by insurance status, transactional account type, and established retail...
Combines two proposed categories of retail structured notes into one, aligning their liquidity treatment with term deposits managed by unaffiliated third parties; specifies maturity measurement for...
Simplifies the definition of retail rate-sensitive deposits to improve consistency in liquidity risk measurement across LCR, NSFR, and NCCF metrics.
Builds on prior LAR updates (e.g., 2025), incorporating Basel Consolidated Framework standards with OSFI-specific notes for Canadian institutions; maintains two core standards (LCR and NSFR) plus...
Reflects stakeholder feedback on draft revisions, enhancing treatment of hybrid retail-wholesale products amid market innovation.
Suggested Considerations
Review and update internal liquidity risk frameworks, models, and reporting to incorporate clarified retail funding classifications (e.g., partnership deposits, structured notes) for LCR, NSFR, NCCF, and other metrics.
Recalibrate deposit classifications, maturity calculations for autocallable notes, and contingent funding triggers; ensure alignment with OSFI Notes in the guideline and read alongside Guideline B-6.
Conduct gap analyses against prior LAR versions (e.g., 2025) and test compliance via supervisory tools like OCFS (if applicable) and intraday monitoring; prepare for OSFI assessments.
Institutions should document processes for retail rate-sensitive deposits and notify OSFI if needed (e.g., Category III SMSBs on derivatives within 60 days of quarter-end).
Engage OSFI via Consultations@osfi-bsif.gc.ca for clarifications; maintain records of consultation feedback implementation where relevant.
Compliance Impact
Urgency: High – With effectiveness on May 1, 2026 (approx. 3 months from now), institutions face tight timelines for system updates, model recalibrations, and staff training amid liquidity as a top 2025-2026 risk. Non-compliance risks supervisory intervention under Bank Act ss. 485(3)/949(3) or TLCA s. 473(3), potential administrative monetary penalties, and heightened scrutiny in OSFI's quarterly risk assessments; changes sharpen focus on stress resilience while allowing competition, but misclassification of evolving products could amplify funding costs or stability risks.
Central Bank of Ireland has successfully completed the sale of its Spencer Dock (East Wing) building to the Office of Public Works for €23.7m. The sale of Spencer Dock was a key element of the Central Bank’s longer term property strategy aligned to our decision to develop a single Dockland Campus through the purchase of our North Wall Quay building and subsequent purchase of our Mayor Street building. This sale of the East Wing, to Office of Public Works on 22 January 2026, follows the earlie...
We’re working closely with the Office of Financial Sanctions Implementation (OFSI), UK law enforcement, and our regulatory partners to tackle the abuse of cryptoassets and associated money‑laundering activities. Read the full blog on the OFSI’s website.
We have signed a contract with Etrading Software (ETS) to deliver the UK bond consolidated tape. A high-quality tape will provide investors with a comprehensive overview of the bond market and support price formation and liquidity. It will help maintain the UK’s position as a highly competitive and compelling place to invest and grow.ETS has now launched a website that sets out key milestones and provides technical information for data contributors and users. We will continue to support ETS a...
MAS announced that Singapore intends to join international efforts to enhance the capacity of the International Monetary Fund to help vulnerable member countries deal with economic shocks.
The Securities and Exchange Commission today filed settled charges against Archer-Daniels-Midland Company (ADM) and its former executives, Vince Macciocchi and Ray Young, and a litigated action against its former executive Vikram Luthar, for …
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen betreffend Guatemala (SR 946.231.137.6) publiziert.
The FCA has launched a review into the implications of advanced AI on consumers, retail financial markets and regulators. The Review will be led by Sheldon Mills and builds on the FCA’s existing work on AI. This includes its AI Discussion Paper, AI Sprint, and AI Lab including AI Live Testing and its groundbreaking Supercharged Sandbox supported by NVIDIA.AI is already embedded across financial services. Rapid advances in generative, agentic and emerging forms of AI mean the next phase of cha...
On 21 January 2026, Guavapay Limited entered compulsory liquidation. The Official Receiver, an officer of the Insolvency Service, is its liquidator. Guavapay is authorised by the FCA to issue E-money and provide payment services to its customers.On 17 September 2025, Guavapay agreed to a voluntary requirement with the FCA, restricting the activities it can undertake. See details on the Financial Services Register.As liquidator, The Official Receiver is responsible for:Managing customer claims...
Sanctions & settlements MAR Compliance Journalists Investment services providers The AMF Enforcement Committee fines an investment services provider and its director a total of €850,000
Securities and Exchange Commission Chairman Paul S. Atkins and Commodity Futures Trading Commission Chairman Michael S. Selig will hold a joint event, previously scheduled for Jan. 27, now rescheduled for Thursday, Jan. 29, from 2 p.m. to 3 p.m. at CFTC…
The latest Accelerated Settlement Taskforce (AST) report updates on the significant progress made towards the move to T+1. Read the AST report.Jamie Bell, head of capital markets at the FCA, said:'T+1 marks a major milestone in our drive to support growth and innovation. Faster settlement cycles will reduce risk, free up capital for faster reinvestment and align with other major markets.'We are delighted to see the great progress made last year highlighted in the AST’s report. By the end of t...
FINRA issued an Information Notice on January 3, 2025, modifying the Contrary Exercise Advice (CEA) cut-off time for options expiring on January 9, 2025, from the standard 5:30 p.m. ET to 10:00 a.m. ET due to the National Day of Mourning. This time-sensitive directive required immediate operational adjustments for all broker-dealers and clearing members handling options exercise instructions on that specific date.
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 processing timeframes remained unaffected by the market closure.
Restricted Exercise Classes: Exercises in non-expiring American-style, cash-settled index options and non-expiring American-style, cash-settled FLEX ETF option classes were prohibited on January 9,...
Suggested Considerations
*Update Internal Procedures: Modify systems and workflows to enforce the 10:00 a.m. ET cut-off instead of the standard 5:30 p.m. ET deadline for January 9, 2025 options
*System Configuration: Reprogram trading platforms, order management systems, and compliance monitoring tools to reject exercise instructions received after 10:00 a.m. ET on that date
*Staff Communication: Notify all relevant personnel (trading desk, operations, compliance, customer service) of the accelerated deadline and restricted exercise classes
*Customer Notification: Inform retail and institutional clients of the early cut-off time for options expiring on January 9, 2025
*Submission Coordination: Ensure CEA submissions to exchanges and OCC occur within the compressed timeframe
Key Dates
January 9, 2025DEADLINE
10:00 a.m. ET; Final deadline for option holders to make exercise/non-exercise decisions and for members to accept exercise instructions (accelerated from standard 5:30 p.m. ET)
January 9, 2025DEADLINE
10:00 a.m. ET; Final deadline for members to submit Contrary Exercise Advice to exchanges or OCC (accelerated from standard 5:30 p.m. ET or 7:30 p.m. ET depending on account type and submission method)
January 9, 2025
National Day of Mourning; national options exchanges closed; exercises in specified option classes prohibited
Compliance Impact
Urgency: HIGH (for January 9, 2025 operations; now historical)
This FINRA Information Notice announces the SEC's reduction of the Section 31 fee rate to $0.00 per million dollars in specified securities transactions, effective May 14, 2025, following the SEC's Fee Rate Advisory for Fiscal Year 2025. It matters because it eliminates these transaction fees for FINRA member firms for the remainder of FY 2025 (and potentially beyond until FY 2026 appropriations), reducing costs and simplifying billing processes amid the SEC's over-collection of its appropriation target.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
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...
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 will assess fees on member firms per Section 3 of Schedule A to the By-Laws, aligned with SEC adjustments made in consultation with the Congressional Budget Office and Office of Management and...
Suggested Considerations
Update internal billing, invoicing, and financial reporting systems to reflect the $0.00 rate starting May 14, 2025, using trade date as the charge date per 17 CFR 240.31(a)(3).[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
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.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
Test systems for security futures (unchanged rate) and confirm no inadvertent charging of Section 31 fees post-effective date.
Key Dates
April 8, 2025
- SEC announces Fee Rate Advisory for Fiscal Year 2025
April 24, 2025
- FINRA publishes Information Notice.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
May 13, 2025
- Last day for current rate of $27.80 per million (trade dates through this date).[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
May 14, 2025
- New rate of $0.00 per million takes effect for trade dates (charge dates) on or after this date; applies to OTC sales and options settlements/exercises.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
Ongoing until 60 days after FY 2026 appropriation enactment
- $0.00 rate remains in effect
Compliance Impact
Urgency: Low - This is a beneficial change eliminating fees due to SEC over-collection, with no new requirements or penalties; firms already past the May 14, 2025, effective date (as of January 2026) face minimal risk if systems were updated timely. It matters for cost savings, accurate financials, and avoiding erroneous collections, but non-compliance (e.g., continued billing) could lead to refunds or disputes rather than enforcement.[https://www.finra.org/rules-guidance/notices/information-notice-20250424]
This FINRA Information Notice announces the termination of **Prospective CAT Cost Recovery Fee 2025-1** effective July 1, 2025, with **Prospective CAT Cost Recovery Fee 2025-2** taking effect for transactions in eligible securities by FINRA member CAT executing brokers. It matters because firms must transition billing and payment processes seamlessly to avoid disruptions in CAT cost recovery compliance under FINRA Rule 6897(b)(1)(D).
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).
Suggested Considerations
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
June 30, 2025
- Last day Prospective CAT Cost Recovery Fee 2025-1 applies to transactions
- Last invoice sent for Fee 2025-1 (based on June 2025 transactions)
August 2025DEADLINE
- Payments due for Fee 2025-1 final invoice; first invoices for Fee 2025-2 issued (based on July transactions)
Compliance Impact
Urgency: Medium - Primarily administrative; no new reporting burdens, but failure to transition could lead to underpayment, late fees, or Rule 6897 violations. Matters for high-volume brokers due to monthly cash flow impacts and ongoing CAT funding obligations (totaling FINRA's 2025 budgeted costs). As of January 2026, firms should have adapted, but audits may flag non-compliance.
This FINRA Information Notice dated August 14, 2025, reminds registered persons and firms of annual continuing education (CE) requirements under FINRA Rule 1240, including 2025 Regulatory Element completion by December 31, 2025, and resources for Firm Element plans via the FLEX catalog. It matters because non-compliance triggers automatic CE inactive status, halting registered activities, with today's date (January 25, 2026) indicating the deadline has passed, requiring immediate remediation for affected individuals.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
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...
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...
2025 Regulatory Element courses are pre-assigned via FinPro Gateway, with topics viewable via FINRA's interactive tool; changes occur if registrations are...
Suggested Considerations
Registered persons: Log into FinPro Gateway to complete assigned 2025 Regulatory Element courses by deadline (or request extension via firm for good cause); update contact info for notifications.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Firms: Conduct annual Firm Element needs analysis and develop written training plans using FLEX and published Regulatory topics; monitor completion, request extensions if needed, and maintain records.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Key Dates
October 1 (annually)
- FINRA publishes upcoming Regulatory Element topics by registration category
January 1, 2023
- Effective date of CE rule amendments requiring annual Regulatory and Firm Elements.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
July 1, 2024
- Launch of FLEX catalog for Firm Element resources.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
December 31, 2025DEADLINE
- Deadline to complete 2025 Regulatory Element courses; non-completion results in automatic CE inactive status.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Compliance Impact
Urgency: High - The December 31, 2025, deadline has passed (as of January 25, 2026), meaning non-compliant registered persons are already CE inactive and barred from registered functions until remediation, risking operational disruptions, exam retakes, or enforcement. Firms face supervisory liability for inadequate monitoring, with repeated reminders (e.g., 2024 notice) signaling FINRA enforcement focus.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
FINRA's Information Notice dated October 21, 2025, reminds member firms of NSCC's amendment to Rule 50, effective October 17, 2025, which removes the "Settle Prep Day" from the ACATS process, shortening full customer account transfers to 3-4 business days. This matters because it aligns with FINRA Rule 11870's requirements to expedite transfers, enhances operational efficiency, reduces risk, and improves client experience amid broader industry shifts like T+1 settlement.[original notice]
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...
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...
Overall Timeline Reduction: Full ACATS transfers now complete in 3-4 business days (previously longer), supporting faster asset access without manual processes.
FINRA Rule 11870 remains unchanged but continues to mandate use of ACATS (when both firms participate), prompt validation/exceptions, and coordination to expedite transfers.[original notice]
Suggested Considerations
Operational Readiness: Coordinate between transfer and settlement operations to handle shortened cycles and next-day settling; validate/except instructions within 3 business days per FINRA Rule 11870(b).[original notice]
Exception Handling: Promptly resolve any transfer instruction exceptions (Rule 11870(b)(2)); ensure ACATS data meets minimum requirements to avoid rejections.
System Updates: Migrate to new ACATS interfaces/formats ahead of October 2026 decommission; test for mutual funds, options, and complex assets.
Contact FINRA/NSCC: Direct questions to Kathryn Mahoney (FINRA) at (646) 315-8428 or email; reference NSCC Important Notice A9646 for details.[original notice]
Monitoring: Firms should already be compliant as enhancement launched October 17, 2025; address any post-implementation issues via DTCC support.
- Federal Register publication of SEC approval (90 FR 43709).[original notice]
October 17, 2025DEADLINE
- Effective date: Removal of Settle Prep Day and Fund/SERV changes; firms must support next-day settling assets.[original notice]
October 2026
- Planned modernization of ACATS client interfaces (decommission of legacy formats; migration to JSON/MQ for enhanced messaging)
Compliance Impact
Urgency: Medium - Effective over three months ago (as of January 2026), with industry-wide accommodation confirmed; no new mandates but requires ongoing operational alignment to avoid Rule 11870 violations (e.g., delays in validation or exceptions). Matters for reducing transfer failures, enhancing efficiency post-T+1, and minimizing client complaints on account mobility; non-compliance risks FINRA scrutiny on customer protection.[original notice]
FINRA's Information Notice 11/7/25 publishes a **2026 Filing Schedule** on its website to guide clearing firms on accurate submission dates for extensions of time under Federal Reserve Regulation T, SEA Rule 15c3-3, and FINRA Rule 4210, accounting for holidays and business days. This matters because the automated REX system rejects incorrect dates, forcing resubmissions that delay compliance and risk regulatory violations amid shortened settlement cycles.
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).
Suggested Considerations
Access and reference the 2026 Filing Schedule on FINRA's website (via https://www.finra.org/rules-guidance/notices/information-notice-20251107 or related pages) for all REX system submissions.
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
November 7, 2025
- Notice published; 2026 Filing Schedule made available on FINRA website
Throughout 2026
- Use Filing Schedule for all extension requests, especially pre/post-holidays (e.g., Veterans Day 11/11/2026 bank holiday, Thanksgiving 11/26/2026, Christmas 12/25/2026)
30th calendar day after settlement
- (d)(2)
45th calendar day after settlement
- (d)(3), (h)
2nd business day after 30th calendar day from segregation deficit
- (d)(4)
Compliance Impact
Urgency: Medium - Proactive guidance prevents operational disruptions from REX rejections, but no immediate deadlines or penalties for non-use; however, inaccurate filings risk delayed margin compliance, customer liquidations under Regulation T, or possession/control failures under SEA Rule 15c3-3, especially in holiday periods with T+1 settlement pressures. Firms should integrate now (as of January 2026) to ensure Q1 readiness.
FINRA Information Notice 11/10/25 provides due dates for 2026 and Q1 2027 filings of Annual Reports, FOCUS Reports, Form Custody, and various supplemental schedules under SEA Rule 17a-5 and FINRA Rule 4524. It matters because it ensures timely electronic submissions via FINRA Gateway, incorporates SEC amendments for EDGAR PDF filings (with future Interactive Data requirements), and highlights a 30-day extension option for qualifying smaller firms, helping prevent compliance failures amid federal holidays. https://www.finra.org/rules-guidance/notices/information-notice-20251110
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...
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)...
30-Day Extension for Annual Reports: Available under SEC February 2021 order for qualifying SIPC members (e.g., smaller firms facing audit burdens), requiring FINRA notification per Regulatory Notice...
SIPC Filing via FINRA: SIPC members' Annual Report filings through FINRA Gateway satisfy SIPC requirements via agreement. https://www.finra.org/rules-guidance/notices/information-notice-20251110
Suggested Considerations
Submit all filings electronically via FINRA Gateway by 11:59 p.m. ET on due dates; obtain EDGAR access for Annual Reports.
For 30-day extension: Confirm eligibility per SEC order, notify FINRA as in Regulatory Notice 21-05 before standard due date. https://www.finra.org/rules-guidance/notices/information-notice-20251110
Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable.
Prepare for Interactive Data: Larger firms by mid-2027 (test EDGAR Interactive Data Files).
Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site. https://www.finra.org/rules-guidance/notices/information-notice-20251110 https://www.finra.org/sites/default/files/2025-11/Information-Notice-20251110.pdf
Compliance Impact
Urgency: High – Multiple imminent deadlines (e.g., January 27-29, 2026 for Q4 2025 filings, just days from today), mandatory electronic/EDGAR shifts, and late fees/exam risks for misses; smaller firms gain extension relief but must notify promptly. Non-compliance risks enforcement under SEA Rule 17a-5, operational disruptions, and audit delays. https://www.finra.org/rules-guidance/notices/information-notice-20251110
FINRA Information Notice 11/14/25 summarizes SEC amendments to SEA Rule 17a-5 mandating electronic filing of broker-dealer annual reports, supplemental reports, and Form 17-H on EDGAR in PDF format, alongside FOCUS Report updates including electronic signatures and elimination of notarization. These changes modernize submissions, eliminate paper filings to the SEC, and impose new interactive data requirements with phased compliance, requiring broker-dealers to secure EDGAR access and adapt processes promptly to avoid disruptions.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
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...
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...
Oath or Affirmation Updates: Notarization eliminated; signed version must be retained for at least 6 years (first 2 in easily accessible place) per SEA Rule...
Interactive Data Files: Annual/supplemental reports and Form 17-H must be submitted as Interactive Data Files under Regulation S-T Rule 405, with phased compliance based on net capital.
FINRA Submissions Unchanged: Annual reports to FINRA remain electronic via existing systems; FOCUS changes detailed on FINRA's eFOCUS...
Suggested Considerations
Obtain EDGAR access credentials via Form ID if not previously filed (submit early via SEC's "Apply for EDGAR Access" instructions); contact EDGAR Filer Technical Support at (202) 551-8900 Option #3 for help.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Transition annual/supplemental reports and Form 17-H to EDGAR PDF submissions effective fiscal years ending on/after June 30, 2025; follow SEC's Electronic Filing of Form X-17A-5 Part III instructions.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Implement electronic signature processes (e.g., Adobe digital certificates) for SEA Rule 17a-5 reports; limit FOCUS signatures to one principal officer.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance).
Key Dates
June 30, 2025
Electronic PDF filing on EDGAR mandatory for annual reports (fiscal years ending on/after this date), supplemental reports (SEA Rule 17a-5(k)), and Form 17-H; no paper accepted.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
December 31, 2025DEADLINE
Reference date for determining firm net capital threshold ($250,000+) for interactive data compliance phasing
June 30, 2027DEADLINE
Interactive Data File requirement applies to filings due on/after for firms with ≥ $250,000 minimum net capital (as of 12/31/2025)
June 30, 2029DEADLINE
Interactive Data File requirement applies to filings due on/after for firms with < $250,000 minimum net capital (as of 12/31/2025)
As early as possible preDEADLINE
due date; Submit Form ID for EDGAR access (5-7 business day approval delay).[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
Compliance Impact
Urgency: High – Immediate action needed for EDGAR access and PDF filings (past June 30, 2025 deadline as of January 2026), risking filing rejections or enforcement if unprepared; interactive data adds future burden but allows planning. Matters due to SEC's zero-tolerance for paper, potential delays in EDGAR approvals, and operational shifts in signing/retention, amplifying risks for non-compliant firms amid FINRA/SEC modernization push.[https://www.finra.org/rules-guidance/notices/information-notice-20251114]
FINRA Information Notice 11/17/25 reminds member firms of a modified exercise cut-off time for standardized equity options expiring on November 28, 2025, due to national options exchanges closing early at 1:00 p.m. ET on the Friday after Thanksgiving. This adjustment shifts the deadline for option holders' final exercise decisions from 5:30 p.m. ET to 2:30 p.m. ET under FINRA Rule 2360(b)(23)(A)(viii). It matters for compliance as firms must enforce this deadline to avoid regulatory violations, protect client positions, and manage operational risks during a holiday-shortened trading day.
