July 2026 Regulatory Updates

What Changed

• - Introduces principles‑based requirements for vertically integrated market structures involving affiliations between derivatives clearing organizations, designated contract markets, swap execution...
• Amends Part 37 to set additional governance, conflict‑management, and structural requirements for swap execution facilities where the SEF is affiliated with an intermediary or trading entity.
• Amends Part 38 to impose enhanced conflict‑of‑interest and self‑regulatory safeguards for designated contract markets that are affiliated with futures commission merchants or proprietary trading...
• Amends Part 39 to clarify and strengthen requirements on derivatives clearing organizations in group structures where the DCO is affiliated with intermediaries or other market participants, including...
• Amends regulation 1.52 (accounts and records; FCM supervisory requirements) to reflect the heightened expectations placed on futures commission merchants that are part of vertically integrated...

Suggested Considerations

• Identify and map all affiliate relationships involving CFTC‑regulated entities within your group (DCO, DCM, SEF, FCM, SD/MSP, trading entities, market makers) and document how roles and control relationships could create actual or perceived conflicts of interest.
• Conduct a gap analysis of existing governance, conflicts‑of‑interest, information‑barrier, and supervision frameworks against the anticipated principles‑based expectations for vertically integrated structures under Parts 37, 38, 39 and regulations 1.52 and 1.55.
• Review and, where necessary, enhance board‑level and committee‑level oversight arrangements for affiliated entities to ensure independent decision‑making on listing, clearing, rule enforcement, membership, and client treatment where affiliates are involved.
• Assess current customer risk disclosures, including those required under regulation 1.55 for FCMs, to determine whether affiliate relationships and related conflicts are adequately described, and prepare draft revisions that could be implemented if the new requirements are finalized.
• Engage legal, compliance, and business stakeholders for each affected entity (DCO, DCM, SEF, FCM, trading entity) to prepare a coordinated comment letter to the CFTC explaining operational impacts, potential unintended consequences, and recommendations on specific rule language.

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/9274-26
• [2] reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=30...
• [3] cftc.gov/LawRegulation/DoddFrankAct/Dodd-FrankProposedRul...
• [4] comments.cftc.gov/FederalRegister/Proposed.aspx?Type=List...
• [5] public-inspection.federalregister.gov/2023-28745.pdf
• [6] content.next.westlaw.com/practical-law/document/If6afd4b4...
• [7] public-inspection.federalregister.gov/2012-00935.pdf?1329...
• [8] cftclaw.com

What Changed

• - The Supplemental Guidance formally sets out the circumstances and general principles the CBI’s Prohibition Decision Maker will consider when deciding whether to impose a Prohibition Notice,...
• The guidance clarifies the decision-making framework for the nature, scope and duration of a prohibition, including whether it applies to specific controlled functions (CFs), parts of CFs, or any...
• The guidance codifies how a Prohibition Notice becomes effective, establishing that effectiveness arises either through a written agreement between the CBI and the individual concerned (prohibition...
• The guidance explains the three mechanisms by which a Prohibition Notice may be terminated or cease to have effect: (1) termination of a prohibition agreement by the CBI, (2) revocation of a...
• The Supplemental Guidance sets out CBI’s approach to requests by prohibited persons to terminate a prohibition agreement, including the factors CBI will assess when considering whether to lift or...

Suggested Considerations

• Update Fitness and Probity policies, procedures, and governance frameworks to explicitly address the possibility of Prohibition Notices, including criteria for escalation, internal investigation standards, record‑keeping, and engagement protocols with the CBI during prohibition-related processes.
• Ensure Board and senior management, including PCF role holders and HR/legal/compliance leads, are briefed on the new prohibition guidance, the publication policy, and the enhanced transparency of outcomes so that they understand the personal and organisational consequences of F&P failings.
• Strengthen documentation and retention of supervisory, disciplinary, compliance and performance records for CF and PCF holders to ensure that, if a prohibition is contemplated, the firm can provide a coherent, contemporaneous factual record to the CBI and the individual.
• Review and, where necessary, amend individual accountability frameworks (including Statements of Responsibilities and role profiles) to clearly delineate responsibilities, seniority and CF scope, given that these factors now explicitly influence the nature, scope and duration of any prohibition.
• Embed procedures to manage individuals who become subject to proposed or actual Prohibition Notices, including immediate role restrictions, notification workflows, communication protocols to boards and key stakeholders, and contingency planning for business continuity.

Key Dates

References

• [1] centralbank.ie/regulation/how-we-regulate/fitness-probity
• [2] centralbank.ie/docs/default-source/regulation/how-we-regu...
• [3] centralbank.ie/docs/default-source/regulation/how-we-regu...
• [4] centralbank.ie/regulation/how-we-regulate/fitness-probity...
• [5] cgi.org.uk/membership/branches-regions/ireland/agenda/iri...
• [6] maples.com/wp-content/uploads/2025/04/Central-Bank-of-Ire...
• [7] centralbank.ie/docs/default-source/regulation/how-we-regu...
• [8] maples.com/knowledge/updates-to-the-irish-fitness-and-pro...