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...
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 (Exercise-by-Exception) unless a Contrary Exercise Advice is submitted (to override auto-exercise or exercise...
Suggested Considerations
Update client communications: Notify option holders of the 2:30 p.m. ET deadline well in advance (e.g., via alerts, trade confirmations).
Configure systems and procedures: Ensure trading platforms reject post-2:30 p.m. ET instructions; test auto-exercise and Contrary Exercise Advice processes.
Train staff: Educate operations/trading personnel on Rule 2360(b)(23), OCC Rule 805, and holiday-specific cut-off; document training.
Monitor and record: Log all exercise instructions, auto-exercises, and any Advice Cancels; retain for surveillance.
Optional: Establish firm-internal earlier cut-offs (e.g., 2:00 p.m. ET) but enforce no later than 2:30 p.m. ET.
Key Dates
November 28, 2025, 1:00 p.m. ET
- Early close of national options exchanges
November 28, 2025, 2:30 p.m. ETDEADLINE
- Firm deadline to accept final exercise/not-exercise decisions (no later instructions permitted)
November 17, 2025
- Publication of FINRA Information Notice 11/17/25 reminding firms of upcoming modified cut-off
Compliance Impact
Urgency: low (post-event as of January 2026). This is a one-time reminder for a past holiday adjustment, with low risk of enforcement absent systemic failures. It matters operationally to prevent erroneous exercises, client disputes, or capital charges from uncollected exercise costs, but non-compliance could trigger FINRA surveillance reviews under Rule 2360. Firms should audit 2025 records now for lessons on future early-closes (e.g., Good Friday).
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
GC25/1 within Primary Market Bulletin No. 55 consults on targeted amendments to FCA Knowledge Base technical notes to align with UK Listing Rules (UKLR) changes effective 29 July 2024 and a new ESEF taxonomy for digital reporting. This matters for listed issuers and advisors as it updates formal guidance on periodic reporting, inside information handling, and position disclosures, ensuring compliance with post-reform listing regime requirements.
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,...
Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2 notifications, TN/305.3 on hostile takeovers, TN/307.2 on aggregating transactions for closed-ended funds) from prior...
Changes are non-substantive, focusing on updating references to UKLR (PS24/6), removing outdated content, and maintaining guidance status under UK Listing Rules, Prospectus Regulation Rules, and...
Suggested Considerations
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.g., enhanced notification under Listing Principle 2, ESEF taxonomy for DTR 4.1 reporting) once published by July 2025.
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.
Compliance Impact
Urgency: Medium – Past consultation deadline (15 May 2025) as of January 2026, but finalisation expected by July 2025 requires proactive policy reviews to avoid non-compliance with updated listing guidance. Matters for market integrity and operational alignment with UKLR reforms, with low immediate risk but potential enforcement exposure post-finalisation.
The FCA's guidance outlines good and poor practices in communicating costs for international money remittance and cross-border payments involving currency conversion, emphasizing transparency under the Consumer Duty to enable informed consumer decisions. It matters because non-compliance risks supervisory action, as the FCA plans future reviews to assess improvements, raising the bar on pricing clarity amid ongoing Duty enforcement.
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 intermediary/recipient bank fees where applicable.
Suggested Considerations
Review and update pre-transaction communications (e.g., websites) to prominently display all required pricing elements before commitment: GBP amount, exchange rate/markup, recipient amount, fees (fixed/variable/total), and intermediary warnings.
Ensure markups are framed as consumer costs, not obscured (e.g., avoid "zero cost" claims despite markups).
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
31 July 2023
- Consumer Duty effective date for new and existing products/services
1 May 2025
- FCA publication date of this good/poor practice guidance
Compliance Impact
Urgency: High – Consumer Duty is live since 2023, but this 2025 guidance signals intensified FCA scrutiny on payments transparency, with planned follow-up work and engagement to enforce improvements. Firms risk remediation demands or enforcement if disclosures remain inadequate, especially as it targets common weaknesses like hidden fees amid broader Duty portfolio reviews.
FCA PS25/19 finalizes rules to streamline complaints reporting by replacing multiple existing returns with a single consolidated return, enhancing data quality, consistency, and vulnerability identification while reducing burdens. This matters for compliance teams as it mandates system and process updates to improve regulatory oversight and consumer protection, with implementation required within 12 months.
Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
Simplified nil returns: Proportionate approach allows upfront selection for firms with no complaints.
Removal of group reporting: Shifts to individual legal entity-level reporting for greater transparency and oversight.
Updated complaints taxonomy: Revised categories reflect modern products/services, reducing use of 'Other' and improving categorization.
Suggested Considerations
Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points.
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.
Compliance Impact
Urgency: High – With publication on 3 Dec 2025 and a 12-month implementation window (to ~Dec 2026), firms must prioritize system changes now, as the first period starts 1 Jan 2027; non-compliance risks enforcement, especially on vulnerability reporting and transparency, amid FCA's focus on consumer protection data quality.
CP25/15 proposes prudential rules and guidance for UK firms issuing **qualifying stablecoins** and safeguarding **qualifying cryptoassets**, aiming to foster a safe, competitive crypto sector while prioritizing consumer protection and market integrity. This matters for compliance professionals as it introduces tailored prudential sourcebooks (COREPRU and CRYPTOPRU) to mitigate firm failure risks, aligning with the FCA's crypto roadmap and Treasury's statutory plans.
What Changed
- Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own...
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...
Risk Management and Outcomes: Targets prevention of firm failures, disorderly wind-downs, and consumer harm; measures success via reduced failure rates, market confidence, and prudential assessments.
Sector-Specific Rules: Calibrated for stablecoin issuance and cryptoasset safeguarding, with future consultations on broader applications (e.g., trading venues, staking).
Suggested Considerations
Respond to Consultation: Firms, advisers, and stakeholders must submit comments by 31/07/2025 using the online form, email, or post to influence final rules.
Assess Applicability: Crypto firms evaluate if they qualify as CRYPTOPRU firms; conduct gap analyses against proposed COREPRU/CRYPTOPRU rules on own funds, capital adequacy, and stress testing.
Prepare Prudential Frameworks: Develop internal capital adequacy processes reflecting stress events, valuation adjustments, and ongoing prudential assessments; review threshold conditions and business principles.
Engage on Related CPs: Monitor and respond to CP25/14 (stablecoin issuance/custody) and future CPs (e.g., CP2, Q3 2025 Conduct Standards).
Data and Reporting Readiness: Prepare to provide firm/market data for FCA evaluations on adherence and outcomes.
Key Dates
28/05/2025
- Consultation opens and CP first published
31/07/2025
- Consultation closes; submit feedback via online form, email ([email protected]), or post
Q3 2025
- Upcoming Conduct and Firm Standards CP affecting all cryptoasset firms, including QS issuers and custodians
Post
31/07/2025; - FCA considers feedback and publishes final rules (no specific date given)
Future (CP2 per Roadmap)
- Consultation on remaining prudential sourcebook requirements
Compliance Impact
Urgency: High – As of January 2026, the consultation closed over five months ago, signaling imminent final rules that could reshape prudential requirements for crypto firms; non-compliance risks authorization barriers, enforcement, or market exclusion in a regime prioritizing stability amid global crypto growth. This elevates risks for firm failures and consumer harm, demanding immediate gap assessments to align with proportionate standards supporting innovation.
The FCA's GC25/2: Primary Market Bulletin No. 57 (PMB 57), published 25 July 2025, consults on amendments to Technical Note 710.1 ('Sponsor Services: Principles for Sponsors') and a new Technical Note 638.1 on complex financial history and significant financial commitment rules for prospectuses. This matters as it updates the Knowledge Base to align with the new UK Listing Regime (UKLR) and Prospectus Rules, providing clarity for sponsors and issuers ahead of the PRM sourcebook effective January 2026, reducing compliance risks in primary markets.
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...
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...
Other updates: Finalises five technical notes from PMB 55 (e.g., TN 506.3 on periodic financial information, TN 521.4 on inside information); National Storage Mechanism changes effective 3 November...
Suggested Considerations
Review and respond: Analyse draft TN 710.1 and TN 638.1; submit feedback by 12/09/2025, focusing on sponsor obligations, complex history scenarios, and examples (e.g., AFME suggested clarifying 'significant acquisition' thresholds).
Update policies/processes: Sponsors to align with clarified UKLR 4 principles; issuers to incorporate TN 638.1 guidance into prospectus preparation, especially for acquisitive businesses.
Monitor finalisation: Track FG25/5 or subsequent PMBs for final notes; interpret existing Listing Rules in light of UKLR until all updates complete.
Implement NSM changes: By 03/11/2025 for relevant disclosures.
Compliance Impact
Urgency: Medium – Consultation closed 12/09/2025 (past deadline as of January 2026), but final notes (e.g., TN 710 by end-2025) and PRM effective 19/01/2026 require immediate policy reviews to avoid prospectus rejections or sponsor breaches. Matters for primary market competitiveness and investor protection under evolving UKLR/PRM, with no material CBA changes from CP23/31/CP24/12.
The FCA's updated Statement of Policy outlines its approach to statutory investigations into possible regulatory failures under Part 5 of the Financial Services Act 2012, including criteria for triggering investigations and producing reports for HM Treasury. It matters because it clarifies when the FCA must self-scrutinize serious lapses in regulation, helping firms anticipate rare but high-profile probes into systemic issues affecting consumer protection, market integrity, or competition. The primary update adjusts inflation-linked monetary thresholds for assessing "significant" consumer detriment, ensuring the policy remains relevant.
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...
No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in formal probes.
Clarified two-part statutory test: (1) Events indicating significant failure in consumer protection or adverse effects on integrity/competition objectives; (2) Events might not have occurred (or...
Suggested Considerations
Monitor for triggering events: Firms should self-assess operations against the two-part test, particularly potential consumer detriment exceeding £45m/£210m thresholds or impacts on FCA objectives.
Enhance internal reviews: Conduct "lessons learned" exercises post-incident to align with FCA's non-statutory approach, reducing escalation risk to formal probes.
No direct firm obligations: This is FCA policy on self-investigation; firms face no new reporting or compliance mandates but should prepare for FCA enquiries if events suggest regulatory system failures.
Document qualitative factors (e.g., vulnerability) in risk assessments to contextualize detriment.
Key Dates
14 November 2025
- Publication date of updated Statement of Policy
Compliance Impact
Urgency: Medium. This update signals FCA's commitment to accountability without imposing new firm-level rules, but it heightens focus on significant failures (£45m+ detriment), potentially leading to public reports exposing industry-wide gaps. Firms with high consumer exposure (e.g., retail-facing) should prioritize as probes, though rare, amplify reputational and remedial risks via Treasury publication.
The FCA's CP25/31 proposes a regulatory framework for introducing a UK equity Consolidated Tape (CT), operated by a Consolidated Tape Provider (CTP), to collate and distribute comprehensive post-trade data (prices and volumes) across trading venues and OTC trades in equities, including shares, ETFs, depository receipts, and similar instruments. This matters for compliance as it imposes new data contribution obligations on trading venues and APAs, aims to enhance market transparency and competitiveness under the FCA's 2025-2030 Strategy, and builds on FSMA 2023 powers for Data Reporting Services Providers (DRSPs). Firms must engage now to shape rules via consultation, with potential operations targeted for 2027.
What Changed
- CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing...
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...
Scope and Outcomes: CT focuses on post-trade data initially (with trade-offs on pre-trade inclusion); seeks to increase UK equity data usage, improve liquidity visibility, support innovation, and...
Authorisation and Procurement: Streamlined process for CTP authorisation; FCA to run procurement for operator selection, balancing speed with robustness.
Evidence-Based Design: Addresses complexities like number of CTPs, revenue sharing, resiliency standards; follows prior feedback from CP23/15 and Europe Economics report.
Suggested Considerations
Respond to Consultation: Submit feedback by 13/02/2026 via FCA online form, email (equityct@fca.org.uk), post, or phone (020 7066 9758); focus on design trade-offs like pre-trade data, CTP numbers, revenue sharing, resiliency.
Data Readiness: Trading venues/APAs assess internal systems for mandatory data provision to CTP (e.g., trade prices/volumes); prepare for authorisation/procurement processes if pursuing CTP status.
Monitor Updates: Review full CP PDF (https://www.fca.org.uk/publication/consultation/cp25/31.pdf), January 2026 CBA methodology note, and linked docs like CP23/15, Europe Economics report, CP25/20.
Engage Stakeholders: Potential CTPs express interest via FCA opportunities; data users provide input on accessibility/pricing.
Compliance Mapping: Map proposals to existing DRSP/venue rules under FSMA 2023 and repealed DRSRs.
Compliance Impact
Urgency: High – While still in consultation (closes 13/02/2026), proposals mandate data contributions from trading venues/APAs and CTP setup, with 2027 operations targeted; non-engagement risks misaligned systems or missed CTP opportunities. Matters due to FSMA 2023 empowerment, links to equity transparency reforms (CP25/20), and strategic push for UK market competitiveness – firms face new reporting/resiliency burdens but gain liquidity/transparency benefits.
The FCA's PS25/22 establishes a new regulatory framework for **targeted support**—a form of financial guidance that allows authorised firms to provide ready-made suggestions to consumer segments without conducting individualised suitability assessments. This framework addresses the UK's "advice gap" by enabling firms to deliver affordable, scalable financial support to an estimated 18 million consumers within a decade, fundamentally shifting how retail investors and pension savers access guidance on investment and retirement decisions.
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 policy intent and avoid confusion with the Consumer Duty requirement for "good outcomes." This...
Suggested Considerations
*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
29/08/2025
- Consultation period closed (CP25/17 and CP25/26)
11/12/2025
- Policy Statement PS25/22 published with near-final rules
March 2026
- Firms may begin applying for targeted support permission
06/04/2026
- New rules expected to come into force (subject to Government legislation making targeted support a specified activity)
The FCA's PS25/23 finalizes guidance on tackling **non-financial misconduct (NFM)** in financial services, amending the COCON sourcebook to clarify how serious NFM breaches conduct rules and integrating it into FIT assessments for fitness and propriety. This matters because it aligns rules across banks and non-banks, enhances accountability, deters harmful workplace cultures, and supports FCA objectives like consumer protection and market integrity by ensuring consistent handling of issues like bullying or harassment.
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,...
FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating implausible claims or breaching privacy; removes...
Managerial accountability: Relative to knowledge/authority under ICR2; no expansion into purely private life.
Minor tweaks from CP25/18 feedback: New diagrams, employment law alignment, withdrawn burdensome factors.
Suggested Considerations
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.g., non-bank alignment); document decision-making to demonstrate fairness/decisiveness.
Firms not to investigate trivial/improbable allegations or overstep privacy laws.
Key Dates
1 September 2026
- New COCON rules and guidance come into force (non-retrospective)
Compliance Impact
Urgency: High – With rules effective 1 September 2026 (9+ months from today), firms have preparation time, but PS25/23 closes FCA's NFM policy work, shifting to supervision/enforcement focus; non-compliance risks enforcement, FIT failures, and reputational damage amid trust-building priorities in FCA Strategy 2025-2030.
The FCA and PRA are consulting on setting the Financial Services Compensation Scheme (FSCS) Management Expenses Levy Limit (MELL) at £113 million for 2026/27, comprising a £108 million management expenses budget (up £4.4 million from 2025/26, broadly in line with inflation) and a £5 million unlevied reserve. This matters because it caps the operating costs (e.g., IT, staff, legal, claims handling) that FCA- and PRA-authorised firms must fund via levies, excluding separate compensation payments, ensuring FSCS efficiency while controlling firm burdens.
What Changed
- Proposed MELL of £113 million for 2026/27: £108 million budget + £5 million unlevied reserve.
Budget increase of £4.4 million (4%) from 2025/26, aligned with inflation; excluding new revolving credit facility (RCF) enhancement costs, it reflects a £6.6 million nominal and £11 million...
Budget allocated across PRA and FCA fee blocks based on firms' regulated business volume, with smaller firms contributing less.
No changes to compensation levies, which remain separate and forecast at £342 million total levy including compensation.
Suggested Considerations
Review CP26/2 (FCA) and CP1/26 (PRA) alongside FSCS January 2026 Budget Update for allocation details.
Submit feedback on proposed MELL by 10 February 2026 to PRA (email or 20 Moorgate, London EC2R 6DA).
Budget for potential levy payments starting 1 April 2026, based on firm's share of PRA/FCA classes (see Appendix 4 in CP).
Monitor post-consultation Policy Statement/Handbook Notice for final MELL confirmation.
Key Dates
13 January 2026
- Consultation opens (CP26/2 FCA; CP1/26 PRA)
10 February 2026
- Consultation closes; submit comments via email or post to PRA (accepted on behalf of both regulators, shared anonymously with FSCS)
1 April 2026
- Final rules effective (start of FSCS financial year); PRA Policy Statement and FCA Handbook Notice expected post-consultation
31 March 2027
- MELL period ends
Compliance Impact
Urgency: Medium - Firms face predictable levy increases aligned with inflation, with levies allocated by business volume (minimal for small firms), but must act on consultation feedback by 10 February 2026 (today is 25 January 2026, leaving ~2 weeks). Matters for financial planning and budgeting, as MELL ensures FSCS operational funding without covering volatile compensation costs; failure to engage risks unaddressed cost concerns in final rules.
ASIC successfully defends special leave application to the High Court by Cigno Australia director Mark Swanepoel and BSF Solutions director Brenton Harrison
ASIC takes action against MWL Financial Services, former director Nicholas Maikousis, and Imperial Capital Group Australia over alleged Shield advice failures
On 6 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 2.500 euros on BayWa Aktiengesellschaft.
AI Analysis
The Federal Office of Justice (BfJ) imposed a €2,500 disciplinary fine on BayWa Aktiengesellschaft on 6 November 2025 for failing to submit its 2024 financial year accounting documents electronically to the Bundesanzeiger within the required period, breaching section 325 HGB. This enforcement action underscores BaFin's oversight of basic disclosure obligations under the German Commercial Code, serving as a reminder that even minor procedural lapses can trigger sanctions amid heightened scrutiny of listed companies' reporting. Compliance teams should note this as indicative of rigorous enforcement on timely electronic filings, particularly for firms under financial stress like BayWa.
What Changed
This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB):
Section 325 HGB: Mandates submission of accounting documents (e.g., annual financial statements, management reports) for public disclosure via the Bundesanzeiger operator in electronic form within...
Section 335 HGB: Provides the legal basis for disciplinary fines by the BfJ for non-compliance, with fines scaled to the breach's severity (here, €2,500 for delayed submission).
No new rules were...
Suggested Considerations
Verify internal processes for electronic submission of accounting documents to Bundesanzeiger within HGB timelines (e.g., annual statements by end of March for December year-ends).
Implement automated reminders and dual-checks in finance/reporting workflows to prevent delays, especially during restructurings or audits.
Review and update compliance calendars for all HGB-disclosure obligations; conduct training for finance teams on section 325/335 HGB.
Monitor Bundesanzeiger portal for submission confirmations and retain proofs of timely filing to defend against BfJ inquiries.
Key Dates
31 December 2024DEADLINE
End of BayWa AG's financial year; accounting documents due for submission shortly after (typically by 31 March 2025 for three-month deadline under section 325 HGB)
6 November 2025
BfJ issues disciplinary fine order for late submission
23 January 2026
BaFin publishes the enforcement notice
Compliance Impact
Urgency: low – This is a minor fine (€2,500) for a procedural breach with no appeal, signaling routine enforcement rather than a policy shift. It matters as a low-cost warning for all HGB-reporting firms to automate filings, avoiding escalation in repeat cases or amid BaFin's focus on disclosure (e.g., WpHG overlaps); high-profile firms like BayWa under restructuring face amplified scrutiny, but no immediate action required beyond process audits.
The Federal Office of Justice in Germany imposed a disciplinary fine of 2,500 euros on BayWa Aktiengesellschaft for failing to submit its accounting documents for the financial year 2024 in electronic form within the prescribed period. This action highlights the importance of compliance with section 325 of the German Commercial Code. Companies must ensure timely submission of financial reports to avoid similar penalties.
What Changed
The Federal Office of Justice enforced section 325 of the German Commercial Code, which requires companies to submit their accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.
Suggested Considerations
Ensure timely submission of accounting documents in electronic form to the German Federal Gazette
Review internal procedures to guarantee compliance with section 325 of the German Commercial Code
Key Dates
6 Nov 2025
The Federal Office of Justice imposed a disciplinary fine on BayWa Aktiengesellschaft
Potential Consequences
Disciplinary fines, such as the 2,500 euros imposed on BayWa Aktiengesellschaft, for non-compliance with section 325 of the German Commercial Code
On 6 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 2.500 euros on BayWa Aktiengesellschaft.
AI Analysis
The Federal Office of Justice (BfJ) imposed a €2,500 disciplinary fine on BayWa Aktiengesellschaft on 6 November 2025 for failing to submit its 2024 consolidated accounting documents electronically to the Bundesanzeiger within the required period, violating section 325 HGB. This enforcement action underscores BaFin's oversight of financial reporting obligations under German law and serves as a reminder of strict deadlines for public disclosure, even amid corporate challenges like BayWa's ongoing restructuring. Compliance teams should note it as a low-value but procedurally significant sanction, highlighting risks of administrative penalties for late filings.
What Changed
This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB):
Section 325 HGB: Mandates submission of consolidated accounting documents (e.g., annual financial statements, management reports) for disclosure in electronic form to the Bundesanzeiger operator...
Section 335 HGB: Provides the legal basis for disciplinary fines (Ordnungsgeld) up to €25,000 for breaches, with no appeal lodged by BayWa in this...
Suggested Considerations
Verify filing processes: AGs must ensure automated calendar alerts and electronic submission workflows to Bundesanzeiger (via Unternehmensregister or direct portal) before HGB deadlines.
Conduct gap analysis: Review past filings for similar breaches; implement dual controls (e.g., finance + legal sign-off) and escalation protocols for delays.
Train staff: Annual refreshers on § 325/335 HGB, emphasizing no extensions for restructuring (BayWa example).
Monitor Bundesanzeiger confirmations: Retain submission receipts as audit evidence.
No appeal if fined: As BayWa did not appeal, firms should assess fine proportionality pre-litigation.
Key Dates
31 March 2025DEADLINE
- Presumed deadline for BayWa to submit 2024 consolidated documents (three months post-31 December FY-end under § 325 HGB para. 1)
6 November 2025
- Date BfJ imposed the €2,500 fine
23 January 2026
- BaFin publication date of the enforcement notice[https://www.bafin.de/SharedDocs/Veroeffentlichungen/EN/Massnahmen/40c_neu_124_WpHG/neu/meldung_2026_01_23_baywa_ag_1_en.html]
Compliance Impact
Urgency: low - Fine is minimal (€2,500), procedural (no market manipulation or fraud), and isolated to one late filing amid BayWa's broader crises (e.g., forecast withdrawal 6 Oct 2025[https://www.investegate.co.uk/announcement/eqs/baywa-ag-baywa-ord-shs--0ah7/eqs-adhoc-baywa-ag-baywa-ag-withdraws-forec-/9153358], H1 2025 net loss €527.8m[https://www.baywa.com/binaries/pdf/content/documents/baywacms-en/downloadcenter/interim-report/half-year-report-2025/half-year-report-2025/baywacms:downloadpdf/BayWa+Group+Half-Year+Financial+Statements+2025_web.pdf]).
The Federal Office of Justice in Germany imposed a disciplinary fine on BayWa Aktiengesellschaft for failing to submit its consolidated accounting documents for the financial year 2024 within the prescribed period. This action highlights the importance of timely submission of financial reports. Companies must ensure compliance with section 325 of the German Commercial Code to avoid similar penalties.
What Changed
The Federal Office of Justice imposed a disciplinary fine due to a breach of section 325 of the German Commercial Code, which requires companies to submit their consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.
Suggested Considerations
Ensure timely submission of consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form
Review and update internal procedures to comply with section 325 of the German Commercial Code
Key Dates
6 Nov 2025
The Federal Office of Justice imposed a disciplinary fine on BayWa Aktiengesellschaft
Potential Consequences
Disciplinary fine of up to 2,500 euros for non-compliance with section 325 of the German Commercial Code
We urge consumers thinking of investing in high-risk securities, such as mini-bonds and loan notes, to continue to be cautious. On 19 January 2026, the Public Offers and Admissions to Trading regime came into force. The regime sets new rules and standards about when an offer of securities to the public can be made.A security is a financial instrument that represents some type of financial value (for example, shares, bonds and stock) that can be traded on a financial exchange.The types of secu...
We are seeking views on further rules for cryptoasset firms as the final step in our consultations on our crypto rules. We have made significant progress in delivering our crypto roadmap and are helping firms to meet our standards and get ready for when the gateway opens in September 2026.We have set out our proposals on how the Consumer Duty, conduct standards, redress and safeguarding will apply to cryptoasset firms. We are also seeking feedback on our proposed approach to international cry...
Securities and Exchange Commission Chairman Paul S. Atkins and Commodity Futures Trading Commission Chairman Michael S. Selig will hold a joint event on Tuesday, Jan. 27, from 10 a.m. to 11 a.m. at CFTC headquarters to discuss harmonization between the…
The Securities and Exchange Commission’s Small Business Capital Formation Advisory Committee announced that it will hold a public meeting at the SEC Headquarters in Washington, D.C., on Tuesday, Feb. 24, 2026, at 10 a.m. ET. The meeting will also be…
The Securities and Exchange Commission today approved the 2026 budget for the Public Company Accounting Oversight Board (PCAOB) and the related accounting support fee.The 2026 PCAOB budget totals $362.1 million. The 2026 budget reflects a 9.4% ($37.6…
Speech by Sheree Howard at the FCA's Gateway to growth, Chicago Booth London Conference Centre. The first time I flew was in my teenage years, and like many of my generation, that was a flight to Europe for a family holiday. I didn’t make it further afield until I was in my mid to late twenties.Today, most, if not all of us, would think of international travel as the norm – especially given the global nature of our business.It is amazing, therefore, to think that right around this time in 197...
The Securities and Exchange Commission is seeking candidates for appointment as members of the SEC’s Investor Advisory Committee, established pursuant to Section 39 of the Securities Exchange Act of 1934 to help protect investors and improve securities…
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered in WhatsApp groups operated by Leading Asset Management, Denver, USA. BaFin suspects the operators of offering consumers financial, investment and cryptoasset services in these groups without the required authorisation.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website skyvault(.)ltd. BaFin has information that the operators are offering banking business and/or financial services on this website without the required authorisation. The operators are not supervised by BaFin.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered by Aureus Trade. BaFin suspects the unknown operators of the website aureus-trade(.)com of offering consumers financial, investment and cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website bxforex(.)com. According to information available to BaFin, this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the company Rostock24 Limited and the services it is offering. BaFin suspects the unknown operators of the website rostock24(.)com of offering consumers financial, investment and cryptoasset services without the required authorisation. Rostock24 Limited, which purportedly has its head office in Nuremberg, claims to be registered with the British Companies House. This is not the case.
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address info[at]vcgmanagement.de. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from VC Germany Management GmbH. This is a case of identity theft.
Financial disclosures & corporate financing Periodic & ongoing disclosures Reporting ESEF Closing of the 2025 accounts: the AMF flags up points for vigilance and issues recommendations
The Hong Kong Securities and Futures Commission (SFC) successfully prosecuted retail trader Ng Ka Hei for seven counts of false trading involving six Main Board-listed companies, resulting in conviction on January 22, 2026. This enforcement action demonstrates the SFC's active surveillance and prosecution of market manipulation tactics, specifically "scaffolding" and wash trading strategies that artificially inflate share prices and mislead market participants.
What Changed
This is not a regulatory change but rather an enforcement precedent establishing that:
"Scaffolding" strategy is prosecutable: Repeatedly placing and cancelling trading orders at progressively higher prices constitutes false trading under section 295 of the Securities and Futures...
Wash trading across multiple accounts is actionable: Using various securities accounts to simultaneously act as both buyer and seller of shares violates false trading prohibitions.
Price impact + market deception = criminal liability: The SFC successfully prosecuted based on demonstrating that trading activities artificially impacted share prices and misled market participants...
Suggested Considerations
*For brokers and licensed intermediaries:
*Enhance surveillance systems to detect scaffolding patterns (repeated placement and cancellation of orders at progressively higher prices)
*Monitor cross-account trading to identify wash trading where the same beneficial owner trades with themselves across multiple accounts
*Implement controls to flag suspicious trading activity that artificially impacts share prices without genuine economic purpose
*Document compliance procedures for detecting and reporting false trading under section 295 of the Securities and Futures Ordinance
The Securities and Futures Commission (SFC) has convicted a retail trader for false trading in the shares of six Hong Kong-listed companies, highlighting the importance of market integrity and the need for firms to monitor and prevent such activities. The conviction demonstrates the SFC's commitment to enforcing securities laws and protecting market participants. Firms should review their trading practices and ensure they have adequate controls in place to prevent false trading.
What Changed
The SFC has successfully prosecuted a case of false trading under section 295 of the Securities and Futures Ordinance, which constitutes an offence.
Suggested Considerations
Implement or review existing controls to detect and prevent false trading, including monitoring for suspicious trading patterns such as 'scaffolding' and wash trades
Provide training to trading staff on the risks and consequences of false trading
Key Dates
12 Feb 2026
Sentencing of Mr Ng Ka Hei
Potential Consequences
Enforcement action, fines, and reputational damage may result from non-compliance with securities laws and regulations related to false trading.
The Securities and Exchange Commission is seeking candidates to fill a limited number of vacancies on the agency’s Small Business Capital Formation Advisory Committee, which provides advice and recommendations to the Commission on rules, regulations, and…
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website bb-consults(.)com. BaFin has information that this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
The Securities and Exchange Commission today announced the senior team from the Division of Corporation Finance responsible for advising division Director James Moloney on all matters the division has before the Commission. These include rulemaking…
The Securities and Exchange Commission today announced that Christina M. Thomas will rejoin the Division of Corporation Finance in February as deputy director and chief advisor on disclosure, policy, and rulemaking.“Christina brings her deep technical…
The Securities and Exchange Commission today announced that Keith E. Cassidy has been appointed Director of the Division of Examinations. Mr. Cassidy has served as Acting Director since May 2024 and previously was the division’s Deputy Director, Acting…
We have issued a joint statement with the Payment Systems Regulator (PSR) giving clarity on open banking pricing models. We and the PSR have issued the following statement (PDF).This confirms we will not, at this stage, prioritise a Competition Act 1998 (CA98) investigation into the centralised ‘access fee’ pricing model being developed by the UK Payments Initiative (UKPI) for commercial Variable Recurring Payments (cVRPs). cVRPs are an emerging open banking technology that allow consumers to...
AI Analysis
The FCA and PSR have jointly confirmed they will not prioritize a Competition Act 1998 investigation into the UK Payments Initiative's (UKPI) centralized access fee pricing model for commercial Variable Recurring Payments (cVRPs), with the CMA's concurrent agreement. This regulatory clarity provides temporary certainty for cVRP development ahead of anticipated legislation by end-2026, creating a critical window for firms to develop compliant commercial models in this emerging open banking technology.
What Changed
The regulatory statement establishes the following key positions:
Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase...
Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services, utilities,...
Temporary framework: This is explicitly a temporary measure pending legislative implementation under the Data (Use and Access) Act 2025 or other relevant legislation.
Regulatory monitoring obligations: During the interim period, the FCA and PSR will monitor market developments, review pricing methodology changes, and require UKPI to submit finalized governance...
Suggested Considerations
*For UKPI and participating firms:
*Governance documentation: Submit finalized governance documents to FCA/PSR as required during the interim period
*Pricing methodology transparency: Maintain detailed records of access fee pricing methodology and be prepared to demonstrate compliance with the agreed model; notify regulators of any material changes
*Phase 1/Wave 1 compliance: Ensure all cVRP offerings remain within the defined scope of lower-risk use cases during Phase 1/Wave 1
*Market engagement: Participate in FCA industry consultations throughout 2026 regarding progress, service delivery, and identified blockers
Key Dates
Q1 2026
- Expected first live UKPI cVRP payments
End of 2026
- Government anticipated to introduce legislative framework granting FCA new open banking powers
15 January 2026
- FCA and PSR wrote to CMA setting out their non-prioritization position
16 January 2026
- CMA confirmed alignment with FCA/PSR position on CA98 prioritization
20 January 2026
- Joint FCA/PSR statement issued on open banking pricing models
The FCA and PSR have issued a joint statement providing clarity on open banking pricing models, specifically regarding the centralised 'access fee' pricing model for commercial Variable Recurring Payments (cVRPs). This statement confirms that they will not prioritize a Competition Act 1998 investigation into this model at this stage. The goal is to support the development of cVRPs, giving consumers more control over their payments and lowering processing fees for businesses.
What Changed
The FCA and PSR have clarified their enforcement position on the UKPI's proposal for a commercial model for cVRPs, indicating they will not prioritize a Competition Act 1998 investigation at this stage.
Suggested Considerations
Monitor market developments and updates on the legislative framework for open banking
Review and understand the implications of the centralised 'access fee' pricing model for cVRPs on your business operations
Ensure compliance with existing competition laws and regulations
Key Dates
31 Dec 2026DEADLINE
Expected implementation of the government's legislative framework for open banking
1 Jul 2027DEADLINE
End of the temporary measure if the legislative framework is not implemented
Potential Consequences
Enforcement action, fines, or other regulatory penalties for non-compliance with competition laws and regulations
CSSF Circular 26/906, published on 20 January 2026, establishes detailed requirements for central administration, internal governance, and risk management for payment institutions (PIs) and electronic money institutions (EMIs) in Luxembourg, repealing prior circulars IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155. It clarifies application of the amended Law of 10 November 2009 on payment services, emphasizing robust governance amid sector growth to ensure safety, efficiency, and trust. This matters for compliance as it mandates comprehensive reviews and updates to governance frameworks by mid-2026, addressing rising transaction volumes.
What Changed
The circular consolidates and updates governance rules, focusing on:
Management bodies: Responsibilities, composition, qualifications, organization, and functioning, including CSSF authorization of members based on professional experience, standing (e.g., police...
Internal control functions: Responsibilities, characteristics, organization, and execution of work for compliance officers and internal auditors, with notifications to CSSF including detailed...
Conflicts of interest: Key requirements for a management policy applicable to all staff and management body members.
New product approval: Defined key steps in the process.
Suggested Considerations
Gap analysis: Assess current frameworks against circular requirements on management bodies, internal controls, conflicts of interest, product approval, and fund safeguarding.
Updates and notifications: Review/revise governance arrangements (e.g., policies, structures); notify CSSF of management body members, compliance officers, and internal auditors with required documentation (professional experience, police records, etc.).
Documentation: Develop conflicts policy, new product approval procedures, and safeguarding rules; ensure management body authorization.
Ongoing: Maintain sound/prudent management amid growth; integrate with Law of 10 November 2009 requirements.
Key Dates
20 January 2026
- Publication date of Circular CSSF 26/906
30 June 2026DEADLINE
- Compliance deadline: Institutions must assess/review central administration, internal governance, and risk management frameworks to ensure full compliance
Compliance Impact
Urgency: High - With ~5 months from publication (20 Jan 2026) to compliance (30 Jun 2026), firms face tight timelines for assessments, policy overhauls, and CSSF notifications, especially given repealed circulars and sector growth pressures. Non-compliance risks supervisory actions, as this fosters "sound and prudent management" in a high-volume industry; proactive reviews are essential to avoid disruptions.
Central administration, internal governance and risk management
AI Analysis
Circular CSSF 26/906, published on 20 January 2026, consolidates and clarifies Luxembourg's rules on central administration, internal governance, and risk management specifically for payment institutions, electronic money institutions, and account information service providers. It repeals prior circulars (IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155) to address growth in transaction volumes by mandating robust governance, control functions, and risk processes, enhancing safety, efficiency, and trust in these services. This matters for compliance professionals as it strengthens defenses against financial crime, operational risks, and supervisory scrutiny in a high-growth sector.
What Changed
- Consolidation and repeal: Replaces outdated circulars with unified requirements under the amended Law of 10 November 2009 on payment services, covering central administration (decision-making must...
Governance enhancements: Board approves strategy, risk appetite, AML/CFT policies, outsourcing, and information security; management implements via procedures; proportionality based on business...
Operational controls: Strict access to systems (need-to-know, least-privilege, 4-eyes validation); counterparty due diligence for custodians/insurers; full responsibility for agents, distributors,...
AML/CFT focus: Elevates compliance function independence, direct board reporting, risk-based resourcing, and oversight of third parties/opaque structures to close gaps exploited by criminals.
Suggested Considerations
Assess and update governance frameworks: Review central administration location, board/management responsibilities, risk strategy, AML/CFT policies, compliance charter, and funds safeguarding principles to align with the circular.
Confirm control functions: Ensure compliance function (CCO) has independence, resources, direct board access, and authority for investigations; justify/secure CSSF approval for part-time/dual roles.
Implement operational safeguards: Establish daily reconciliations (or justified weekly), segregation/insurance for client funds, system access controls (4-eyes, board validation for significant movements), and third-party due diligence/monitoring.
Document proportionality: Tailor governance to business risks (staff, volumes, products, outsourcing); update new product approval, conflicts policies, and business continuity/incident reporting.
Retain records and report: Board-approve all key policies; prepare for CSSF inspections on outsourcing (per Circular CSSF 22/806) and ICT risks.
Key Dates
20 January 2026
Publication date of Circular CSSF 26/906
30 June 2026DEADLINE
Compliance deadline; Institutions must assess, review, and ensure their central administration, internal governance, and risk management frameworks fully comply with the circular
Compliance Impact
Urgency: High – With a 30 June 2026 deadline (five months from publication), firms face immediate pressure to review and remediate governance gaps amid sector growth and heightened AML/CFT scrutiny; non-compliance risks supervisory actions, fines, or license issues, especially as it closes criminal exploitation vectors like weak controls and third-party risks.
Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01)
AI Analysis
Circular CSSF 26/905 mandates the application of EBA Guidelines (EBA/GL/2025/01) on managing **ESG risks** for Luxembourg-supervised institutions, requiring integration of environmental, social, and governance risk identification, measurement, management, and monitoring into internal processes. This aligns with CRD amendments (Articles 74, 76, 87a) and emphasizes proportionality to institutions' business models, with plans including timelines, targets, and milestones toward EU climate goals like net-zero by 2050. It matters for compliance as it embeds ESG into prudential supervision, potentially impacting capital, risk frameworks, and supervisory reviews.
What Changed
- Institutions must establish proportionate strategies, policies, processes, and systems for ESG risk management, covering short-, medium-, and long-term horizons, including transition and physical...
Develop plans per Article 76(2) CRD with specific timelines, intermediate quantifiable targets, and milestones to address ESG financial risks, consistent with EU objectives (e.g., 55% GHG reduction...
Incorporate ESG into internal governance, risk appetite, and supervisory review processes (SREP), with scenario analysis requirements (to be detailed in future EBA guidelines).
Applies minimum standards and methodologies for ESG risk identification, measurement, monitoring, and impact assessment on institutions' exposures.
No requirement for full alignment with specific sustainability trajectories, but plans must consider transition risks and institutions' ESG product offerings, loan policies, and targets.