What Changed

• - Issuers domiciled in Germany with securities admitted to trading on an organised market in Germany must publish an announcement (“Hinweisbekanntmachung”) specifying the exact date and internet...
• The announcement on annual financial information must be published no later than four months after the end of each financial year and must be issued before the first public availability of the...
• Annual financial information must be made publicly available on the internet in addition to its disclosure in the Company Register (Unternehmensregister), and the announcement obligation relates...
• Issuers must publish a half‑yearly financial report no later than three months after the end of each reporting period.
• Failure to publish financial reports or the required announcements, or failure to do so within the prescribed periods, constitutes a contravention of the WpHG and exposes the issuer to administrative...

Suggested Considerations

• Map all WpHG‑related periodic reporting obligations (annual, half‑yearly, and any interim or ad‑hoc requirements) into a documented compliance calendar with responsible owners and system reminders well ahead of statutory deadlines.
• Implement a formal procedure to prepare, approve, and publish “Hinweisbekanntmachungen” that clearly specify the date and internet address of annual financial information, ensuring publication before the first public availability of the annual report and within four months of financial year‑end.
• Establish controls to guarantee that annual financial information is published both in the Company Register and on the issuer’s website, and that these publications are synchronised with the required announcements.
• Design and enforce a process for producing and publishing half‑yearly financial reports within three months after the end of each reporting period, including clear timelines for drafting, audit/review (where relevant), management approval, and technical website publication.
• Conduct a gap analysis of current financial reporting and disclosure procedures against WpHG requirements to identify any missing steps, unclear responsibilities, or weaknesses in escalation mechanisms for imminent deadline breaches.

Key Dates

References

• [1] bafin.de/SharedDocs/Veroeffentlichungen/DE/Massnahmen/40c...
• [2] bafin.de/SharedDocs/Downloads/DE/Angebotsunterlage/Leo_In...
• [3] bafin.de/EN/home_node_en.html
• [4] northdata.com/Leo%20International%20Precision%20Health%20...
• [5] finanznachrichten.de/nachrichten-2026-03/68026196-leo-int...
• [6] globenewswire.com/news-release/2026/05/22/3300302/0/en/le...
• [7] globenewswire.com/news-release/2026/06/12/3311244/0/en/le...

What Changed

• - The PRA finalises amendments to the Reporting Part of the PRA Rulebook to implement post‑implementation clarifications, consistency improvements and data quality enhancements to Solvency UK...
• Reporting and disclosure templates and instructions are amended (including XBRL taxonomy changes) to reflect the refined Solvency UK reporting framework and consequential changes from the Own Funds...
• The PRA confirms transfer of the Matching Adjustment Asset and Liability Information Return (MALIR) templates from Excel to XBRL submission format, to be incorporated into the single insurance...
• The PRA updates Supervisory Statement 7/18 – Solvency II: Matching adjustment, including changes to the Matching Adjustment supplementary information form under Insurance rule permissions and...
• The PRA introduces a new collection of projected Financial Services Compensation Scheme (FSCS) liabilities data from third‑country branch undertakings to support enhanced branch supervision.

Suggested Considerations

• Review and map existing Solvency UK reporting processes, systems and controls against the amended Reporting Part of the PRA Rulebook and updated templates and instructions to identify required changes for year‑end 2026.
• Engage with finance, risk and actuarial functions to implement the new XBRL‑based MALIR submission process, including testing data extraction, validation and filing workflows aligned to the updated insurance taxonomy.
• Update internal Own Funds policies, classification procedures and governance documentation to reflect removal of specified permission requirements and the amended Own Funds Part and Group Supervision Part of the PRA Rulebook.
• Reconfigure regulatory reporting infrastructure and vendor solutions to adopt the single updated PRA insurance XBRL taxonomy, ensuring all Solvency UK quantitative reporting templates and narrative disclosures are correctly mapped and validated.
• For third‑country branch undertakings, design and implement processes to calculate and report projected FSCS liabilities data in line with PRA expectations, including data sourcing, modelling assumptions and internal review controls.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/regulatory-repo...
• [2] skadden.com/insights/publications/2025/10/chapter-9-solve...
• [3] bankofengland.co.uk/prudential-regulation/key-initiatives...
• [4] bankofengland.co.uk/prudential-regulation/publication/202...
• [5] nortonrosefulbright.com/en/knowledge/publications/8dc8438...
• [6] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [7] bankofengland.co.uk/prudential-regulation/publication/202...
• [8] bankofengland.co.uk/prudential-regulation/publication/202...

What Changed

• - Lloyd’s syndicates would be removed from the scope of Internal Model Output (IMO) reporting to the PRA via amendments to SS25/15 (Solvency II: Regulatory reporting, internal model outputs),...
• SS26/15 (Solvency II: ORSA and the ultimate time horizon – non‑life firms) would be amended to clarify that the option to use IMO outputs in ORSA reporting applies only to firms still required to...
• The IM.03 reporting instructions (section “General Comment”) would be amended to align the reporting template guidance with the removal of Lloyd’s syndicates from IMO reporting, avoiding inconsistent...
• SS25/15 and SS26/15 would receive non‑substantive drafting updates to improve clarity and consistency, remove outdated EU references, and align terminology and framing with the PRA’s current Solvency...
• For 2026 year‑end, Lloyd’s syndicates would no longer be required to submit IMOs to the PRA, with supervisory reliance instead on other Solvency UK reporting streams and data provided through the...