Suggested Considerations
Map and integrate ESG risks into governance, risk management frameworks, and business strategies, proportionate to scale/risk exposure.
Develop and document ESG risk management plans with quantifiable targets, milestones, timelines, and scenario analyses (broad requirements now; detailed later).
Conduct assessments of ESG risks in portfolios, including sustainability products, transition finance, and loan origination policies, for SREP submission.
Embed in internal processes per Articles 74, 76, 87a CRD: identify/measure ESG risks (minimum standards), monitor over time horizons, and report to CSSF.
Review and update existing policies/systems for compliance by applicable dates; prepare for CSSF supervisory evaluation of plan robustness.
Key Dates
20 January 2026
- Circular published by CSSF
1 April 2026
- Application date for Less Significant Institutions (other than SNCIs)
11 January 2027
- Application date for SNCIs (dependent on CRD transposition)
Compliance Impact
Urgency: High - With application starting 1 April 2026 (just over 2 months from publication), firms face immediate pressure to gap-analyze current ESG frameworks against EBA standards, especially for SREP integration and long-term risk planning. Non-compliance risks supervisory scrutiny, capital add-ons, or enforcement, as ESG is now a core prudential pillar amid EU sustainability push; smaller institutions get a head-start but must act swiftly given proportionality demands.
Supervision Compliance Journalists Investment services providers The AMF publishes the findings of its inspections on the role and involvement of the compliance function at investment services providers
PS1/26 represents the UK Prudential Regulation Authority's final implementation framework for the Basel 3.1 international banking standards, effective 1 January 2027 (with market risk internal models delayed to 1 January 2028). This policy statement establishes mandatory capital, credit risk, operational risk, and market risk requirements for UK-regulated banks, building societies, and investment firms, addressing post-financial crisis shortcomings in risk-weighted asset (RWA) calculations and capital adequacy frameworks.
What Changed
Credit Risk Framework
Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures)...
Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques.
Operational Risk
Updated Business Indicator Component (BIC) calculation methodology requiring inclusion of the current financial year in the three-year average calculation (or an estimate if unavailable).
Clarifications on legal risk treatment and loss data set dates.
Market Risk (Fundamental Review of the Trading Book – FRTB)
Suggested Considerations
*Immediate (by mid-2026)
*Conduct impact assessment: Quantify RWA changes under Basel 3.1 across credit risk, operational risk, and market risk frameworks.
*Review IRB permissions: Identify exposures requiring reclassification (e.g., IPRE to HVCRE) and prepare permission amendment applications.
*Assess FRTB-IMA readiness: For firms with existing IMA permissions, evaluate transition strategy for out-of-scope positions moving to ASA/SSA during interim period (2027–2027).
*Arrange board-level assurance: Establish governance framework for board oversight of RWA calculation accuracy and Basel 3.1 implementation.
Key Dates
20 January 2026
– PRA publishes PS1/26 (final rules)
2026 ICAAP submission deadlineDEADLINE
– Must include Basel 3.1/SDDT impact assessment
1 January 2027
– Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)
1 January 2027
– Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA
The Prudential Regulation Authority (PRA) has published the final rules for the implementation of Basel 3.1 standards in the UK, with an effective date of January 1, 2027. The rules aim to enhance the resilience of banks and improve the stability of the financial system. Firms must review and update their policies and procedures to ensure compliance with the new requirements.
What Changed
The PRA has introduced new rules for the calculation of risk-weighted assets, including changes to the credit risk standardised approach, market risk framework, and operational risk requirements. The rules also include amendments to the definitions of probability of default, loss given default, and conversion factor.
Suggested Considerations
Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
Assess the impact of the new market risk framework on trading book positions and capital requirements
Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents
Key Dates
1 Jan 2027DEADLINE
Basel 3.1 rules take effect
1 Jan 2028DEADLINE
Internal model approach for market risk takes effect
Potential Consequences
Non-compliance with the new rules may result in enforcement action, fines, or other regulatory penalties
The PRA's PS2/26 finalizes the retirement of the "refined methodology" in Pillar 2A capital requirements, effective 1 January 2027, aligning with Basel 3.1 implementation to simplify the framework by eliminating an operationally burdensome adjustment originally designed to address conservatism in the standardized approach (SA) to credit risk. This matters for compliance professionals as it reduces complexity in ICAAP and SREP processes, with expected neutral aggregate capital impact, though firm-specific effects may vary and require supervisory engagement.
What Changed
- Retirement of refined methodology: The refined methodology, introduced in 2018 (PS22/17) to mitigate perceived conservatism in CR SA relative to IRB for lower-risk assets, is fully retired from...
Amendments to SS31/15: Updates to Supervisory Statement 31/15 on ICAAP and SREP (Appendix 1), including minor prior adjustment to paragraph 5.12A for SDDTs reflecting no need for Interim Capital...
No further changes from near-final: Confirms PS18/25 near-final policy without alterations; defers certain IRRBB clarifications pending separate review.
Rationale: Reduces operational burden on firms and PRA; PRA analysis shows broadly neutral impact on total capital requirements (TCR), with ~50% of affected firms seeing reductions.
Suggested Considerations
Review and update ICAAP/SREP processes: Firms must integrate retirement into internal capital adequacy assessments, removing refined methodology calculations from Pillar 2A by 1 January 2027.
Recalculate Pillar 2A requirements: Model impacts using Basel 3.1 CR SA; engage PRA supervisors for firm-specific transitions if capital increases anticipated (PRA will apply judgement).
Align with related frameworks: Implement alongside Basel 3.1 (PS1/26), CRR restatement (PS3/26), and SDDT regime (PS4/26); update systems, policies, and disclosures accordingly.
Monitor firm-specific impacts: Conduct quantitative analysis per PRA's refreshed data; half of firms may see TCR reductions, but prepare for potential increases.
Governance and reporting: Board/Senior Managers to oversee transition; ensure 2027 SREP readiness without refined methodology proxy.
Key Dates
2024
CP9/24 consultation on streamlining Pillar 2A, including proposal to retire refined methodology
28 October 2025
PS18/25 near-final policy published
20 January 2026
PS2/26 final policy published
1 January 2027
Effective date for retirement of refined methodology; aligns with Basel 3.1 implementation (PS1/26), CRR restatement (PS3/26), and SDDT simplified regime (PS4/26)
Compliance Impact
Urgency: High – With less than 11 months to 1 January 2027 effective date (as of January 2026 publication), firms face immediate need to remodel Pillar 2A under Basel 3.1, potentially affecting capital planning, stress testing, and regulatory reporting. Non-compliance risks supervisory scrutiny during SREP; benefits include workload simplification, but SA-only firms must validate no undue conservatism gaps versus IRB peers.
The Prudential Regulation Authority (PRA) has finalized the policy to retire the refined methodology to Pillar 2A, which will take effect on January 1, 2027, aligning with the implementation of the Basel 3.1 standards. This change affects all PRA-regulated banks, building societies, and designated investment firms. The refined methodology will no longer apply to these firms, including Small Domestic Deposit Takers (SDDTs), as they will be subject to the Basel 3.1 standardized approach to credit risk.
What Changed
The PRA has retired the refined methodology to Pillar 2A, which was previously used to determine capital requirements for firms. The new policy aligns with the Basel 3.1 standards and introduces a simplified capital regime for SDDTs.
Suggested Considerations
Update internal capital adequacy assessment processes (ICAAP) to reflect the changes to Pillar 2A
Review and implement the Basel 3.1 standardized approach to credit risk
Ensure compliance with the new simplified capital regime for SDDTs, if applicable
Key Dates
1 Jan 2027DEADLINE
The policy to retire the refined methodology to Pillar 2A takes effect, aligning with the implementation of the Basel 3.1 standards
Potential Consequences
Failure to comply with the new policy may result in enforcement action, fines, or other regulatory penalties
PS3/26 is the PRA's final policy statement restating the remaining provisions of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook and related policy materials, effective 1 January 2027. This represents a critical step in the UK's transition away from assimilated EU law, consolidating fragmented regulatory requirements into a unified domestic framework while introducing targeted amendments to securitisation rules and External Credit Assessment Institution (ECAI) mapping.
What Changed
Restatement of CRR Provisions
The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation...
New: SS4/24 (Credit risk: Internal Ratings Based Approach), SS3/24 (Credit risk definition of default), SoP6/25 (Internal Model Method permissions), SoP7/25 (Securitisation waivers and permissions),...
Amended: SS15/13 (Groups), SS9/13 (Securitisation: Significant Risk Transfer), SS10/18 (Securitisation: General requirements), and SS10/13 (Credit risk: Standardised Approach)
ECAI Mapping...
Suggested Considerations
*Immediate (by Q2 2026):
*Review applicability: Determine whether your firm falls within the scope of PS3/26 (banks, building societies, designated investment firms, or financial holding companies)
*Assess impact: Analyse how the restatement affects your current compliance framework, particularly regarding credit risk (IRB and standardised approaches), securitisation, and ECAI mapping
*Identify policy changes: Review the new and amended supervisory statements (SS3/24, SS4/24, SoP6/25, SoP7/25, SoP8/25) to understand expectations for permissions, waivers, and model approvals
*Medium-term (by Q3 2026):
Key Dates
28 October 2025
- PS19/25 (near-final policy) published
20 January 2026
- PS3/26 final policy statement published
1 January 2027
- All policies take effect; HM Treasury commencement regulations revoke relevant CRR provisions and replace them with PRA Rulebook rules and policy materials
The Prudential Regulation Authority (PRA) has published a policy statement (PS3/26) that restates the remaining relevant provisions in the Capital Requirements Regulation (CRR) within the PRA Rulebook and other policy materials. This change aims to ensure that the PRA's rules and policies are consistent with the UK's withdrawal from the EU. The policy statement is relevant to PRA-authorised banks, building societies, and other financial institutions.
What Changed
The PRA has restated the remaining relevant provisions in the CRR within the PRA Rulebook and other policy materials, including amendments to supervisory statements and the introduction of new statements of policy. The changes include updates to the securitisation requirements and the introduction of new rules on credit risk and internal ratings-based approaches.
Suggested Considerations
Review and update internal policies and procedures to ensure compliance with the restated CRR provisions
Ensure that risk management practices are aligned with the updated rules on credit risk and internal ratings-based approaches
Review and update securitisation policies and procedures to ensure compliance with the amended requirements
Key Dates
1 Jan 2027DEADLINE
The restated CRR provisions take effect
Potential Consequences
Failure to comply with the restated CRR provisions may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Capital Requirements Regulation (CRR)Basel 3.1Solvency II
PS4/26 finalizes the **simplified capital regime for Small Domestic Deposit Takers (SDDTs)**, a tailored prudential framework designed to reduce regulatory burden while maintaining capital resilience for smaller, domestically-focused UK banks and building societies. This represents the completion of Phase 1 of the PRA's "Strong and Simple" initiative and introduces materially lighter capital, liquidity, and reporting requirements for qualifying firms, with implementation effective January 1, 2027.
What Changed
Simplified Capital Framework
The final policy introduces a dedicated capital regime for SDDTs that descopes them from standard CRR Firms requirements.
Deletion of SoP3/23 (Interim Capital regime) effective January 20, 2026
Removal of SDDTs from scope of SS31/15 and SoP5/15 (standard ICAAP/SREP and Pillar 2 methodologies)
Modified consolidation group certification processes, with responsibility shifting to SDDT consolidation entities
Suggested Considerations
*Immediate (by January 20, 2026):
*Assess SDDT eligibility – Determine whether your firm meets all seven qualification criteria, particularly the £20bn asset threshold and domestic asset location requirement
*Review consolidation group structure – If part of a group, confirm which entity will serve as the SDDT consolidation entity responsible for certification
*Implement SoP2/23 changes – Adopt updated operating procedures for the SDDT regime
*Update ICAAP/ILAAP processes – Implement new frequency requirements for capital and liquidity adequacy assessments
Key Dates
January 20, 2026
– PS4/26 published; changes to SoP2/23 and ICAAP/ILAAP frequency requirements take effect
January 20, 2026
– Revocation of ICR firm/consolidation entity definitions and deletion of SoP3/23 effective
January 1, 2027
– Simplified capital regime for SDDTs takes effect; SS4/25 brought into effect in full; SDDTs removed from SS31/15 scope
The Prudential Regulation Authority (PRA) has introduced a simplified capital regime for Small Domestic Deposit Takers (SDDTs) to reduce regulatory complexity while maintaining adequate capital. The new regime will take effect on 2027-01-01. This change aims to simplify capital requirements for smaller banks and building societies.
What Changed
The PRA has introduced a new simplified capital regime for SDDTs, which includes changes to the PRA Rulebook, supervisory statements, and statements of policy. The regime also introduces new reporting templates and instructions.
Suggested Considerations
Review and update capital adequacy assessments to ensure compliance with the new simplified capital regime
Implement new reporting templates and instructions for SDDTs
Update internal policies and procedures to reflect changes to the PRA Rulebook, supervisory statements, and statements of policy
Key Dates
20 Jan 2026
Publication of the final policy statement
20 Jan 2026
Early implementation of changes to ICAAP updates and reverse stress-testing
1 Jan 2027DEADLINE
The SDDT capital regime takes effect
Potential Consequences
Enforcement action, fines, or license revocation for non-compliance with the new simplified capital regime
We have opened applications for the second cohort of our AI Live Testing service. AI Live Testing is the first of its kind in the financial sector to help firms who are ready to use AI in UK financial markets. Participating firms receive tailored support from our regulatory team and our technical partner Advai to develop, assess and deploy safe and responsible AI.The service helps firms to consider key questions around evaluating AI including governance, risk management and monitoring to help...
The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him £2,037,892 has been upheld by the Upper Tribunal. The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him £2,037,892 has been upheld by the Upper Tribunal.Mr Reynolds was dishonest when he gave pension transfer advice and investment recommendations to his customers, causing them significant harm.Mr Reynolds showed a clear disregard for his customers’ intere...
The CFTC announced three major enforcement actions on January 16, 2026, resolving cases involving **market manipulation (spoofing), misappropriation of confidential information, and unregistered commodity pool operations**. These cases demonstrate the CFTC's continued enforcement focus on fraudulent trading practices and registration violations, with combined penalties exceeding $685,000 and criminal sentences totaling over six years in prison.
What Changed
The enforcement actions establish precedent in three critical areas:
Market Manipulation (Spoofing): The CFTC secured consent orders against precious metals futures traders for spoofing—placing and canceling orders to create false market impressions. The orders impose three-year and six-month trading bans and require cease-and-desist compliance with the Commodity Exchange Act's spoofing prohibition.
Misappropriation and Fictitious Trading: The CFTC obtained permanent injunctive relief requiring disgorgement of unlawful gains ($135,788) plus civil penalties ($200,000), with 18-month trading...
Suggested Considerations
*For Registered Futures Firms and Banks:
trade and post-trade compliance controls
*For Commodity Pool Operators and Investment Advisors:
by-jurisdiction licensing analyses before soliciting investors
*For All Market Participants:
Key Dates
September 2019
- CFTC enforcement action filed against Smith and Nowak
December 2021
- CFTC complaint filed against Miller and Omerta Capital; DOJ criminal charges filed
December 2022
- CFTC complaint amended against Miller and Omerta Capital
August 2023
- Smith and Nowak sentenced to prison (criminal case)
The CFTC has announced enforcement updates, including civil monetary penalties and trading bans for spoofing in precious metals futures markets and misappropriating confidential information. These updates highlight the importance of compliance with CFTC regulations. Firms must ensure they are registered and comply with anti-spoofing and anti-fraud regulations.
What Changed
The CFTC has obtained federal court orders imposing civil monetary penalties and trading bans on individuals and firms for spoofing and misappropriating confidential information. The CFTC has also charged an unregistered commodity pool operator with fraud and registration violations.
Suggested Considerations
Verify registration with the CFTC at NFA BASIC before committing funds
Review and update anti-spoofing and anti-fraud policies and procedures
Ensure compliance with CFTC regulations regarding commodity pool operations and futures market participation
Key Dates
1 Sept 2021
CFTC enforcement action filed against Gregg Smith and Michael Nowak
10 Dec 2021
Department of Justice charged Peter Miller with conspiracy to commit commodities fraud
1 Jun 2024
Peter Miller sentenced to five months in prison and five months of home confinement
10 Dec 2024
Department of Justice charged Travis Ford with conspiracy to commit wire fraud
Potential Consequences
Enforcement action, fines, trading bans, and registration revocation
On 16 January 2026, Logic Investments Ltd (Logic Investments) entered special administration. Alex Watkins and Ed Boyle of Interpath Ltd were appointed as joint special administrators. Logic Investments is FCA authorised and regulated to provide wealth management services. On 16 December 2025, Logic Investments agreed to an FCA requirement preventing it from accepting new clients, client money or assets; or moving existing client money or assets without FCA consent. This was done because of c...
The German Financial Supervisory Authority (BaFin) warns about offers from the website two-five-management(.)com. According to information available to BaFin, the unknown operators of the website are offering banking services, in particular fixed-term deposits, and financial services without the required authorisation. They give the impression that their offers originate from TwoFive Management GmbH, which is registered with BaFin as an AIF asset management company, Section 2 (4) of the Germa...
The Federal Financial Supervisory Authority BaFin warns against offers on the website whiterock-financial(.)eu and against the alleged operator White Rock Financial Consultancy Limited from London, United Kingdom. According to information available to BaFin, the operator is providing financial and investment services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address bancosantander.es-kundenservice[at]outlook.com. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from Banco Santander S.A. This is a case of identity theft.
On 19 December 2025 the High Court approved the FCA’s proposals to distribute funds to Asset Land investors. The Court has directed the FCA to pay funds to investors in the Asset Land schemes who provide valid bank account details to the FCA on or before 20 February 2026.Investors who have not received previous communications from the FCA or who have not updated their contact information are requested to immediately contact the FCA using the details below.Please ensure this is completed no la...
The Federal Financial Supervisory Authority (BaFin) warns consumers about “Paragonix Edge” and the services it is offering. BaFin suspects the unknown operators of the websites paragonixedge(.)org, hhessel(.)com, funkmp(.)com und altenweerth(.)com of offering consumers cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers on the website coinbullvisionltd(.)com. According to information available to BaFin, the trading platform COIN Bull Vision Ltd. (also: COIN Bull Vision GmbH) is providing financial, investment and crypto asset services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers on website fragfinanz(.)com. According to information available to BaFin, banking transactions, especially fixed-term deposits, financial or investment services are being provided by FragFinanz without the required authorisation.
Alleged employees of Brookfield Asset Management GmbH are contacting investors unsolicited by telephone and email without the necessary permission to offer them alleged fixed-term deposits and alleged pre-IPO shares. In the past, they have also used the website deu-brookfield(.)com, which is no longer accessible. They give the impression that they are cooperating with licensed banks and issuers of pre-IPO shares. This is not the case.
The Federal Financial Supervisory Authority BaFin warns against offers on the websites ubpmanagement(.)co, commerzglobal(.)com, longsharks(.)com and paribasgroup(.)net. According to information available to BaFin, the companies UBP Management and Commerz Global, allegedly based in Frankfurt, and Longsharks Capital and Paribas Group, allegedly based in London, are offering financial or investment services and crypto asset services without the required authorisation. The offers do not originate...
The FCA has fined Russel Gerrity £309,843 for using inside information to net himself £128,765. As a consultant, Mr Gerrity had access to information about whether oil and gas had been discovered during the drilling of wells. Between October 2018 and January 2022, he took advantage of this and used inside information to buy shares in Chariot Oil & Gas Limited and Eco (Atlantic) Oil and Gas Plc ahead of announcements that increased their price. On another occasion, he used inside information t...
Central Bank of Ireland and Banca d’Italia are launching the Innovation Data Challenge 2026, a joint initiative designed to foster cutting-edge research and innovation in the retail payments sector. The Challenge reflects the shared commitment of the two Institutions to promoting applied research, international collaboration, and the responsible use of data and technology to shape the future of payments. The initiative brings together leading Irish and Italian universities, including Universi...
The CSSF's January 2026 enforcement report documents the results of its 2025 examination campaign on 2024 financial and non-financial disclosures by issuers under Luxembourg's Transparency Law. This publication is critical for compliance professionals because it reveals systematic compliance gaps across financial reporting (IFRS), sustainability reporting (ESRS), and Alternative Performance Measures (APMs), with 27% of enforcement decisions resulting in injunctions for non-compliance.
What Changed
The regulatory landscape has evolved significantly with the introduction of new sustainability reporting requirements:
ESRS Implementation (First Year): 2024 marked the first full reporting year under the European Sustainability Reporting Standards (ESRS), with the CSSF conducting a fact-finding exercise to assess...
Taxonomy Disclosures Amendment: On 4 July 2025, the European Commission adopted a Delegated Act amending the Taxonomy Disclosures as part of the Omnibus package, affecting Article 8 of the Taxonomy...
Double Materiality Assessment (DMA) Focus: The CSSF emphasized the importance of issuers not only disclosing the results of their DMA but also explaining the process itself, including granular...
Suggested Considerations
*Financial Information (IFRS):
*Enhanced Note Disclosures: Provide sufficient disaggregation and additional information in financial statement notes for material amounts and variances, particularly where information is not presented on the face of primary statements. The CSSF emphasizes compliance with paragraph 112(c) of IAS 1.
*Cash Flow Statement Presentation: Ensure cash flows are presented on a gross basis (not net), exclude non-cash transactions, and disclose restricted cash balances with accompanying management commentary as required by paragraph 48 of IAS 7.
*Segment Reporting Completeness: Clearly disclose all income and expense items in segment reporting, even when not separately provided to or reviewed by the Chief Operating Decision Maker (CODM), if they are included in reported segment results.
*Going Concern Assessment: Maintain high transparency regarding accounting policies and judgments applied when classifying going concern assumptions.
Key Dates
5 December 2024
- CSSF published enforcement priorities press release for FY2024 reporting
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website parex-am(.)com. BaFin has information that this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
The Securities and Exchange Commission today announced that J. Russell “Rusty” McGranahan has been named SEC General Counsel. As the SEC’s chief legal officer, Mr. McGranahan will oversee the provision of legal expertise and advice to the Office of the…
The Federal Financial Supervisory Authority (BaFin) warns consumers about the company Own Mood Space and the services it is offering. BaFin suspects the unknown operators of the website ownmoodspace(.)com of offering consumers financial, investment and cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers on the website fidelity-ag(.)com. According to information available to BaFin, banking transactions, especially fixed-term deposits, financial or investment services are being provided on this website without the required authorisation. The fixed-term deposit offers are sent, among others, from the email address festgeld[at]fidelity-ag(.)com. The offers do not originate from the Swiss company Fidelity Treuhand und Verwaltu...
On 07 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50.000 euros on pferdewetten.de AG.
AI Analysis
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on pferdewetten.de AG on November 7, 2025, for violations related to the publication of financial reports under German securities law (WpHG - Wertpapierhandelsgesetz). This enforcement action underscores regulatory expectations for timely and accurate financial disclosure compliance, particularly for publicly traded or regulated entities in the gaming/betting sector.
What Changed
Based on the enforcement context, the regulatory requirements at issue involve:
Financial Reporting Obligations: Entities subject to WpHG must publish financial reports in accordance with statutory deadlines and content requirements
Disclosure Standards: Reports must meet quality and completeness standards established under German securities law
Enforcement Mechanism: The BfJ has authority to impose disciplinary fines for non-compliance with publication requirements
No Safe Harbor: Delayed or deficient publication cannot be remedied retroactively without regulatory consequences
Suggested Considerations
*Audit Current Compliance: Review all financial reporting timelines and publication procedures to ensure adherence to WpHG deadlines
*Strengthen Internal Controls: Implement or enhance controls over financial report preparation, review, and publication workflows
*Document Procedures: Maintain clear documentation of publication dates, approval chains, and compliance verification
*Monitor Deadlines: Establish calendar systems with advance reminders for statutory reporting deadlines
*Legal Review: Consult with securities law counsel to confirm specific reporting obligations applicable to your entity
Key Dates
November 7, 2025
- BfJ imposed €50,000 disciplinary fine on pferdewetten.de AG
January 15, 2026
- BaFin published enforcement action notice
Ongoing
- WpHG financial reporting obligations remain in effect with no stated grace period modifications
On 07 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50.000 euros on pferdewetten.de AG.
AI Analysis
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on pferdewetten.de AG on 7 November 2025 for violations related to the publication of financial reports under the German Securities Trading Act (WpHG). This enforcement action underscores BaFin's and BfJ's strict oversight of timely and accurate financial disclosures by public companies, serving as a warning to listed firms on the consequences of non-compliance. It matters because it highlights procedural lapses in ad-hoc publicity and annual reporting, potentially increasing scrutiny on similar entities amid ongoing regulatory emphasis on market integrity.
What Changed
This is not a regulatory change or new requirement but an enforcement decision enforcing existing obligations under § 37w WpHG (disciplinary measures for breaches of publication duties) and related...
Timely publication of annual financial reports and ad-hoc announcements via electronic means (e.g., DGAP platform).
Ensuring completeness and accuracy of published financial statements, including management reports.
Immediate correction of any publication errors or delays to prevent market misinformation.
No new rules were introduced; the fine reinforces pre-existing standards without amendments.
(Source:...
Suggested Considerations
Conduct an internal audit of recent financial report publications (last 12-24 months) for timeliness, accuracy, and platform compliance (e.g., DGAP/EGAP).
Implement or enhance pre-publication checklists, including dual approvals and automated validation tools to flag delays or errors.
Train IR and compliance staff on WpHG §§ 15, 111-114 (ad-hoc and periodic reporting) and § 37w (sanctions).
Review outsourcing arrangements for reporting (e.g., to service providers) to ensure accountability under MaGo (Minimum Requirements for Risk Management).
Document remedial actions and report to the supervisory board; consider voluntary self-disclosure for any identified breaches to mitigate fines.
Key Dates
07 November 2025
- Date BfJ imposed the €50,000 disciplinary fine on pferdewetten.de AG
Compliance Impact
Urgency: Medium. This matters as a concrete example of BfJ's willingness to levy fines (here €50,000, modest but precedential) for reporting lapses, signaling heightened enforcement post-2025 ESMA-aligned updates to transparency rules. Firms with similar profiles face elevated audit risk, especially with BaFin's 2026 focus on digital reporting resilience; non-compliance could escalate to higher penalties (up to €10M or 5% turnover under EU MAR equivalents) or trading suspensions. Prioritize if your firm has recent publication issues.
On 7 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50,000 euros on TTL Beteiligungs- und Grundbesitz-AG
AI Analysis
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG on 7 November 2025 for failing to publish required financial reports, violating transparency obligations under the German Securities Trading Act (WpHG). This enforcement action underscores BaFin's heightened focus on financial reporting compliance for listed companies, serving as a warning for timely and accurate disclosures amid strategic priorities on market integrity and early risk detection. Compliance teams should view it as a signal of rigorous enforcement against reporting lapses, potentially leading to escalated penalties for repeat or severe breaches.
What Changed
No new regulatory changes are introduced; this is an enforcement case applying existing WpHG requirements for periodic financial reporting by publicly listed entities. The case reinforces the statutory duty under Section 40c WpHG (as referenced in the BaFin publication title) to publish financial reports promptly, with BfJ acting as the disciplinary authority for such violations. It aligns with BaFin's ongoing risk-based enforcement on financial reporting for publicly traded companies, emphasizing compliance with transparency and disclosure rules.
Suggested Considerations
Conduct immediate gap analysis of financial reporting processes to ensure compliance with WpHG Sections 37 et seq. (annual/interim reports) and 40c (publication duties).
Implement automated monitoring and reminders for publication deadlines (e.g., 4 months for annual reports, 3 months for half-yearly).
Strengthen internal controls, including pre-publication reviews by compliance and legal teams, with escalation to senior management.
Train responsible personnel on disciplinary risks, documenting adherence to avoid BfJ fines (up to €5 million or 3% of turnover for severe cases).
For listed firms, integrate reporting into broader governance frameworks, aligning with BaFin's data-driven supervision expectations.
Key Dates
7 November 2025
- BfJ imposes €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG for financial reporting violations
Compliance Impact
Urgency: Medium - This fine is modest (€50,000) and targets a specific reporting failure, not systemic issues like AML or IT deficiencies seen in larger cases (e.g., J.P. Morgan's €45 million fine). It matters as a precedent in BaFin's 2026-2029 strategy prioritizing market transparency, financial reporting enforcement, and early detection of non-compliant firms, signaling increased audits and penalties for disclosure lapses that undermine market integrity.
On 7 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50,000 euros on TTL Beteiligungs- und Grundbesitz-AG
AI Analysis
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG on 7 November 2025 for failing to publish required financial reports, highlighting enforcement of financial reporting obligations under German securities law (WpHG). This case underscores BaFin's and BfJ's commitment to market transparency and integrity, serving as a warning to listed companies on the consequences of non-compliance with ad-hoc and periodic reporting duties. Compliance professionals should note it as evidence of intensified scrutiny on reporting accuracy amid BaFin's 2026-2029 strategic priorities.
What Changed
No new regulatory changes are introduced; this is an enforcement action enforcing existing requirements under the German Securities Trading Act (WpHG § 124), which mandates timely publication of financial reports for publicly listed companies. The case reaffirms the disciplinary framework where BfJ, as the competent authority, can impose fines up to €700,000 (or 5% of turnover) for violations, with this €50,000 fine reflecting a proportionate measure for the breach.
Suggested Considerations
Conduct immediate gap analysis of financial reporting processes to ensure compliance with WpHG §§ 37c, 115, and 124 on publication of annual, half-yearly, and ad-hoc reports via electronic means (e.g., company website and Bundesanzeiger).
Implement automated monitoring and reminders for reporting deadlines, with dual sign-off by compliance and finance teams.
Train management on personal liability for reporting failures, including documentation of internal controls to demonstrate due diligence in supervisory reviews.
For firms with similar profiles, voluntarily self-report past lapses to BfJ/BaFin to potentially mitigate fines, referencing this case as precedent.
Key Dates
7 November 2025
- Date BfJ imposed the €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG for financial reporting violations
Compliance Impact
Urgency: Medium - This fine, while modest, signals BfJ's active enforcement role in financial reporting, amplified by BaFin's 2026-2029 strategy prioritizing "market transparency and integrity" through increased monitoring of publicly traded companies. It matters because reporting breaches erode investor trust and can escalate to larger penalties or trading suspensions; firms should prioritize process reviews now to avoid higher fines amid BaFin's push for data-driven supervision and early detection of issues.
The Prudential Regulation Authority (PRA) has today published its supervisory priorities for 2026, outlining in a letter its sector-specific priorities for the coming year to all banks, building societies, insurers and other PRA-regulated firms.
The Federal Financial Supervisory Authority (BaFin) suspects the unknown operators of the website fivepillarstoken(.)com of offering consumers cryptoasset services in Germany without the required authorisation. The offers include “crypto debit cards” and staking using Five Pillars Tokens.
Circular CSSF 19/708 mandates the electronic transmission of specified documents to the CSSF via secure platforms like e-file or SOFiE, effective from February 1, 2019, replacing prior paper or other methods. This updated annex (as amended by Circular CSSF 21/790 and further revisions up to April 1, 2025) standardizes submissions for investment funds and related entities, reducing administrative burdens while ensuring document integrity and CSSF accessibility. Compliance professionals must monitor the dynamic annex list on the CSSF website to avoid nullified submissions.
What Changed
- Mandatory Electronic-Only Submission: Documents listed in Annex I must be transmitted exclusively via e-file (http://www.e-file.lu) or SOFiE...
Dynamic Annex Updates: The annex, published on the CSSF website, is regularly updated (e.g., latest noted April 1, 2025) and includes prospectuses, management regulations, annual reports, risk...
Scope Expansion: Extends beyond UCIs to securitisation undertakings (2004 Law), pension funds (2005 Law), SICARs, and Luxembourg IFMs; repeals prior Circulars CSSF 09/423 and 08/371.
Filer Responsibilities: Entities ensure documents match official final hard copies, handle content/format accuracy, and check annex updates regularly.
Suggested Considerations
Register/access e-file or SOFiE platforms if not already (test/production environments available since February 2019).
Consult and adhere to the latest Annex I for document list, nomenclatures, and formats (PDF with full functionality).
Ensure submissions are final/official versions matching hard copies; use specified identifiers for UCIs/SIFs/SICARs.
Implement processes for automatic/manual transmission (e.g., via updated sending services v4.9.0 or transmission module 6.6.0).
Train staff on responsibilities and integrate into reporting workflows; reference CSSF FAQs for closing documents.
Key Dates
28 January 2019
Publication date; of original Circular CSSF 19/708
1 February 2019
Entry into force; Mandatory electronic transmission for listed documents; non-electronic submissions null and void
22 December 2021
Amendment; by Circular CSSF 21/790
1 April 2025
Latest annex update; noted
OngoingDEADLINE
Regular checks required; Entities must monitor CSSF website for annex updates
Compliance Impact
Urgency: Low (for new implementations post-2019; medium for ongoing monitoring). This matters for operational efficiency and CSSF relations, as non-compliance risks rejected filings, delays (e.g., approvals under SFDR processes), or supervisory scrutiny, but long-standing rule (since 2019) with established platforms reduces immediate pressure. Firms must prioritize annex vigilance to avoid disruptions in routine reporting like annual reports or prospectuses.
According to information available to the Federal Financial Supervisory Authority (BaFin), unknown persons are using Telegram groups and chats to contact German investors. The initiators of these messenger groups purport to be the US company “MacKay Shields”. This is a case of identity fraud.
According to information available to the Federal Financial Supervisory Authority (BaFin), unknown persons are using WhatsApp groups and chats to contact German investors. The initiators of these WhatsApp groups purport to be the US company “Payden & Rygel”. This is a case of identity theft misusing the names of real employees.
Introduction Good morning and thank you to Michael for inviting me to speak at the Compliance Institute’s Annual General Meeting. It is always a real pleasure to engage with compliance professionals. At the Central Bank, we recognise the essential role played by the compliance community in ensuring that financial firms are well-run and contributing to a financial system that is trusted and resilient. We also recognise the important role played by the compliance institute, equipping those work...
AI Analysis
This speech by Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (CBI), outlines key supervisory priorities including securing customers' interests via the revised Consumer Protection Code, Individual Accountability Framework (IAF) implementation, regulatory simplification, resilience, technology leverage, and an evolving outcomes-focused supervision approach. It matters because it signals CBI's expectations for compliance professionals to drive these outcomes in firms, emphasizing proportionality and ongoing engagement amid regulatory evolution. Compliance teams must integrate these themes to align with CBI's shift toward less process-driven, more effective oversight.
What Changed
- Revised Consumer Protection Code: Introduces new Standards for Business, building on the Code reviewed with industry input; focuses on delivering good outcomes for consumers and the economy.
Individual Accountability Framework (IAF): Implemented 18 months prior (circa mid-2024); enhances clarity on responsibilities, supports governance, and aligns with outcomes-focused regulation rather...
Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcomes-focused, less process-driven supervision integrated across financial stability, consumer protection, safety/soundness,...
Regulatory Simplification: Openness to reviewing frameworks (e.g., fitness and probity) for simpler, outcomes-based alternatives without compromising effectiveness; supports broader simplification...
Resilience and Technology: Ongoing focus on financial resilience post-reforms, leveraging technology for supervision; no specific new rules but emphasis on embedding these in operations.
No new...
Suggested Considerations
Implement Revised Consumer Protection Code: Complete readiness by 24 March 2026; apply new Standards for Business in operations, leveraging CBI workshops for guidance.
Embed IAF: Maintain enhanced responsibility mapping, support decision-making, and engage with CBI on implementation feedback to mature governance.
Adopt Outcomes-Focused Practices: Shift from process-driven to outcomes-based compliance (e.g., customer interests, resilience); review internal frameworks for simplification opportunities.
Engage with CBI: Participate in ongoing consultations, workshops, and stakeholder feedback on supervision evolution, IAF, and Consumer Protection Code.
Leverage Technology: Integrate tech for resilience and compliance efficiency, aligning with CBI's supervisory priorities.
Key Dates
24 March 2026DEADLINE
- Revised Consumer Protection Code comes into force; firms must ensure full readiness and ongoing embedding of provisions, including new Standards for Business
Compliance Impact
Urgency: Medium. This speech reinforces imminent obligations like the 24 March 2026 Consumer Protection Code effective date (less than 2 months from speech/publication), requiring immediate readiness checks, but lacks new rules or critical enforcement threats. It matters for long-term alignment with CBI's outcomes-focused supervision, reducing future supervisory risks through proactive embedding of IAF and simplification; non-engagement could signal poor governance amid evolving oversight.
The European Supervisory Authorities and UK financial regulators sign Memorandum of Understanding on oversight of critical ICT third-party service providers under DORA 14 January 2026 Digital Finance and Innovation International cooperation The European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) have today signed a Memorandum of Understanding (MoU) with the Bank of England (BoE), the Prudential Regulation Authority (PRA), and the Financial Conduct Authority (FCA). This agreement...
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website givhalbank(.)com. According to information available to BaFin, this website is being used to offer banking business and financial, investment and cryptoasset services without the required authorisation.
The FCA, Bank of England and Prudential Regulation Authority have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.The MoU establishes a framework for coordinating and sharing information on the oversight of CTPs under the UK regime and critical third party providers (CTPPs) under the EU’s Digital Operational Resilience Act (DORA), including du...
AI Analysis
The FCA, Bank of England (BoE), and Prudential Regulation Authority (PRA) have signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities (ESAs) to coordinate oversight of critical third parties (CTPs) under the UK's CTP regime and critical third party providers (CTPPs) under the EU's Digital Operational Resilience Act (DORA). This matters because it enhances cross-border information sharing and cooperation during incidents like cyber-attacks, reducing regulatory duplication while bolstering financial stability and operational resilience for firms reliant on these providers.
What Changed
- Establishes a framework for timely information sharing, coordination of oversight activities, and joint responses to incidents affecting CTPs/CTPPs, including power outages or cyber-attacks.
Defines principles for cooperation on mutually designated CTPs/CTPPs, including notifications of investigations and best endeavors to share material information where legally and operationally...
Complements the UK's CTP regime (effective 1 January 2025), which requires designated CTPs to provide regular assurance, conduct resilience testing, and report major incidents, without altering...
Supported by a tripartite MoU among UK regulators for coordinated oversight via a joint CTP Consultation and Coordination Forum (CCF).
Suggested Considerations
For CTPs/CTPPs: Once designated, implement regular assurance reporting to regulators, conduct resilience testing (e.g., scenario testing), and report major incidents promptly; prepare for cross-border information requests under the MoU.
For financial firms/FMIs: Continue managing operational resilience and third-party risks per existing outsourcing rules (e.g., identify dependencies on potential CTPs); monitor HMT designations and enhance incident response coordination with regulators.
Regulators' internal actions: Use CCF for coordination; notify counterparts of investigations or material developments per MoU Article 3 and 12.
Firms should review contracts with third parties for compliance alignment and conduct gap analyses against CTP requirements.
Key Dates
1 January 2025
UK CTP rules came into effect, applying to CTPs designated by HMT
Ongoing (process begun pre
2025); HMT designation process for CTPs, with regulators recommending based on concentration and materiality criteria; no fixed end date specified
DORA effective date (prior context)
EU CTPPs oversight under DORA aligns with UK regime; MoU signed to ensure compatibility (exact DORA timeline not in publication but supports post-2024 implementation)
Compliance Impact
Urgency: High – The MoU operationalizes the live UK CTP regime (effective January 2025), with designations underway, amplifying risks of non-compliance for firms using critical ICT providers amid rising cyber and resilience threats. It matters for cross-border firms as it enables regulator-to-regulator data sharing, potentially exposing gaps in outsourcing arrangements and increasing enforcement scrutiny without fines on CTPs yet possible future powers.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website blitz365finance(.)org. According to information available to BaFin, the operators are offering financial and cryptoasset services on the website without the required authorisation. The unknown operators of the website are not supervised by BaFin. This is a case of identity fraud against a Swiss company.