Suggested Considerations

• Review existing IMO reporting processes and systems for Lloyd’s syndicates and prepare to decommission IMO submissions to the PRA for 2026 year‑end, ensuring all dependent internal reports and controls are updated.
• Map all uses of IMOs in ORSA processes and supervisory reporting for non‑life firms, and update ORSA documentation and methodologies to reflect that the IMO‑based option applies only to firms that remain in scope of IMO reporting.
• Update internal reporting manuals and instructions for IM.03 and related Solvency UK templates to reflect the revised PRA wording, removal of outdated EU references, and alignment with the PRA’s Solvency UK framework.
• For Lloyd’s managing agents and syndicates, confirm alternative data channels and reporting obligations to the PRA (via Lloyd’s or Solvency UK templates) that will replace the supervisory reliance previously placed on IMO reporting.
• Conduct an inventory of non‑UK covered bonds currently recognised as Level 2A HQLA in LCR calculations and assess how the proposed amendments to Article 11(1)(d)(ii) would change eligibility, haircuts, or caps from 1 January 2027.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] bankofengland.co.uk/prudential-regulation/low-impact-amen...
• [4] kpmg.com/xx/en/our-insights/regulatory-insights/uk-regula...
• [5] bankofengland.co.uk/prudential-regulation/regulatory-dige...
• [6] bankofengland.co.uk/prudential-regulation/publication/202...
• [7] finreg.aoshearman.com/UK-PRA-consults-and-makes-low-impac...
• [8] media.milliman.com/v1/media/edge/images/millimaninc5660-m...

What Changed

• - Financial investment advisors must not conduct non‑guaranteed placement services (service de placement non garanti) such as actively seeking subscribers on behalf of issuers, unless they hold the...
• Firms that present themselves as independent advisors must not receive remuneration (direct or indirect) from product issuers whose instruments they recommend, unless permitted under MiFID II/French...
• When claiming independence, firms must provide accurate, clear and non‑misleading information on the nature of their independence, remuneration model, and any relationships with issuers or...
• Financial investment advisors must issue a written suitability statement formalising the investment advice provided, setting out the client’s profile, the recommended products, and the reasons why...
• Pre‑contractual documentation must include full information on costs, fees and remuneration, covering both the advised investment and any business introducer partners; omission of these disclosures...

Suggested Considerations

• Review the firm’s regulatory status (CIF versus investment services provider) and ensure that any placement or capital‑raising activities are within authorised limits; discontinue or re‑authorise any non‑guaranteed placement services currently carried out under CIF status.
• Conduct a comprehensive mapping of all services and activities (advisory, marketing, introductions, distribution) to confirm that none constitute regulated investment services (e.g., non‑guaranteed placement) without the requisite AMF/ACPR authorisation.
• Inventory all remuneration flows from issuers and third parties, including commissions, retrocessions and fees, and assess whether they are compatible with any independence claims and MiFID II inducements rules; remove or re‑label “independent” branding where issuer remuneration is received.
• Update client‑facing documentation (engagement letters, brochures, websites, emails) to provide clear, accurate and non‑misleading information on adviser independence, remuneration model, and any relationships with issuers or introducers.
• Implement or enhance procedures to ensure a written suitability statement is produced and delivered to clients for each piece of investment advice, documenting client profile, recommended products and rationale; integrate this into advisory workflows and record‑keeping.

Key Dates

References

• [1] amf-france.org/en/news-publications/news-releases/enforce...
• [2] amf-france.org/en/news-publications/news-releases/enforce...
• [3] amf-france.org/en/sujets/sanctions-settlements
• [4] amf-france.org/en/news-publications/publications/reports-...
• [5] financemagnates.com/forex/amf-fines-a-financial-investmen...
• [6] pideeco.be/regwatch/la-commission-des-sanctions-de-lamf-s...
• [7] amf-france.org/sites/institutionnel/files/pdf/56719/en/A_...
• [8] finascope.fr/english/communiques/

What Changed

• - Licensed corporations must ensure that firewall protection and network monitoring are implemented and effective across critical infrastructure, including file servers, domain controllers, email...
• Licensed corporations must maintain up‑to‑date operating systems and antivirus software, avoiding end‑of‑life or unpatched environments that materially increase vulnerability to ransomware and other...
• Firms must enforce strong user access and privileged account controls, including robust administration of system admin accounts, least‑privilege access models, periodic reviews of access rights, and...
• Firms must implement secure password management practices, prohibiting the storage of credentials in unencrypted files and enforcing strong password policies and technical controls for credential...
• Remote access must be subject to strict controls, including secure configuration of VPN or other remote access solutions, need‑to‑have access principles, and monitoring for unusual or unauthorized...

Suggested Considerations

• Conduct a comprehensive cybersecurity risk assessment and control gap analysis across all critical systems, including trading platforms, email servers, domain controllers, file servers, and accounting systems.
• Implement and regularly review firewall configurations and network monitoring tools to ensure effective protection and detection capabilities for internal and external network traffic.
• Upgrade all operating systems and antivirus software to supported, fully patched versions and establish formal patch and vulnerability management procedures with defined timelines and testing steps.
• Establish and enforce robust user access management policies, including least‑privilege access, periodic recertification of user and privileged accounts, and logging and monitoring of admin activities.
• Implement secure password management solutions and technical controls, eliminating unencrypted storage of credentials and enforcing strong password complexity, rotation, and multi‑factor authentication where applicable.