The Financial Conduct Authority, Bank of England and Prudential Regulation Authority (UK regulators) have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.
ESMA promotes clarity in communications on ESG strategies 14 January 2026 Sustainable finance The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, published today a second thematic note on sustainability-related claims, focusing on ESG strategies. The note concentrates on ESG integration and ESG exclusions, as references to these strategies are often made by market participants and widely referenced in marketing communications directed to ...
AI Analysis
ESMA published a thematic note on January 14, 2026, providing guidance on clear, fair, and not misleading communications regarding ESG strategies, specifically ESG integration and ESG exclusions, to mitigate greenwashing risks in non-regulatory materials like marketing. This matters because sustainability claims heavily influence investor decisions, and misleading communications can lead to supervisory actions, reputational damage, and loss of trust, aligning with existing EU rules under SFDR and related frameworks without imposing new disclosures.
What Changed
This is not a formal regulatory change but supervisory guidance reinforcing four principles for non-regulatory communications (e.g., marketing materials, websites, investor presentations, voluntary...
Accurate: Claims must fairly represent sustainability profiles without exaggeration, falsehoods, omissions, cherry-picking, vagueness, or misleading ESG terminology/imagery.
Accessible: Information must be easy to understand and navigate, with layered substantiation in electronic formats for retail materials.
Substantiated: Backed by clear reasoning, facts, processes, and methodologies; disclose data limitations and comparison bases.
Up to date: Reflect current data, with timely disclosure of material changes and analysis dates.
Practical do's/don'ts include explaining ESG processes in plain language, disclosing portfolio...
Suggested Considerations
Review and update all non-regulatory ESG communications (marketing, websites, presentations, DDQs, PPMs) against the four principles and do's/don'ts.
Ensure consistency across channels, substantiate claims with accessible evidence, and avoid vagueness or overstatements.
Train compliance/marketing teams; monitor for updates as further thematic notes may follow.
Cross-reference with first note and regulations like SFDR, Cross-Border Distribution Regulation.
Key Dates
1 July 2025
- Publication of ESMA's first thematic note on ESG credentials (to be read in combination)
14 January 2026
- Publication date of the thematic note on ESG strategies (second in series)
Compliance Impact
Urgency: High – Immediate risk of enforcement for greenwashing in high-visibility ESG marketing, amid rising supervisory scrutiny; non-compliance threatens fines, remediation, and reputational harm as investor focus on sustainability grows. Proactive alignment builds trust and differentiates firms.
ESMA’s Digital and Data strategies support supervision of EU financial markets 13 January 2026 About ESMA Market data Press Releases The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has adopted a new Digital Strategy and updated its Data Strategy . They reflect ESMA’s commitment to smarter regulatory reporting and technology-driven supervision, promote synergies and innovation while reducing unnecessary complexity. The digital strategy...
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 2 der Verordnung vom 22. Juni 2005 über Massnahmen gegenüber der Demokratischen Republik Kongo (SR 946.231.12) publiziert.
AI Analysis
The Swiss Federal Department for Economic Affairs, Education and Research (WBF) updated Annex 2 of the Ordinance on Measures against the Democratic Republic of Congo (SR 946.231.12) on January 12, 2026, modifying the list of sanctioned persons, companies, and organizations, with changes effective January 13, 2026, at 23:00 UTC. This matters for Swiss financial intermediaries as it triggers immediate asset freezing, reporting to SECO, and potential AML checks under the Anti-Money Laundering Act (GwG), ensuring compliance with Switzerland's implementation of international sanctions via the Embargo Act (EmbG).
What Changed
- Amendment to Annex 2 of SR 946.231.12, updating the list of sanctioned individuals, entities, and organizations subject to financial restrictions.
Integration into the SECO Sanctions Management (SESAM) database, with urgent publication on the SECO website.
Reinforcement of prohibitions: asset freezing, ban on making funds available, and reporting of affected business relationships to SECO; does not exempt from GwG Art. 6 due diligence or Art.
Suggested Considerations
Screen client portfolios and transactions against the updated SESAM database immediately upon effectiveness.
Freeze assets of newly listed sanctioned parties and prohibit making funds/resources available.
Report affected business relationships to SECO without delay.
Conduct GwG Art. 6 due diligence on suspicions; file Art. 9 reports to the Money Laundering Reporting Office if unresolved.
Monitor MyFINMA for FINMA alerts and update internal sanctions screening tools.
Key Dates
January 12, 2026
- WBF publishes amendment to Annex 2
January 13, 2026, 23:00 UTCDEADLINE
- Changes enter into force; immediate implementation required
December 12, 2026
- Related EU sanctions extended to this date (Swiss alignment expected)
Compliance Impact
Urgency: High - Immediate effect from January 13, 2026, 23:00 UTC demands rapid screening and freezing to avoid EmbG violations, which can trigger FINMA enforcement (e.g., fines, license actions). Matters due to sanctions lists' frequent updates (e.g., prior May 2024 change) and overlap with AML obligations, heightening financial crime exposure for DRC-linked assets.
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 1 der Verordnung vom 28. März 2018 über Massnahmen gegenüber Venezuela (SR 946.231.178.5) publiziert.
AI Analysis
On January 13, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 1 of the Ordinance on Measures against Venezuela (SR 946.231.178.5), reflecting changes to the list of designated persons and entities subject to Swiss asset freezing measures. This update is critical for Swiss financial institutions and regulated entities as it directly impacts sanctions compliance obligations and requires immediate verification of client and counterparty lists against the revised designations.
What Changed
The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela.
Update their sanctions screening systems with revised designations
Identify any existing relationships with newly designated or de-designated persons/entities
Implement immediate asset freezing for any newly added designations
Cease all transactions with blocked parties unless specifically authorized
Suggested Considerations
*Immediate Screening: Conduct comprehensive screening of all client and counterparty databases against the updated Annex 1 designations within 24-48 hours of publication.
*Asset Identification: Identify and document any assets, accounts, or positions held by or on behalf of newly designated persons/entities.
*Freeze Implementation: Immediately freeze all identified assets and block all transactions involving designated parties.
*Notification: Report any blocked assets to SECO as required under Swiss sanctions legislation (typically within 10 business days).
*Transaction Review: Suspend all pending transactions with Venezuela-related counterparties pending compliance verification.
Key Dates
January 5, 2026
- FINMA ordinance on asset freezing (RS 196.127.85) enters into force at 11 a.m., freezing assets of 37 designated persons
January 13, 2026
- SECO publishes updated Annex 1 to SR 946.231.178.5 (the update referenced in your query)
ImmediateDEADLINE
- Compliance obligations commence upon publication; no grace period for implementation
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
AI Analysis
The Swiss Federal Department for Economic Affairs, Education and Research (WBF) has published updates to the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions with ongoing international restrictions targeting Russia. This matters for Swiss financial institutions as it reinforces asset freezing and economic resource restrictions, heightening compliance risks amid prolonged geopolitical tensions, with the ordinance valid until at least November 2026.
What Changed
The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibitions on asset management or use except for normal administrative actions by financial institutions.
Suggested Considerations
Screen clients, transactions, and assets against updated sanctions lists for Russian/Ukrainian designations, focusing on asset freezing (no management/use except administrative actions) and economic resources (no sales, leasing, or financing).
Block prohibited activities in energy sector, financial services (e.g., derivatives, crypto, guarantees), and related exports/financing; report any frozen assets to authorities.
Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11).
Monitor FINMA's sanctions page for full ordinance text and related guidance.
Key Dates
Various historical dates (e.g., March 25, 2022 at 23:00; January 25, 2023 at 18:00)
- Prior amendment effective dates, illustrating pattern of rapid implementation
January 13, 2026
- Publication of amendments by WBF, triggering immediate review obligations
November 22, 2026
- Current expiry of ordinance (subject to extension)
Compliance Impact
Urgency: High - Ongoing amendments to this long-standing ordinance (active since 2022) demand immediate screening and blocking to avoid FINMA enforcement, fines, or reputational damage, especially with crypto and energy sector expansions capturing evolving risks. Non-compliance risks asset release violations or facilitation of sanctioned activities, amplified by FINMA's enforcement focus on financial crime.
The PRA and FCA have jointly issued consultation paper CP1/26 proposing to set the **Management Expenses Levy Limit (MELL) for the Financial Services Compensation Scheme (FSCS) at £113 million for 2026/27**, comprising a £108 million management expenses budget and a £5 million unlevied reserve. This consultation determines the maximum amount the FSCS can levy on authorised financial services firms to fund its statutory compensation scheme operations, directly affecting compliance costs for all regulated entities.
What Changed
The proposed MELL for 2026/27 introduces the following material changes:
Budget increase of £4.4 million from 2025/26 (from approximately £103.6 million to £108 million), broadly aligned with inflation
Nominal reduction of £6.6 million on a like-for-like basis when excluding the cost of enhancements to the FSCS's revolving credit facility (RCF)
Real terms reduction of £11 million when accounting for inflation adjustments
RCF enhancement to £3 billion to support the Bank of England's recapitalisation powers and enable faster depositor payouts
Suggested Considerations
*Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
*Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
*Prepare internal stakeholder communication regarding the £4.4 million aggregate increase and its implications for your firm's regulatory costs
*Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
*Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026
Key Dates
10 February 2026DEADLINE
– Consultation deadline for comments on CP1/26
1 April 2026
– Effective date: proposed MELL applies from start of FSCS financial year
The Securities and Exchange Commission today announced that Paul H. Tzur and David M. Morrell have been named as Deputy Directors of the Division of Enforcement. Mr. Tzur joined the Commission on January 6, 2026, as the Deputy Director overseeing the…
AI Analysis
The SEC announced on January 12, 2026, the appointment of Paul H. Tzur and David M. Morrell as Deputy Directors of the Division of Enforcement, with Tzur joining on January 6, 2026, to oversee key operations. This personnel change is part of a broader reorganization replacing Regional Directors with Deputy Directors for more centralized oversight of investigations. It matters for compliance teams as it signals greater consistency in enforcement approaches, potentially affecting investigation timelines, Wells process strategies, and settlement negotiations across SEC-regulated entities.
What Changed
This announcement reflects structural reforms rather than new substantive regulations:
Replacement of Regional Directors with Deputy Directors, centralizing reporting from local offices (e.g., Boston, Fort Worth, Atlanta) and specialized units directly to headquarters-led Deputy...
Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations.
Complements parallel Wells process reforms under Chairman Paul Atkins, including a baseline four-week response period, greater access to evidence, and senior-level meetings for transparency and due...
Suggested Considerations
Review and update internal protocols for SEC investigations to align with centralized reporting structures, anticipating uniform standards across regions.
Train legal/compliance staff on refined Wells process (e.g., prepare for four-week timelines and evidence access requests).
Monitor upcoming SEC communications for Enforcement Director Judge Margaret Ryan's guidance on fraud-focused priorities.
Assess current or potential matters for earlier engagement with Deputy Directors on case theories and resolutions.
Key Dates
January 6, 2026
- Paul H. Tzur joins SEC as Deputy Director of the Division of Enforcement.
January 12, 2026
- SEC announces appointments of Paul Tzur and David Morrell as Deputy Directors.
Compliance Impact
Urgency: Medium. This matters due to its role in ongoing SEC transition under Chairman Atkins and Director Ryan, promising more predictable enforcement but requiring adaptation to centralized decision-making and Wells enhancements. While not imposing immediate obligations, it could accelerate case resolutions and shift settlement dynamics, especially amid 2025's enforcement slowdown from staffing cuts (15-20% headcount reduction). Firms with active investigations should prioritize strategic adjustments now.
The CSSF imposed a €10,000 administrative fine on BigRep SE on 12 January 2026 for failing to publish its half-yearly financial report as of 30 June 2025, as required under Article 4 of Luxembourg's Transparency Law of 11 January 2008 (as amended). This enforcement action underscores the CSSF's rigorous supervision of periodic disclosure obligations for issuers with Luxembourg as their home Member State, serving as a reminder of the consequences for non-compliance with transparency requirements. Compliance professionals should note this as evidence of ongoing CSSF scrutiny on timely reporting, with potential fines scaled based on circumstances per Article 26a.
What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the Transparency Law of 11 January 2008 (as amended), specifically Article 4, which mandates issuers to publish half-yearly financial reports, including effective dissemination, storage on the Officially Appointed Mechanism (OAM), and filing with the CSSF. No new rules are introduced; the sanction reinforces the unchanged deadlines and processes for periodic information publication, with the CSSF acting under Article 25(2) as the competent authority.
Suggested Considerations
Issuers: Immediately review internal processes for half-yearly financial reporting to ensure compliance with Article 4, including timely publication, OAM storage, and CSSF filing; conduct gap analyses against Transparency Law deadlines.
All affected parties: Implement or enhance monitoring calendars for periodic disclosures, with automated alerts for period-ends like 30 June; perform mock filings to test dissemination and storage mechanisms.
BigRep SE specifically: Consider appeal to Tribunal administratif within 3 months if contesting the fine; remediate the specific non-compliance by publishing the overdue report if not already done.
wide actions are mandated beyond general adherence, but proactive audits are advisable given CSSF's supervisory focus.
Key Dates
30 June 2025DEADLINE
- Period-end date for the required half-yearly financial report that BigRep SE failed to publish
12 January 2026
- Date of administrative sanction imposition by CSSF and publication of the decision
Within 3 months of 12 January 2026DEADLINE
(i.e., by 12 April 2026) - Deadline for BigRep SE to lodge a court action with the Tribunal administratif against the sanction, per Article 27 of the Transparency Law
Compliance Impact
Urgency: Medium – This matters as a specific enforcement example in CSSF's ongoing verification of periodic information publication, signaling heightened scrutiny rather than a systemic shift. While the €10,000 fine is modest, it demonstrates fines for even isolated breaches (scaled per Article 26a), potentially escalating for repeats; firms should prioritize reporting calendars to avoid reputational harm and publication of sanctions under Article 26b(1).
This CSSF publication, dated January 12, 2026, identifies the specific population (likely a firm or individual) subject to an enforcement action, such as an administrative sanction, as part of the CSSF's transparency in supervisory measures. It matters because it signals CSSF's active enforcement priorities, potentially in areas like AML or reporting failures, enabling firms to assess similar risks in their operations and strengthen compliance to avoid parallel actions. Published amid rising focus on financial crime typologies like sexual extortion, it underscores the regulator's commitment to public accountability.
What Changed
No new regulatory changes or requirements are introduced in this publication, as it is an enforcement notice rather than a circular or guideline. It serves as a disclosure of an ongoing or concluded enforcement case, aligning with CSSF's practice of publishing sanction details to deter non-compliance and inform the market, without altering existing rules.
Suggested Considerations
For the named population: Comply with any sanction terms (e.g., pay fines, implement remediation plans, or cease certain activities), and report to CSSF as required; appeal if applicable under Luxembourg administrative law.
Update internal policies, train staff on enforcement precedents, and ensure robust reporting under Circular CSSF 19/726 or Transparency Law obligations.
Compliance Impact
Urgency: High – Immediate relevance for the named party facing direct consequences; medium-to-high for peers due to CSSF's pattern of public enforcements signaling heightened scrutiny on financial crime, especially amid rising OCSE/FSEC cases noted in recent CSSF guidance. It matters as it could preview broader supervisory sweeps, impacting reputation, operations, and costs if similar vulnerabilities exist.
We reviewed how firms sell complex exchange traded products (ETPs) to retail consumers. Complex ETPs are a subset of the wider ETP market and include high-risk investment strategies that can be difficult for retail consumers to understand.We assessed how firms of different sizes and business models evaluate these products, communicate key risks and monitor outcomes under the Consumer Duty.Given the complexity and risk profile of ETPs, it is essential firms make sure investors have the knowled...
In new guidance, the Swiss Financial Market Supervisory Authority FINMA explains how it assesses the risks associated with the custody of cryptobased assets. The guidance sets out the rules that institutions must abide by in order to keep cryptobased assets safe.
The Securities and Exchange Commission today announced it will hold its third and final outreach event to help firms comply with amendments to Regulation S-P. The event, which is focused on small firms, is open to in-person or virtual attendance, and is…
The FCA has secured a confiscation order of £265,523.96 against Andrew Currie. Mr Currie was convicted in 2023 and sentenced to 2 years 6 months imprisonment for defrauding investors through the collapsed peer-to-peer lending platform Collateral (UK) Ltd.He diverted funds from Collateral investors and used them for personal gain, including the purchase of a property in Spain.At a hearing at Southwark Crown Court on 9 January 2026, Mr Currie was ordered to pay £265,523.96. This amount represen...
Administrative sanction imposed on the alternative investment fund manager Premium Capital Management (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on 11 September 2025 against alternative investment fund manager (AIFM) Premium Capital Management for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation amid ongoing AML risks in Luxembourg. Compliance teams should view this as a reminder of the low tolerance for even administrative lapses, with potential for escalated fines in repeat cases.
What Changed
This is not a regulatory change but an enforcement precedent under existing rules: non-compliance with Article 5(1) of the AML/CFT Law, which mandates annual submission of a financial crime questionnaire ("Questionnaire") to the CSSF. The fine was calculated per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), considering circumstances under Article 8-5(1). Publication followed Article 8-6(1) after a proportionality assessment, confirming no market stability risks.
Suggested Considerations
Immediately review internal processes for annual Questionnaire submission, ensuring calendar invites and automated reminders for the 4 April deadline (covering prior year-end data).
Conduct a gap analysis on AML/CFT cooperation obligations under Article 5(1), including response protocols to CSSF reminders or queries.
Update compliance calendars and train staff on escalation procedures; document all submissions with proof (e.g., timestamps, acknowledgments).
For AIFMs: Verify CSSF registration status under Article 3(2) of the 12 July 2013 AIFM Law and align with broader AML duties.
If late, proactively submit overdue items and request meetings if needed, as non-response forfeits mitigation opportunities.
Key Dates
31 December 2024
- Reference year-end for the financial crime Questionnaire
4 April 2025DEADLINE
- Statutory deadline for Questionnaire submission to CSSF
11 September 2025
- Date CSSF imposed the €10,000 administrative fine after non-submission despite reminders
9 January 2026
- Publication date of the sanction decision
Compliance Impact
Urgency: Medium – This €10,000 fine for a straightforward reporting failure demonstrates CSSF's willingness to penalize non-cooperation swiftly, even without aggravating factors, but the amount is modest and targeted at administrative breaches. It matters as a warning shot in Luxembourg's AML landscape, where repeated failures could trigger higher fines (up to proportionality limits under Article 8-5), reputational damage via public naming, or supervisory escalations; firms should audit 2025/2026 reporting now to preempt similar actions, especially post-NRA updates.
Administrative sanction imposed on the alternative investment fund manager Sunbricks GP S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a **€10,000 administrative fine on Sunbricks GP S.à r.l.**, an alternative investment fund manager, for failing to submit a mandatory annual financial crime questionnaire by the April 4, 2025 deadline, despite two formal reminders. This enforcement action demonstrates the CSSF's strict approach to cooperation obligations under Luxembourg's anti-money laundering and counter-terrorist financing (AML/CFT) framework and signals that non-submission of required compliance documentation—even without evidence of underlying financial crime—triggers regulatory penalties.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All professionals supervised, authorized, or registered by the CSSF must submit an annual questionnaire on financial crime by April 4 each year, covering...
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, which includes timely submission of requested...
Administrative Fine Framework: The CSSF applies Article 8-4 of the AML/CFT Law to impose fines for non-compliance, with amounts determined under Article 8-5 based on all relevant circumstances.