Key Dates

References

• [1] apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announce...
• [2] fxnewsgroup.com/tag/luk-fook/
• [3] apps.sfc.hk/edistributionWeb/api/circular/list-content/ci...
• [4] charltonslaw.com/legal/newsletters/574/sfc-enforcement-ac...
• [5] davispolk.com/insights/client-update/hong-kong-sfc-calls-...
• [6] apps.sfc.hk/edistributionWeb/gateway/EN/circular/intermed...
• [7] sfc.hk/-/media/EN/files/IS/publications/Cybersecurity-the...
• [8] reuters.com/legal/litigation/hong-kong-securities-regulat...

What Changed

• - The FCA expects firms to regularly assess, test, understand, and evidence the outcomes retail customers are receiving under the Consumer Duty.
• Firms should use monitoring to identify whether any group of retail customers is experiencing different outcomes from another group for the same product and understand why those differences exist.
• Monitoring frameworks should define what good outcomes look like in practice and translate those outcomes into measurable indicators tied to the customer journey.
• Firms should not rely on broad or high-level MI alone; they must use information to challenge performance, identify risks, and drive improvements.
• Firms should be able to explain why metrics and tolerances were chosen and whether any actions taken have been tested and shown to reduce harm or friction.

Suggested Considerations

• Firms must establish and maintain a documented outcomes monitoring framework that defines good and poor customer outcomes for each relevant product or service.
• Firms must map metrics to the full customer journey, including product design, communications, customer support, and distribution arrangements.
• Firms must collect MI that can identify poor or potentially poor outcomes, root causes, and emerging risks before harm crystallises.
• Firms must document the rationale for each metric, threshold, and tolerance, including why those measures are appropriate for the customer population and product.
• Firms must maintain a clear audit trail linking MI, governance review, decisions, remediation, and outcome improvement testing.

Key Dates

References

• [1] fca.org.uk/publications/multi-firm-reviews/insurance-mult...
• [2] fca.org.uk/publications/corporate-documents/our-rule-revi...
• [3] tlt.com/insights-and-events/insight/the-fcas-expectations...
• [4] handbook.fca.org.uk/handbook/prin2a/prin2as9
• [5] youtube.com/watch?v=qEc9w7_EBsc
• [6] fca.org.uk/publication/finalised-guidance/fg22-5.pdf
• [7] square4.com/outcomes-monitoring-in-a-consumer-duty-world/
• [8] adoreboard.com/fca-consumer-duty-outcomes/

What Changed

• - Asset managers must maintain and apply documented procedures and controls to identify whether proposed private fund arrangements or transactions are dubious, including where structures are...
• Where a proposed arrangement or transaction is assessed as dubious, asset managers may only proceed once they are satisfied that concerns and red flags have been sufficiently addressed and evidenced.
• Fund managers are expected to exercise independent investment discretion and cannot rely solely on investor‑driven proposals, especially from influential client personnel such as chief investment...
• Asset managers must ensure that all fund investments comply with the fund’s stated investment restrictions and align with its stated investment objectives, with documented controls to verify...
• Firms must implement effective measures to identify, manage, and continuously monitor the risks to which private funds are exposed, including counterparty, concentration, structural, and...

Suggested Considerations

• Review and update private fund governance frameworks to ensure investment approvals require independent investment discretion, documented due diligence, and explicit challenge of investor‑driven proposals, particularly those originating from client senior management.
• Implement or enhance written procedures to identify “dubious arrangements”, including criteria such as unnecessary structural complexity, unclear commercial rationale, additional costs or risks, related‑party exposure, and potential concealment of asset movements or connected transactions.
• Establish a mandatory escalation and approval process for complex or investor‑driven transactions, requiring risk, compliance, and senior management sign‑off before execution and documented reasoning for proceeding.
• Conduct a gap analysis of all existing private funds to confirm that current and past investments comply with the funds’ investment restrictions and stated objectives, and remediate any breaches including client notification and corrective actions where appropriate.
• Strengthen risk management frameworks for private funds by defining key risk types, setting monitoring thresholds, and implementing periodic risk reporting to senior management and the board.

Key Dates

References

• [1] caproasia.com/2023/08/24/hong-kong-sfc-fines-china-indust...
• [2] sfc.hk/en/Regulatory-functions/Enforcement/Disciplinary-p...
• [3] sfc.hk/-/media/EN/files/COM/Reports/Enforcement-Reporter_...

What Changed

• - Firms conducting Type 1, 4 or 7 regulated activities are expected to maintain both pre‑trade and post‑trade surveillance capable of detecting wash trades and other manipulative patterns, rather...
• Pre‑trade interception controls that depend primarily on manual intervention (e.g. dealer intervention after alerts) are deemed inadequate where the controls allow suspicious trades to proceed until...
• Surveillance logic must treat multiple suspicious trades in the same client account on the same day as separate events, rather than aggregating them into one “instance,” to ensure repeated misconduct...
• Trade surveillance tools and procedures must be capable of detecting wash trades across a wide universe of instruments, including both equities and structured products such as warrants.
• SFC has reaffirmed that failure to maintain adequate and effective internal controls to monitor and detect wash trades constitutes a breach of the SFC Code of Conduct and is considered contrary to...

Suggested Considerations

• Review existing trade surveillance frameworks (both pre‑trade and post‑trade) to ensure they can reliably identify wash trades, including same‑account and related‑account trades with no change in beneficial ownership.
• Implement or enhance automated pre‑trade controls that can detect and automatically block or hold suspected wash trades before execution, rather than relying primarily on manual dealer intervention after the fact.
• Re‑design alert logic so that each suspicious wash trade or pair of trades is counted as a separate event, including multiple events in the same client account on the same day, and ensure escalation thresholds reflect this.
• Calibrate surveillance parameters to cover all relevant product types, including Hong Kong‑listed stocks, warrants and other structured products commonly used by clients.
• Document and update internal policies and procedures to explicitly prohibit wash trades, define wash trading typologies, and describe detection, escalation and blocking processes.

Key Dates

References

• [1] sfc.hk/web/files/ER/PDF/14PR93_statement.pdf
• [2] webb-site.com/codocs/SFC041125b.pdf
• [3] webb-site.com/codocs/SFC051024.pdf
• [4] apps.sfc.hk/edistributionWeb/api/news/list-content?refNo=...
• [5] financemagnates.com/forex/regulation/hong-kong-listed-bro...
• [6] prudent.hk/post/sfc-issues-restriction-notice-to-a-broker...
• [7] sfc.hk/-/media/EN/files/LSD/Gazette/GN-2652-of-2025-Eng.p...
• [8] sfc.hk/en/Regulatory-functions/Enforcement/Disciplinary-p...

What Changed

• (Strictly speaking this is an enforcement case rather than a rule change, but it effectively clarifies regulatory expectations and evidences enforcement priorities.)
• Licensed corporations must treat discrepancies between a client’s declared financial profile and purported asset holdings as material red flags, triggering enhanced KYC,...
• Firms must independently verify documents purportedly issued by other brokers, especially when used as proof of holdings for sell orders, and must not rely on such documents at face value when they...
• Licensed corporations are expected to apply risk-based AML/CFT controls to securities sell orders where there is a risk that the client may not beneficially own the assets, or where forged/false...
• Firms must report suspected fraudulent or deceptive conduct by clients to the SFC (and, where applicable, to JFIU) without delay, even where the misconduct appears confined to a single transaction or...

Suggested Considerations

• Review and update client onboarding procedures to ensure that inconsistencies between clients’ declared financial profiles and claimed asset holdings are systematically identified, documented, and escalated for enhanced due diligence before any orders are executed.
• Implement controls requiring independent verification (e.g. direct confirmation or reliable third‑party checks) of statements and documents purportedly issued by other brokers when these are used to evidence holdings for sell orders.
• Update AML/CFT policies and procedures under AMLO and the SFC Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Corporations) to explicitly cover handling of suspected forged documents and false information supplied by clients.
• Establish or reinforce a formal process for promptly reporting suspected fraudulent, deceptive, or market abusive conduct by clients to the SFC, and where appropriate to JFIU, including clear internal thresholds, escalation paths, and record‑keeping.
• Conduct a gap analysis of existing red flag indicators to ensure they cover situations where the size or nature of client holdings is incommensurate with the client’s stated income, net worth, occupation, or overall risk profile.

Key Dates

References

• [1] webb-site.com/codocs/SFC060328.pdf
• [2] kucoin.com/news/flash/hong-kong-sfc-fines-victory-securit...
• [3] sfc.hk/en/Regulatory-functions/Enforcement/Disciplinary-p...
• [4] www1.hkexnews.hk/listedco/listconews/gem/2018/0716/gln201...
• [5] sfc.hk/-/media/EN/files/COM/QR-Reports/202110-12/2eEnforc...
• [6] chinadailyhk.com/hk/article/353041
• [7] sfc.hk/-/media/EN/files/COM/Reports/Enforcement-Reporter_...

What Changed

• - The CFTC has extended the comment deadline on the RFC regarding 24/7 trading of standard futures contracts and perpetual contracts in energy markets by 30 days, moving the due date to 26 August...
• The RFC focuses on the extension of standard futures contracts, including energy futures, to a 24/7 trading schedule while keeping fixed expirations but allowing potentially material economic changes...
• The RFC separately focuses on the listing and regulation of perpetual contracts that reference physically delivered or storable energy commodities, such as crude oil, and that have no fixed...
• The Commission has added additional questions to the original RFC to probe market integrity, price formation, operational resilience, customer protections, and risk management implications of 24/7...
• The RFC builds on and is informed by the CFTC’s May 29, 2026 coordinated actions on perpetual contracts and 24/7 trading in digital commodities, including the Policy Statement on perpetual contracts,...

Suggested Considerations

• Identify and convene an internal cross‑functional working group (trading, risk, operations, compliance, legal, and IT) to assess potential impacts of 24/7 trading and energy perpetual contracts on your firm’s business model and control environment.
• Perform a gap analysis of current trading, clearing, surveillance, margin, and risk management frameworks against the operational and risk expectations articulated in recent CFTC staff advisories and policy statements on 24/7 markets and perpetual contracts.
• Draft and submit a data‑driven comment to the CFTC by 26 August 2026 addressing the RFC questions most relevant to your activities, including empirical analysis of liquidity, price formation, manipulation risk, funding rate behavior, and customer protection in energy derivatives.
• Review and update internal policies and procedures for trade surveillance, market abuse monitoring, and manipulation detection to address continuous 24/7 trading windows and any contemplated use of energy perpetual contracts.
• Assess whether current staffing models, systems support, and incident‑response processes can support 24/7 trading or clearing operations, and document enhancements or mitigations that would be needed to maintain operational resilience.