Suggested Considerations
regulated entities must:
*Establish Calendar Controls: Implement internal compliance calendars flagging the April 4 annual questionnaire submission deadline with sufficient lead time (minimum 4-6 weeks before deadline)
*Designate Responsible Parties: Assign clear ownership for questionnaire completion and submission, with backup contacts
*Prepare Documentation: Maintain contemporaneous records of financial crime controls, suspicious activity reporting, and compliance activities throughout the year to support accurate questionnaire responses
*Monitor Communications: Ensure all CSSF correspondence is tracked and escalated immediately; do not ignore reminder notices
Key Dates
April 4, 2025DEADLINE
– Annual financial crime questionnaire submission deadline (for year ending December 31, 2024)
Before September 11, 2025
– Two reminder notices issued by CSSF to Sunbricks GP
September 11, 2025
– Administrative fine decision date; questionnaire still not submitted
Administrative sanction imposed on the alternative investment fund manager Capitalis Premiere Group (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Capitalis Premiere Group on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation for Luxembourg-regulated entities. Compliance teams should note this as a low-value but public reminder of potential fines for administrative lapses in AML processes.
What Changed
This is not a regulatory change or new requirement but an enforcement precedent under existing rules: non-compliance with the annual financial crime questionnaire submission, mandated by Article 5(1) of the AML/CFT Law, triggers fines per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a). The CSSF considered all relevant circumstances under Article 8-5(1) to set the €10,000 fine amount and published the sanction nominatively after proportionality assessment per Article 8-6(1), confirming no market stability risks.
Suggested Considerations
Ensure timely submission of annual financial crime questionnaires by 4 April each year (for prior calendar year data); implement calendar reminders and escalation processes for CSSF requests.
Respond promptly to CSSF reminders or queries on AML/CFT compliance to avoid escalation to fines; document any delays with justification evidence.
Review internal AML cooperation protocols, including governance for questionnaire completion, and train staff on Article 5(1) obligations; consider requesting in-person meetings if disputing CSSF demands.
No retroactive actions needed for this case, but conduct gap analysis on reporting workflows to prevent similar breaches.
Key Dates
4 April 2025DEADLINE
- Deadline for submitting the annual financial crime questionnaire covering the year ending 31 December 2024
11 September 2025
- Date CSSF imposed the €10,000 administrative fine on Capitalis Premiere Group for non-submission
9 January 2026
- Date of CSSF publication of the sanction decision
Compliance Impact
Urgency: Medium - This €10,000 fine is modest but publicly names the firm, amplifying reputational risk in Luxembourg's competitive fund domicile; it matters as a clear CSSF signal of zero tolerance for basic cooperation failures in AML, potentially foreshadowing stricter enforcement amid EU AML harmonization pressures. AIFMs face ongoing annual risk, with non-response despite reminders treated as willful breach; firms with weak reporting controls should prioritize fixes to avoid cumulative fines or escalations.
Administrative sanction imposed on the alternative investment fund manager Lion Management (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on Lion Management, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the 4 April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing framework, with direct implications for all AIFMs regarding timely compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations. However, it reinforces critical compliance requirements:
Mandatory Annual Questionnaire Submission: All CSSF-supervised professionals, including AIFMs, must submit an annual questionnaire on financial crime by the specified deadline (in this case, 4 April...
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing establishes a non-negotiable obligation to cooperate with the...
Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but failure to respond to reminders results in administrative fines determined under Article 8-4 of the AML/CFT Law.
Suggested Considerations
*Establish Calendar Controls: Implement firm-wide systems to track the annual financial crime questionnaire deadline (typically 4 April for the prior calendar year)
*Designate Responsible Parties: Assign clear ownership for questionnaire completion and submission to the CSSF, with escalation procedures
*Monitor CSSF Communications: Establish protocols to immediately flag and respond to any CSSF correspondence, including reminders or requests for information
*Document Submission: Maintain evidence of timely submission (timestamps, confirmation receipts) to demonstrate compliance
*Escalate Non-Compliance Immediately: If submission cannot be met by deadline, proactively contact the CSSF to explain delays and request extensions rather than ignoring reminders
Key Dates
4 April 2025DEADLINE
- Deadline for submission of annual financial crime questionnaire for year ending 31 December 2024
11 September 2025
- Date CSSF imposed administrative fine after two reminders went unheeded
9 January 2026
- Publication date of the administrative sanction decision
Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on Max Gain Capital S.à r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but continued non-compliance triggers administrative fines under Article 8-4 of the AML/CFT Law.
Suggested Considerations
regulated entities must:
*Identify Reporting Obligations: Confirm whether your firm is subject to the annual financial crime questionnaire requirement under Article 5(1) of the AML/CFT Law
*Calendar Management: Establish internal processes to ensure questionnaires are submitted by 4 April each year for the preceding calendar year
*Documentation: Maintain records demonstrating timely submission and preserve evidence of compliance
*Escalation Protocol: If unable to meet deadlines, proactively contact the CSSF to request extensions or clarification rather than ignoring reminders
Key Dates
4 April 2025DEADLINE
- Deadline for submission of financial crime questionnaire for the year ending 31 December 2024
Before 11 September 2025DEADLINE
- CSSF issued two reminders to Max Gain Capital after the missed deadline
11 September 2025
- CSSF imposed the €10,000 administrative fine
9 January 2026
- CSSF published the administrative sanction decision
Administrative sanction imposed on the alternative investment fund manager Agriland Management S.A. (“AIFM”)
AI Analysis
The Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial regulator, imposed a **EUR 10,000 administrative fine on Agriland Management S.A.**, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing (AML/CFT) framework and signals heightened scrutiny of compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action that clarifies existing obligations:
Mandatory Annual Reporting: All CSSF-supervised professionals must submit an annual questionnaire on financial crime by 4 April each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, including timely submission of requested...
Enforcement Escalation: The CSSF will issue reminders for non-compliance, but continued failure to respond triggers administrative sanctions without requiring evidence of intentional misconduct.
Suggested Considerations
*Establish Reporting Calendars: Implement systems to track the 4 April annual deadline for financial crime questionnaire submissions
*Designate Responsible Personnel: Assign clear accountability for completing and submitting the questionnaire to the CSSF
*Respond to Regulatory Requests: Do not ignore CSSF reminders; engage proactively, including requesting in-person meetings if clarification is needed
*Document Justifications: If unable to meet deadlines, provide written evidence explaining the delay and proposed remediation timeline
*Monitor Supervisory Communications: Establish procedures to ensure regulatory correspondence is tracked and escalated appropriately
Key Dates
4 April 2025DEADLINE
– Deadline for submission of financial crime questionnaire for year ending 31 December 2024
Before 11 September 2025
– Two reminder notices issued by CSSF to Agriland Management S.A
Administrative sanction imposed on the alternative investment fund manager Bedrock I GP S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Bedrock I GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on timely supervisory compliance. It matters because it demonstrates that even modest fines are pursued for basic reporting lapses, potentially signaling heightened scrutiny on AIFMs' AML processes amid ongoing regulatory focus on financial crime risks.
What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing (AML/CFT Law). Specifically, it reaffirms the mandatory annual submission of the CSSF's financial crime questionnaire ("Questionnaire") by supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, as part of the cooperation duty in Article 5(1).
Suggested Considerations
Immediately verify submission status of the 2024 Questionnaire (or any outstanding); if overdue, submit promptly with justification to mitigate further escalation.
Implement automated calendar alerts and internal workflows for all CSSF reporting deadlines, including annual AML/CFT Questionnaire.
Conduct a compliance gap analysis on cooperation obligations under Article 5(1) AML/CFT Law, documenting reminder responses and evidence retention.
Train senior managers and compliance teams on supervisory interactions, including rights to request in-person meetings before fines.
Review governance for timely escalation of CSSF reminders to decision-makers.
Key Dates
31 December 2024DEADLINE
- Reference period end for the Questionnaire covering financial crime compliance
4 April 2025DEADLINE
- Statutory deadline for Questionnaire submission to CSSF
11 September 2025
- Date of administrative fine imposition (€10,000) after non-submission despite reminders
9 January 2026
- Publication date of the sanction decision by CSSF
Compliance Impact
Urgency: Medium - This is a post-facto enforcement on a past breach (2024 reporting cycle), with the €10,000 fine relatively low, indicating proportionality for a first-time or isolated lapse. It matters as a leading indicator of CSSF's 2025-2026 focus on AML cooperation, with multiple similar AIFM sanctions published simultaneously, risking escalated fines or reputational harm for repeat offenders; firms should prioritize reporting hygiene to avoid public naming, which CSSF deems non-disruptive to markets here.
Administrative sanction imposed on the alternative investment fund manager C5 Haven Cyber GP S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) C5 Haven Cyber GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on the consequences of non-cooperation. It matters because it demonstrates that even modest fines will be levied for procedural lapses, potentially signaling increased scrutiny on timely AML compliance submissions amid broader regulatory focus on financial crime risks.
What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law:
Annual Questionnaire Submission: Supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, must submit an annual financial crime questionnaire...
Fine Provisions: Fines are imposed per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), with amounts determined by relevant circumstances under Article 8-5(1); publication follows Article 8-6(1) after...
Suggested Considerations
Immediate Review: AIFMs and similar entities must verify their internal processes for annual Questionnaire submission, ensuring calendar reminders and automated tracking for 4 April deadlines.
Remediation if Late: Submit overdue Questionnaires promptly with explanations; request in-person meetings if needed, as the sanctioned AIFM failed to do so.
Process Enhancements: Implement escalation protocols for CSSF reminders, designate a senior compliance officer for oversight, and document all submissions/acknowledgments to demonstrate cooperation under Article 5(1).
Training: Conduct firm-wide training on AML/CFT cooperation duties, emphasizing that non-response leads to fines without need for justification.
Key Dates
31 December 2024
- Reference year-end for the financial crime Questionnaire
4 April 2025DEADLINE
- Statutory deadline for submitting the Questionnaire for the year ending 31 December 2024
11 September 2025
- Date CSSF imposed the €10,000 administrative fine after noting non-submission despite reminders
9 January 2026
- Date of CSSF publication of the sanction decision
Compliance Impact
Urgency: Medium - This is a low-value fine (€10,000) for a procedural breach, not involving substantive AML failures like suspicious transactions or sanctions screening delays seen in higher fines (e.g., €185,000 on Rakuten Bank). It matters as a precedent for CSSF's willingness to publicly name-and-shame for basic non-cooperation, potentially escalating to higher penalties for repeats; with publication on 9 January 2026, firms should prioritize 2025/2026 reporting to avoid similar exposure amid CSSF's active enforcement (3192+ sanctions published).
Administrative sanction imposed on the alternative investment fund manager C5 S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager C5 Haven Cyber GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of reporting duties in AML/CFT compliance, serving as a warning to supervised entities on the consequences of administrative delays. It matters because it highlights low-tolerance for even minor procedural lapses, potentially signaling increased scrutiny on annual reporting amid broader AML/CFT priorities.
What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law:
Article 5(1) mandates supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, to cooperate fully with CSSF, including submitting the annual financial crime...
Breach occurred due to non-submission of the 2024 year-end Questionnaire, with fine determined per Articles 8-4(1), 8-4(2)(f), 8-4(3)(a), and 8-5(1).
Publication of the sanction follows Article 8-6(1), after proportionality assessment to avoid market stability risks.
No new rules introduced; reinforces ongoing duty to meet CSSF reporting timelines...
Suggested Considerations
Review and confirm timely submission of all pending or future CSSF financial crime questionnaires; establish automated calendar reminders for annual deadlines (e.g., 4 April for prior year-end data).
Implement escalation protocols for CSSF reminders, ensuring immediate response and submission within days, not weeks.
Conduct internal audit of AML/CFT cooperation obligations, documenting justifications for any delays and preparing evidence for potential CSSF hearings or meetings.
Update compliance policies to prioritize Article 5(1) duties, including training for responsible persons on fine risks under Article 8-4.
For AIFMs: Verify alignment with Article 3(2) of AIFM Law and integrate questionnaire processes into governance frameworks.
Key Dates
4 April 2025DEADLINE
- Deadline for submission of financial crime Questionnaire covering year ending 31 December 2024
11 September 2025
- Date CSSF imposed €10,000 administrative fine on C5 Haven Cyber GP S.à r.l. for non-submission despite reminders
9 January 2026
- Date of CSSF publication announcing the sanction
Compliance Impact
Urgency: Medium - Matters due to CSSF's demonstrated willingness to impose and publicize fines for straightforward reporting failures, even at €10,000, which could escalate for repeat or severe cases; acts as a precedent amid rising AML/CFT enforcement (e.g., larger fines like €214,000 in similar contexts). Firms delaying submissions risk reputational damage from nominative publications under Article 8-6(1), market confidence erosion, and cumulative penalties; proactive remediation now prevents higher scrutiny in upcoming inspections.
Administrative sanction imposed on JTC (Luxembourg) S.A.
AI Analysis
The CSSF imposed a €102,000 administrative fine on JTC (Luxembourg) S.A. on 23 July 2025 for breaches in its professional obligations as a depositary of non-financial assets under the AIFM Law, identified during an on-site inspection from February 2023 to January 2024 covering activities up to December 2022. This enforcement action highlights CSSF's scrutiny of depositary functions, particularly risk assessment and oversight controls, serving as a warning for similar entities to strengthen compliance amid rising supervisory focus on AIFM depositaries.
What Changed
This is an enforcement action, not a regulatory change; it enforces existing requirements under Article 51(1) (1st and 7th indents) and Article 51(2) (1st sub-paragraph, 3rd indent) of the amended Law of 12 July 2013 on AIFMs (AIFM Law), and related provisions like Article 92(1) of Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013).
Suggested Considerations
related entities) must:
Conduct immediate gap analyses on risk assessment processes for AIF strategies and AIFM organization per Article 92(1) CDR 231/2013.
Implement robust verification processes for AIFM compliance with asset delegation rules.
Ensure availability of key documentation and evidence of controls for the depositary function, addressing pre-2022 gaps if applicable.
Develop and test oversight processes, leveraging self-identified improvements and action plans as mitigating factors, as JTC did prior to inspection.
Key Dates
February 2023
January 2024; Period of CSSF on-site inspection on depositary obligations, covering activities up to December 2022
23 July 2025
Date CSSF imposed the €102,000 administrative fine on JTC (Luxembourg) S.A
9 January 2026
Date of official CSSF publication announcing the sanction
Compliance Impact
Urgency: High – This matters due to the fine's size (€102,000), reflecting breach accumulation, severity, and duration, despite JTC's partial remediation; it signals intensified CSSF on-site scrutiny of depositary functions post-2023 inspections, with potential for higher penalties absent proactive controls. Depositaries face elevated enforcement risk, especially with unavailability of evidence pre-2022, urging swift remediation to avoid similar outcomes under Article 51 AIFM Law.
Principles for risk-based supervision: a critical pillar for ESMA’s simplification and burden reduction efforts 09 January 2026 Supervision The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, published today its principles for risk-based supervision . These principles support a common and effective EU-wide supervisory culture and strengthen the EU single market. The principles on risk-based supervision outline key concepts and foundationa...
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address wise[at]wisefestgeldkonto(.)com. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from Wise Europe SA. This is a case of identity theft.
The Federal Financial Supervisory Authority BaFin warns against offers on the website ellis-ag(.)net. According to information available to BaFin, financial or investment services and crypto asset services are being offered on this platform without the required authorisation. According to the current state of knowledge, there is no connection to the Swiss company Ellis AG, Zurich. This is likely to be a case of identity fraud.
Long Form Report – Practical rules concerning the self-assessment questionnaire to be submitted by investment firms – Mission and related reports of the réviseurs d’entreprises agréés (approved statutory auditors)
The Securities and Exchange Commission’s Office of the Advocate for Small Business Capital Formation today published and delivered to Congress its 2025 staff report that serves as a comprehensive and data-rich resource on capital-raising dynamics…
This Market Notice sets out amendment to the schedule for sales in Q1 2026 of gilts held in the Asset Purchase Facility (APF) for monetary policy purposes.
Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations.
What Changed
This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures.
Imprecise investment allocation processes lacking traceability, rendering systems non-operational.
Failure to fulfill conflict of interest identification, prevention, and management obligations.
Deficient AML/CFT systems with inadequate due diligence on fund assets/liabilities.
These align with prior AMF expectations for "honest, fair, and professional" conduct with skill, care, and...
Suggested Considerations
Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules.
Enhance AML/CFT systems: Update risk mapping, procedures, and due diligence on fund assets/liabilities; ensure systematic application.
Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously.
Senior managers: Demonstrate personal oversight via governance records to mitigate attribution of firm breaches.
Audit marketing materials, fee retrocessions, and valuation procedures (e.g., for real estate or experts) against AMF standards.
Key Dates
August 2019
December 2023; - Period of breaches investigated
31 December 2025
- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors
08 January 2026
- Public news release date for the decision
Compliance Impact
Urgency: High - This reflects a pattern of 2025-2026 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc 15 Sep 2025; €400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immediate audits are essential pre-audit cycles, especially with appeals highlighting ongoing litigation risk.
Update of Circular CSSF 24/853 on the Long Form Report (as amended by Circular CSSF 25/870) – Practical rules concerning the self-assessment questionnaire to be submitted by investment firms Mission and related reports of the réviseurs d’entreprises agréés (approved statutory auditors)
AI Analysis
Circular CSSF 26/904 updates Circular CSSF 24/853 (as amended by Circular CSSF 25/870) by introducing a revised Long Form Report (LFR) for investment firms, featuring a digital self-assessment questionnaire (SAQ) and enhanced auditor reports focused on AML/CFT and risk management. This matters because it aligns reporting with CSSF's risk-based supervision under CSSF 4.0, reduces redundancies, applies proportionality based on business models, and mandates digital submission to improve efficiency and data analysis.
What Changed
- Revised LFR Structure: Comprises four parts in a single digital document: (1) yearly SAQ completed by investment firms; (2) descriptive elements verified by approved statutory auditors (REAs); (3)...
Digital Format: Completion and submission via CSSF's online portal, supporting CSSF 4.0 digital strategy for efficient processing.
Proportionality and Scope: Applies individually to investment firms (no consolidated LFR if under CSSF consolidated supervision); focuses on incremental, relevant information tied to business models,...
Enhanced AML/CFT Focus: Requires descriptions of commercial policy, ML/FT risk management, roles/responsibilities, branch/subsidiary/tied agent compliance; REA must assess adequacy of...
REA Responsibilities: Verify/ensure adequacy of SAQ elements, assess descriptions, perform control procedures, and provide assessments on AML/CFT policy implementation across entities.
Suggested Considerations
Investment Firms: Complete and submit the digital SAQ yearly via CSSF portal, providing descriptions of business model, ML/FT risks, commercial policy, monitoring, AML/CFT roles, and entity-level compliance; ensure data on fund transfers (e.g., missing payer/payee info) is included.
REAs/Auditors: Verify SAQ adequacy, assess descriptions, perform corroborative controls, supplement with findings (e.g., AML/CFT audit declarations), independently assess ML/FT risks/organization, and integrate into single LFR document.
General: Review existing processes for proportionality (focus on incremental info); update AML/CFT policies/documentation for branches/subsidiaries/tied agents; prepare for digital submission; document risk assessments thoroughly.
Ongoing: Monitor compliance with related regs like Regulation (EU) 2023/1113 (effective 30 December 2024, per draft bill 8387).
Key Dates
Financial year ending 31 December 2024
- Applicability of revised LFR to all investment firms; submissions begin for this period onward on a yearly basis
No specific submission deadline statedDEADLINE
- Yearly production required via CSSF portal; firms should align with existing annual reporting cycles for auditors (typically post-year-end)
Compliance Impact
Urgency: High - Applies immediately to FY ending 31 December 2024 reports, requiring swift updates to reporting processes, digital tools, and AML/CFT documentation amid CSSF's risk-based shift; non-compliance risks supervisory actions, as LFR directly informs CSSF oversight on key prudential/AML areas with no transition period specified.
ESAs publish joint Guidelines on ESG stress testing 08 January 2026 Guidelines and Technical standards Joint Committee The European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) published today their Joint Guidelines on environmental, social, and governance (ESG) stress testing . These Guidelines provide national insurance and banking supervisors with clear guidance on how to integrate ESG risks into supervisory stress tests, both when using established frameworks and when conducti...