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/9271-26
• [2] dentonscrypto.com/cftc-issues-staff-advisory-setting-expe...
• [3] bloomberg.com/news/articles/2025-04-21/cftc-seeks-input-o...
• [4] bloomberg.com/news/articles/2026-06-23/cftc-seeks-input-o...
• [5] wilmerhale.com/-/media/files/shared_content/editorial/pub...
• [6] sidley.com/en/insights/newsupdates/2025/04/the-us-cftc-lo...
• [7] complianceconcourse.willkie.com/articles/cftc-releases-pr...
• [8] jdsupra.com/legalnews/cftc-advances-framework-for-perpetu...

What Changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the themes “European culture” and “Rivers and birds.”
• The ECB has opened an online public survey to gather feedback on the proposed designs.
• The survey is open until 21 September 2026.
• The ECB Governing Council is expected to make the final design decision around the end of 2026.
• The current publication does not impose any immediate compliance obligation on firms; it is a consultation and design-selection step, not an enacted regulatory rule.

Suggested Considerations

• Review the ECB consultation materials and assess whether your firm has any direct operational exposure to future euro banknote changes.
• Monitor ECB and Central Bank of Ireland updates for the final design decision expected around the end of 2026.
• Prepare internal stakeholder briefings for cash operations, branch operations, payments, customer service, and communications teams on the expected euro banknote redesign timeline.
• If your firm accepts or processes cash, begin a preliminary review of any systems, controls, or vendor dependencies that could be affected by future note specifications, authentication features, or rollout timing.
• Update external messaging and FAQs only after the ECB publishes the final banknote design and implementation details.

Key Dates

References

• [1] lemonde.fr/economie/article/2026/07/23/la-banque-centrale...
• [2] centralbanking.com/central-banks/currency/banknotes/79592...
• [3] ecb.europa.eu/press/pr/date/2025/html/ecb.pr250131~611055...
• [4] linkedin.com/posts/european-central-bank_we-have-taken-th...
• [5] bundesbank.de/en/tasks/topics/new-design-for-euro-banknot...
• [6] ecb.europa.eu/euro/banknotes/future_banknotes/html/ecb.fa...
• [7] euronews.com/2026/07/23/leonardo-callas-and-curie-or-euro...
• [8] en.ara.cat/economy/beethoven-cervantes-or-callas-the-fina...

What Changed

• - The AMF’s decision reinforces that asset managers must maintain continuous compliance with their authorisation conditions, but isolated overreach by a person not listed as an executive officer was...
• Firms must have procedures that identify and manage conflicts of interest, including conflicts arising from links with a parent company and from the overlapping functions of directors and financial...
• Asset managers must ensure continuity of human resources and align remuneration practices for financial managers with the applicable regulations, the approved programme of activity, and internal...
• Firms must disclose to investors management-fee retrocessions paid to distributors and must be able to justify any claimed enhancement of the service provided.
• Information provided to investors and prospects must be clear, accurate, and not misleading, including in marketing materials.

Suggested Considerations

• Review the firm’s authorisation file, governance map, and executive-officer appointments to confirm that actual decision-making powers match the AMF-approved organisational structure.
• Update conflicts-of-interest procedures to capture conflicts arising from parent-company relationships, cross-directorships, and shared finance leadership roles.
• Test whether staffing levels and succession arrangements ensure continuity of human resources for control functions and key operational roles.
• Reassess remuneration arrangements for financial managers to verify consistency with the firm’s programme of activity, internal procedures, and regulatory requirements.
• Verify that all distributor retrocessions are fully disclosed to investors and that any claim of enhanced service is documented with evidence.

Key Dates

References

• [1] amf-france.org/en/news-publications/news-releases/enforce...
• [2] amf-france.org/sites/institutionnel/files/pdf/77659/en/Th...
• [3] finascope.fr/english/reglementation/la-commission-des-san...
• [4] kroll.com/en/publications/financial-compliance-regulation...
• [5] kroll.com/en/insights/publications/financial-compliance-r...
• [6] amf-france.org/en/news-publications/news-releases/enforce...
• [7] opalesque.com/712766/AMF_ruling_underscores_personal_acco...
• [8] navacelle.law/historical-sanctions-financial-markets-auth...

What Changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the two themes “European culture” and “Rivers and birds”.
• An EU‑wide online public survey has been launched to collect feedback on the shortlisted designs, forming part of the ECB’s inclusive approach to banknote design.
• The ECB’s Governing Council will select a single design proposal around the end of 2026, informed by the Design Contest Jury conclusions, technical assessments and survey results.
• The chosen design will undergo further development and testing before production, including integration of new and improved security features.
• The new series of euro banknotes will be introduced into circulation in subsequent years, alongside existing series, which will retain their legal value and continue to circulate.

Suggested Considerations

• Establish an internal project workstream to monitor ECB communications on the banknote redesign and plan for operational impacts on cash handling, ATM networks and merchant devices.
• Conduct a preliminary impact assessment of how new banknote security and design features may affect existing banknote sorting, authentication and recycling equipment, and identify likely upgrade or replacement needs.
• Engage with ATM and cash‑handling hardware vendors to understand expected firmware, sensor and software changes required to support the new banknote series and to secure upgrade slots ahead of issuance.
• Review and update internal cash‑handling and banknote authentication procedures, including staff training materials, to incorporate new design and security features once technical specifications are published.
• Plan customer communications strategies to explain the coexistence of old and new series banknotes, reaffirm the continued validity of previous series, and address any fraud or counterfeiting concerns.

Key Dates

References

• [1] ecb.europa.eu/home/html/index.en.html
• [2] banque-france.fr/en/press-release/ecb-selects-motifs-futu...
• [3] ecb.europa.eu/press/pr/date/2023/html/ecb.pr230710~77cf71...
• [4] ecb.europa.eu/euro/banknotes/future_banknotes/html/index....
• [5] bundesbank.de/en/tasks/topics/ecb-selects-motifs-for-futu...
• [6] politico.eu/article/ecb-euro-christine-lagarde-to-choose-...
• [7] ecb.europa.eu/euro/banknotes/future_banknotes/html/ecb.fa...
• [8] rte.ie/news/business/2023/1130/1419310-new-ecb-banknote-t...

What Changed

• - The FCA explicitly highlights vertically integrated insurance business models (combining underwriting, distribution, premium finance and related services within one group) as a source of heightened...
• Ownership and financing relationships, including private and non-transparent arrangements within groups or between firms, are now clearly framed as potential conflicts drivers that must be assessed...
• The FCA reiterates that having conflicts of interest is not inherently unacceptable, but firms must actively identify, manage and evidence those conflicts through effective governance, senior...
• The FCA states that disclosure on its own is not sufficient; firms remain obligated to properly manage conflicts, and cannot rely solely on informing customers to discharge their duties.
• Firms are expected to review how they design products and panels, structure remuneration, and communicate with customers to ensure that commercial relationships and incentives do not distort customer...

Suggested Considerations

• Conduct a board-level review of the firm’s business model, focusing on vertical integration, ownership and financing relationships to identify where commercial incentives may misalign with customer interests and create conflicts of interest.
• Map the full insurance value chain (underwriting, distribution, premium finance, ancillary services) within the group or related parties, and document actual and potential conflicts of interest at each link and interaction point.
• Review and, where necessary, update the firm’s conflicts-of-interest policy and SYSC 10 framework to explicitly cover vertically integrated structures, premium finance arrangements, delegated authorities and any intra-group referrals.
• Establish or strengthen governance arrangements to ensure clear senior management accountability for conflicts-of-interest management, including allocation of responsibilities in Statements of Responsibilities and the Management Responsibilities Map.
• Assess product design, panel construction and distribution strategies to ensure they are not unduly influenced by internal group relationships or remuneration structures that could lead to poor customer outcomes or unfair value.

References

• [1] handbook.fca.org.uk/handbook/sysc10
• [2] fca.org.uk/news/blogs/managing-conflicts-interest-insurance
• [3] handbook.fca.org.uk/handbook/ICOBS/8/3.pdf
• [4] rrcompliance.com/post/understanding-fca-requirements-for-...
• [5] hfw.com/insights/fcas-consultation-paper-on-client-catego...
• [6] paradigm.co.uk/blog/blog-how-firms-should-manage-conflict...
• [7] mco.mycomplianceoffice.com/blog/fca-actions-conflicts-of-...
• [8] iomfsa.im/media/1900/cp1603coiforissue.pdf

What Changed

• - The Central Bank of Ireland has formally identified “Bates Finance Limited (CLONE)” as an unauthorised investment firm / investment business firm and published its details (name, website, email,...
• The warning explicitly states that Bates Finance Limited (CLONE) is not authorised to provide investment services in Ireland and is cloning an authorised firm’s details to pass itself off as...
• The Central Bank confirms that there is no connection between the legitimate authorised firm and the cloned entity using its name.
• The firm’s name is published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reaffirming the Central Bank’s enforcement power to publicly name unauthorised providers.
• The warning reiterates channels for reporting suspected unauthorised firms to the Central Bank (telephone and online reporting), reinforcing expectations that firms and individuals will escalate...

Suggested Considerations

• Monitor the Central Bank of Ireland’s unauthorised firms and warning notices on an ongoing basis and promptly update internal watchlists, sanctions‑style lists, and fraud‑monitoring tools to include Bates Finance Limited (CLONE).
• Update customer‑facing communications, scam warnings, and investor education materials to reference clone firms and instruct clients to verify authorisation using the Central Bank’s Registers before engaging with any investment firm.
• Review and strengthen controls for detecting and responding to clone firm activity, including monitoring for misuse of the firm’s name, logo, Companies Registration Office number, or website domain in Ireland and other jurisdictions.
• Implement procedures to immediately escalate to the Central Bank and law enforcement (e.g. An Garda Síochána) if the firm becomes aware that its identity is being cloned or if clients are approached by Bates Finance Limited (CLONE) or similar unauthorised entities.
• Enhance due‑diligence and onboarding checks to validate counterparties and intermediaries offering investment products into Ireland, ensuring they hold appropriate authorisation from the Central Bank or relevant EU/EEA regulators.

Key Dates

References

• [1] centralbank.ie/regulation/how-we-regulate/authorisation/u...
• [2] centralbank.ie/regulation/how-we-regulate/authorisation/u...
• [3] centralbank.ie/news/article/warning-notice-service-financ...
• [4] service.betterregulation.com/document/30388
• [5] registers.centralbank.ie/downloadspage.aspx
• [6] fca.org.uk/news/warnings/bates-finance-clone-uk-registere...
• [7] eu-fpg.com/resources/jurisdictions/ireland
• [8] centralbank.ie/news/article/warning-notice-central-bank-o...