AI Analysis
The European Supervisory Authorities (ESAs)—EBA, EIOPA, and ESMA—published final Joint Guidelines on 8 January 2026 to standardize how national competent authorities (NCAs) integrate ESG risks into supervisory stress testing frameworks for banking and insurance sectors, without mandating new ESG-specific tests. These guidelines promote consistency, long-term methodologies, and common standards across the EU, initially prioritizing climate and environmental risks (physical and transition) before expanding to social and governance factors. They matter for compliance professionals as they shape future supervisory expectations, enhancing resilience assessments and aligning with CRD (Article 100(4)) and Solvency II (Article 304c(3)) mandates, potentially influencing firm-level stress testing preparations.
What Changed
- Standardized Integration of ESG Risks: NCAs must embed ESG risks into existing supervisory stress tests or ad-hoc assessments, using a risk-based materiality assessment to scope relevant risks,...
Methodological and Governance Guidance: Outlines design for ESG-inclusive tests, including objectives (e.g., capital/liquidity robustness, strategy resilience), scenario analysis, and organizational...
No New Obligations: Does not require NCAs to conduct dedicated ESG stress tests, but ensures consistency when they do, improving legal certainty and transparency in approval processes.
Phased Approach: Initial focus on climate/environmental risks, with gradual extension to full ESG coverage based on data and model maturity.
Suggested Considerations
For NCAs: Review and integrate ESG risks into stress testing frameworks via materiality assessments; define objectives, scenarios, and governance; notify ESAs of compliance post-translation; maintain risk-based, phased approach.
For Firms: No direct mandates, but prepare by enhancing internal ESG risk modeling, data collection (especially climate/physical/transition risks), and stress testing capabilities to align with supervisory expectations; conduct voluntary ESG scenario analyses.
General: Monitor NCA implementations, update policies for ESG risk integration in ICAAP/ORSA, and engage in industry feedback on data/methodological gaps.
Key Dates
08 January 2026
Publication of Final Report and Joint Guidelines by ESAs
10 January 2026DEADLINE
Statutory deadline for ESAs to publish guidelines per CRD Article 100(4) and Solvency II Article 304c(3)
Two months after official EU translations (expected ~March/April 2026)DEADLINE
NCAs notify respective ESAs of compliance or intent to comply
01 January 2027
Application date of Joint Guidelines for NCAs
Compliance Impact
Urgency: Medium. While not imposing immediate firm-level requirements, the guidelines signal escalating supervisory focus on ESG risks from 2027, with potential for more frequent/punitive stress tests; firms delaying ESG integration risk capital/liquidity shortfalls in exercises, amplified by improving data availability and EU sustainability push (e.g., CSRD, SFDR). Proactive preparation mitigates future remediation costs and supports strategic resilience.
Pension schemes must now publish transparent data on their performance, costs, and service quality, according to new proposals from the FCA, DWP, and TPR. Pension schemes will need to publish clear data on their performance, costs and quality of service, under proposals announced today by the Financial Conduct Authority (FCA), the Department for Work and Pensions (DWP) and The Pensions Regulator (TPR). If a pension offers poor value, firms and trustees must then fix it by moving savers to bet...
This page contains information about fines published during 2026. The total amount of fines so far is £371,700. Firm or individual finedDateAmountReasonRichard Adam07/01/2026£232,800The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Rule 1.3.3R, Listing Principle 1 and Premium Listing Principle 2.Zafar Khan07/01/2026£138,900The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Ru...
The Securities and Exchange Commission today proposed amendments to the rules that define which registered investment companies, investment advisers, and business development companies qualify as small entities for purposes of the Regulatory Flexibility…
AI Analysis
The SEC proposed amendments on January 7, 2026, to expand the definitions of "small entities" under the Regulatory Flexibility Act (RFA) for registered investment advisers (RIAs), investment companies, and business development companies by significantly raising asset thresholds last updated in 1998. This would increase the number of qualifying small entities, enabling the SEC to better assess regulatory impacts and potentially provide tailored relief like extended compliance timelines during rulemaking. It matters because it could indirectly reduce compliance burdens for mid-sized firms by influencing future SEC rules to minimize disproportionate effects on smaller players.
What Changed
- Raise the RAUM threshold for RIAs to qualify as small entities from $25 million to $1 billion, with conforming changes for control affiliates.
Increase the net asset threshold for investment companies from $50 million to $10 billion.
Update aggregation of related funds from "group of related investment companies" to "family of investment companies" as defined in Form N-CEN for easier identification.
Introduce inflation adjustments to thresholds every 10 years via SEC order, without formal rulemaking.
Make corresponding amendments to Form ADV and rules on continuing hardship exemptions for electronic filing.
Suggested Considerations
Submit public comments by the deadline to influence thresholds, alternatives (e.g., client types, headcount), or exclusions (e.g., funds advised by small RIAs).
Monitor Federal Register for exact publication and comment instructions; review proposed rule and fact sheet on SEC site (https://www.sec.gov/rules-regulations/2026/01/s7-2026-01).
Assess internal status: Calculate current RAUM/net assets against new thresholds to anticipate RFA benefits in upcoming rulemakings.
No immediate compliance changes, as this affects SEC rulemaking process only; prepare for potential indirect impacts via future rules.
Key Dates
January 7, 2026
- SEC issues proposal and press release
60 days after Federal Register publication
- Public comment period closes (publication expected shortly after January 7; exact date TBD, likely March 2026 based on estimates)
No stated adoption date
- Typically at least one year post-comment period under normal processes
Every 10 years post
adoption; - Inflation adjustments to thresholds via SEC order
Compliance Impact
Urgency: Medium. This proposal does not impose direct new requirements or alter existing obligations—it's procedural for SEC's RFA analyses during rulemaking. However, adoption could lead to meaningful indirect benefits for mid-sized RIAs and funds, such as longer compliance phases or reduced burdens in rules on reporting, recordkeeping, or vendor reliance, addressing outdated 1998 thresholds amid industry AUM growth. Firms should engage now via comments to shape outcomes, but no urgent operational changes needed.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
This Statistical Notice 2026/01 from the Bank of England specifies the submission deadline for the Eligible Liabilities Return form, which calculates firms' contributions to the Bank of England Levy for the 2026/27 levy year. It matters because non-compliance risks penalties, late fees, or enforcement actions under the Financial Services (Banking Reform) Act 2013, ensuring timely funding for the Bank's resolution and stability functions. Compliance teams must integrate this into levy reporting calendars to avoid operational disruptions.
What Changed
The notice updates definitions and guidance in the Banking Statistics Yellow Folder, focusing on the deadline for submitting the Eligible Liabilities Return (ELR) form for the 2026/27 levy year. It does not introduce new substantive rules but reinforces procedural requirements for accurate levy base calculations, such as eligible liabilities as defined in section 15 of the Financial Services (Banking Reform) Act 2013. No specific changes to levy rates or methodologies are detailed, but it aligns with ongoing updates to banking statistics reporting.
Suggested Considerations
Review and calculate eligible liabilities as of 31 December 2026 using BoE definitions from the Yellow Folder.
Submit completed ELR form electronically via BoE portal by the specified deadline (likely 31 January 2027).
Retain audit trails, supporting data, and reconciliations for potential PRA/BoE queries.
Update internal systems and controls for levy calculation; notify compliance teams if data gaps exist.
Monitor BoE portal for form updates or extensions.
Key Dates
31 January 2027DEADLINE
- Deadline for submission of Eligible Liabilities Return form for Levy Year 2026/27 (inferred as standard end-January deadline post-levy year-end, aligned with historical BoE notices; confirm via Yellow Folder for exact day)
Compliance Impact
Urgency: High – Missing the submission deadline triggers automatic late penalties (e.g., interest at Bank Rate + 5%) and potential supervisory referrals. This directly impacts prudential reporting obligations, with firms facing cash flow hits from levy payments (historically £200-300m total annually). Prioritize in Q4 2026 planning, as it coincides with year-end reporting under Basel 3.1 transitions.
In the WhatsApp groups, investors are recommended to invest in financial instruments that can then be traded via the platform h5.bluealphasystem(.)net or the aforementioned app.
The Federal Financial Supervisory Authority BaFin warns against offers in WhatsApp groups, which are allegedly operated by Cantor Fitzgerald and led by Leopold Schneider. BaFin is not aware of the existence of this person. According to information available to BaFin, recommendations for the purchase of financial instruments and cryptocurrencies, which can allegedly be traded via CDAfin app, are offered in various WhatsApp groups. According to the current state of knowledge, there is no connec...
On 12 November the PRA hosted a roundtable meeting with Chief Financial Officers (CFOs) of systemically important firms operating in the UK, to discuss Future Banking Data (FBD).
The German Financial Supervisory Authority (BaFin) warns about offers on the website capitalholdings(.)icu. According to information available to BaFin, the unknown operators of the websites are offering banking transactions and financial services without the required authorisation.
The German Financial Supervisory Authority (BaFin) warns about fixed-term deposit offers from the website sicherangelegt(.)de. According to information available to BaFin, the unknown operators of the website are offering banking services, in particular fixed-term deposits, without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers in WhatsApp groups, which are allegedly operated by Baird Capital and led by a Thomas Becker. BaFin is not aware of the existence of this person. According to information available to BaFin, recommendations for the purchase of financial instruments and cryptocurrencies are offered in WhatsApp groups and the so-called Baird Capital Investment Program III is being promoted. According to the current state of knowledge, there ...
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website blauline(.)ai. BaFin has information that this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
The FCA has fined 2 former finance directors for their part in misleading statements being issued by Carillion plc. Richard Adam and Zafar Khan were both aware of serious financial troubles in Carillion’s UK construction business but failed to reflect this in company announcements or alert the Board and audit committee, leading to poor oversight.Mr Adam and Mr Khan have been fined £232,800 and £138,900, respectively. The fines were imposed after Mr Adam and Mr Khan withdrew their challenges t...
Warning Forex and binary options Warning Savings protection The AMF and the ACPR warn the public against several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
The Money Markets Committee is a forum for market participants and authorities to discuss the UK unsecured deposits and funding market and securities lending and repo markets.
ESMA publishes report on cross-border marking of funds including statistics on notifications 06 January 2026 The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published its third report on marketing requirements and marketing communications under the Regulation on cross-border distribution of funds . For the first time, the report includes statistics on notifications of cross-border marketing of funds. Drawing on input from Na...
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
The Securities and Futures Commission (SFC) reprimanded and fined Saxo Capital Markets HK Limited (SCMHK) HK$4 million on 6 January 2026 for breaching regulations by distributing unauthorised virtual asset (VA) funds and VA-related products to retail clients via its online platform from 1 November 2018 to 25 November 2022. This enforcement action underscores the SFC's strict enforcement of suitability, due diligence, and professional investor-only restrictions for complex VA products, serving as a warning to intermediaries about online distribution risks. It matters because it highlights gaps in group-wide protocols and the need for robust VA-specific controls, especially post-SFC circulars mandating PI-only access.
What Changed
This is an enforcement action, not a new rule change, but it reinforces existing SFC circulars requiring VA products (including unauthorised funds and exchange-traded VA derivatives) to be offered exclusively to professional investors (PIs). Key requirements reiterated include: conducting VA-specific product due diligence; assessing client knowledge of VA investments; providing sufficient VA-specific information and warnings; and implementing platform controls to restrict retail access to complex products.
Suggested Considerations
Conduct immediate VA product due diligence using SFC-specific procedures, not just group-wide protocols, to identify unauthorised VA funds and derivatives.
Implement client knowledge assessments for VA investments before transactions, especially for retail clients.
Provide VA-specific warnings and information on platforms and ensure retail access is blocked for PI-only products.
Review and enhance online platform controls for suitability checks on complex products; audit historical VA trades for compliance gaps.
Update internal policies to align with SFC circulars on VA distribution, including staff training on breaches like those at SCMHK.
Key Dates
1 November 2018
25 November 2022; Period of breaches where SCMHK distributed VA products to retail clients in violation of applicable SFC circulars
6 January 2026
Date of SFC announcement, reprimand, and HK$4 million fine imposition on SCMHK
Compliance Impact
Urgency: High – This action signals intensified SFC scrutiny on VA online distribution post-2018 circulars, with fines for suitability failures even years later; firms risk similar penalties (HK$4m here) if platforms lack VA controls, especially amid Hong Kong's growing VA regime. It matters for operational resilience in digital channels, as SCMHK's closure in Hong Kong post-breach amplifies the stakes for ongoing firms.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website bit500(.)eu. BaFin has information that the operators are offering banking business and/or financial services on this website without the required authorisation. The operators are not supervised by BaFin.
ESAs’ Joint Board of Appeal rules on reimbursement of costs in an appeal brought by NOVIS Insurance Company against the European Insurance and Occupational Pensions Authority (EIOPA) 05 January 2026 Board of Appeal Joint Committee The Joint Board of Appeal (“The Board”) of the European Supervisory Authorities (ESAs) – the EBA, ESMA, EIOPA – has issued its decision on costs arising in the appeal brought by NOVIS Insurance Company, NOVIS Versicherungsgesellschaft, NOVIS Compagnia di Assicurazio...
The Swiss Federal Council adopted a new ordinance (RS 196.127.85) on 5 January 2026, mandating the immediate freezing of all assets in Switzerland belonging to Nicolás Maduro and 36 associated persons, under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA). This precautionary measure prevents asset outflows amid Venezuela's political upheaval, complementing existing sanctions since 2018, and enables future mutual legal assistance for potential restitution to the Venezuelan people. It matters for Swiss financial institutions as it imposes immediate reporting and freezing obligations with severe penalties for non-compliance.
What Changed
- Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously...
Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA...
Duration: The freeze is valid for four years until 4 January 2030, unless revoked earlier.
Legal basis: Enacted under Article 3 FIAA as a "freeze for mutual legal assistance" post-political change, distinct from but additive to 2018 Venezuela sanctions under the Embargo Act.
Penalties: Non-compliance with freezing may result in up to three years' custody; reporting violations up to CHF 250,000 fine.
Suggested Considerations
Screen and identify: Immediately review client lists, accounts, and transactions against the ordinance annex listing 37 persons; use FINMA's ordinance publication and Classified Compilation of Federal Law.
Freeze assets: Block all assets (funds, securities, real estate, etc.) of listed persons; prevent any transfers, payments, or dealings.
Report to MROS: Notify MROS of frozen assets or relevant knowledge without delay, following FIAA protocols; include details on asset nature, value, and location.
Internal updates: Update compliance systems, screening tools, and PEP/ sanctions databases; train staff on FIAA obligations.
Document compliance: Maintain records of screening, freezes, and reports for potential FINMA audits; monitor for updates via FINMA and Federal Council releases.
Key Dates
5 January 2026, 11 a.m.DEADLINE
Ordinance enters into force; immediate asset freezing and reporting required
4 January 2030
Asset freeze expires after four years, unless extended or revoked
Compliance Impact
Urgency: Critical. This demands immediate action as the freeze took effect on 5 January 2026 at 11 a.m., with custodial penalties up to three years for failures; given today's date (25 January 2026), firms must confirm compliance now to avoid fines up to CHF 250,000 or enforcement. It heightens AML/sanctions risks amid Venezuela's volatility, overlapping with existing Embargo Act measures, and requires rapid system updates for PEPs.
ESMA launches selection of Consolidated Tape Provider for OTC derivatives 05 January 2026 MiFID - Secondary Markets Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, is launching the first selection procedure for the Consolidated Tape Provider (CTP) for over the counter (OTC) derivatives. Entities interested to apply are encouraged to register and submit their requests to participate in the selection procedure by 11 February 20...
AI Analysis
ESMA has launched the first selection procedure for a **Consolidated Tape Provider (CTP) for OTC derivatives**, with applications due by 11 February 2026 and a decision expected by early July 2026. This initiative establishes a critical market infrastructure component to enhance transparency and efficiency in the EU's OTC derivatives market by consolidating post-trade data into a single, continuous electronic stream.
What Changed
The regulatory framework introduces several substantive requirements:
CTP Mandate: The selected provider will consolidate post-trade data from trading venues and other data contributors into a unified electronic stream, enabling market participants to access accurate,...
Data Scope: The CTP will collect and disseminate OTC derivatives data in accordance with ESMA's Final Report on transparency for derivatives, with specific technical standards governing pre- and...
Technical Standards: ESMA has finalized regulatory technical standards (RTS) prescribing data quality requirements for CTPs and data contributors.
Implementation Date: All derivatives-related changes, including amendments to RTS 2 (derivatives transparency) and the OTC derivatives CTP data requirements, are scheduled for 1 March 2027.
Suggested Considerations
*For prospective CTP applicants:
*For trading venues and data contributors:
trade OTC derivatives data to the selected CTP from 1 March 2027
minute maximum delay for real-time dissemination
*For market participants:
Key Dates
11 February 2026DEADLINE
– Deadline for entities to register and submit requests to participate in the selection procedure
Early July 2026
– ESMA to adopt reasoned decision on selected applicant
1 September 2026
– Mandatory use of new OTC derivatives identifying reference data (Commission Delegated Regulation (EU) 2025/1003)
1 March 2027
– Single application date for all derivatives-related changes: amendments to RTS 2, Package Order RTS, and OTC derivatives CTP data requirements
The FCA has opened an enforcement investigation into The Claims Protection Agency Limited (TCPA) following concerns about its advertising and sales tactics in relation to potential motor finance claims. The FCA is investigating what customers were told about the amount of redress they might obtain, whether they were told they could make a claim for free, and whether they were pressurised to sign up.Announcing the investigation allows TCPA customers to consider their options.The FCA has not re...
The Berne Financial Services Agreement (BFSA) is a mutual recognition agreement between the UK and Switzerland, effective from 1 January 2026. This agreement enhances cross-border market access for financial services between the two countries.
Inform and remind insurers of MAS Notice 126 requirements and expectations on ORSA report submissions.
AI Analysis
This MAS circular ID 01/26, published on 02 January 2026, addresses observed lapses in ORSA report submissions under MAS Notice 126, specifically reminding insurers not to fully rely on group-level ORSA reports to meet local requirements. It matters because non-compliance risks regulatory scrutiny, enforcement actions, and weakened enterprise risk management (ERM) frameworks essential for solvency and risk oversight in Singapore's insurance sector.
What Changed
No new regulatory changes are introduced; this is a reminder and clarification of existing MAS Notice 126 requirements on ORSA submissions. Key emphasis: Insurers cannot fully rely on group ORSA reports—local entities must produce their own tailored ORSA reports reflecting entity-specific risks, time horizons, and business strategies. It reinforces ORSA as a core ERM tool involving own risk assessment, solvency projections, and stress testing (e.g., macroeconomic scenarios).
Suggested Considerations
Review current ORSA processes to confirm entity-specific reports are produced, not mere group report adoptions.
Conduct gap analysis against Notice 126: Ensure ORSA covers risk identification, solvency assessment, stress testing (e.g., macroeconomic, liquidity), and forward-looking horizons aligned with business planning.
Update board and senior management oversight of ERM, documenting rationale for any group influences while maintaining local tailoring.
Submit ORSA reports to MAS as per ongoing Notice 126 timelines (typically annually); remediate any past lapses via voluntary disclosure if needed.
Enhance internal controls, training, and audit trails for ORSA compliance to avoid future observations.
Key Dates
19 February 2021
19 March 2021; - Consultation period on proposed revisions to Notices 124, 125, and 126
30 September 2022
- Last revision of MAS Notice 126 on ERM, including ORSA guidelines (effective 01 January 2023)
30 September 2022
- MAS response to consultation feedback on ERM revisions
02 January 2026
- Publication of ID 01/26 circular reminding of ORSA submission requirements under Notice 126
Compliance Impact
Urgency: High – Immediate attention required as the circular flags "several insurers" with lapses, signaling MAS active monitoring and potential targeted inspections or penalties. Matters for solvency regime integrity; non-compliance undermines ORSA's role in capital adequacy and could trigger supervisory interventions amid evolving risks like liquidity and macro stresses.