What Changed

• - The Central Bank of Ireland has formally designated “Russell Administration Limited (CLONE)” as an unauthorised investment firm under section 53 of the Central Bank (Supervision and Enforcement)...
• The warning confirms that Russell Administration Limited (CLONE) is not authorised to provide investment services in Ireland, and that there is no connection between this clone entity and the...
• The Central Bank has publicly disclosed specific identifiers for the unauthorised firm (website, email address, and phone number) to assist firms and consumers in recognising and blocking fraudulent...
• The notice reiterates that firms and individuals can report suspected unauthorised or clone firms directly to the Central Bank via designated telephone contact points.
• By publishing the warning, the Central Bank reinforces its policy that operating as an investment firm in Ireland without appropriate authorisation is unlawful and subject to supervisory and...

Suggested Considerations

• Verify that your firm’s name, contact details, and regulatory authorisation information have not been cloned or misused by Russell Administration Limited (CLONE) or other similar entities, and escalate any evidence of impersonation to the Central Bank and local law enforcement.
• Update client-facing communications, including website fraud alerts and investor letters, to warn about clone firms and specifically list known identifiers (such as the Russell Administration Limited (CLONE) website, email address, and phone number) where relevant to your client base.
• Instruct front-office, call centre, and relationship management staff to advise clients to check the Central Bank Registers and unauthorised firms list before engaging with any entity claiming to be regulated in Ireland, and to report any suspicious contact immediately.
• Review and strengthen internal financial crime and fraud detection controls to include explicit screening for clone firm indicators, such as mismatched contact details, unregistered domains, and requests to transfer funds to newly introduced counterparties.
• Incorporate the Russell Administration Limited (CLONE) warning and similar Central Bank warning notices into your firm’s ongoing financial crime risk assessments and customer risk profiling, particularly for high-risk investment products and cross-border services.

Key Dates

References

• [1] centralbank.ie/regulation/how-we-regulate/authorisation/u...
• [2] service.betterregulation.com/document/30388
• [3] centralbank.ie/regulation/industry-market-sectors/securit...
• [4] fi.ee/sites/default/files/2025-08/Loan%20365%20(Clone)%20...
• [5] linkedin.com/posts/central-bank-of-ireland_central-bank-o...
• [6] registers.centralbank.ie
• [7] edit.centralbank.ie/docs/default-source/publications/fina...

What Changed

• - BaFin reiterates that shareholders must notify both the issuer and BaFin when their voting rights in an issuer reach, exceed, or fall below specified thresholds, in line with sections 33 et seq.
• The publication confirms that the notification must be made within four trading days from the triggering event (i.e. crossing of a relevant voting rights threshold).
• BaFin highlights that failure to notify, or to notify within the prescribed four‑trading‑day period, constitutes an administrative offence under the WpHG.
• The notice confirms that BaFin can impose administrative fines on natural persons for breaches of the voting rights notification obligation up to a statutory maximum of €2 million.
• The case illustrates BaFin’s willingness to impose multiple fines for multiple notification failures arising from separate threshold crossings or reporting obligations within a given period.

Suggested Considerations

• Map all shareholdings in German‑listed issuers (including derivatives and instruments conferring voting rights) against the WpHG notification thresholds and maintain a central register of current and potential reportable positions.
• Implement or enhance automated monitoring tools and internal controls to detect in real time when voting rights in a German‑listed issuer are about to reach, exceed, or fall below a threshold, triggering a four‑trading‑day notification period.
• Establish a clear, documented procedure for preparing and submitting voting rights notifications to both the issuer and BaFin, including responsible owners, escalation paths, and backup arrangements for absences or system outages.
• Review and update internal policies, shareholder disclosure manuals, and client onboarding documentation to explicitly reflect the four‑trading‑day deadline and the requirement to notify both the issuer and BaFin when thresholds are crossed.
• Train front‑office, trading, corporate actions, and legal/compliance staff (including those outside Germany) on German voting rights notification rules, focusing on threshold levels, calculation principles (including aggregation across entities and instruments), and timelines.

Key Dates

References

• [1] bafin.de/SharedDocs/Veroeffentlichungen/EN/Massnahmen/40c...
• [2] bafin.de/EN/Aufsicht/BoersenMaerkte/Emittentenleitfaden/M...
• [3] bafin.de/SharedDocs/Veroeffentlichungen/EN/Massnahmen/40c...
• [4] bafin.de/EN/Aufsicht/BoersenMaerkte/Emittentenleitfaden/M...
• [5] solutions-atlantic.com/germany-bafin-sets-fine-for-substa...
• [6] bafin.de/SharedDocs/Veroeffentlichungen/EN/Fachartikel/20...
• [7] noerr.com/en/insights/payment-service-providers'-reportin...
• [8] resourcehub.bakermckenzie.com/en/resources/cloud-complian...

What Changed

• - Credit institutions and investment firms are no longer permitted to accept payments, fees, commissions or non‑monetary benefits from third parties (e.g.
• The prohibition applies to the forwarding of both retail and professional client orders and covers any form of economic benefit linked to routing orders to a specific counterparty or venue.
• Germany’s previous use of the MiFIR national exemption for domestic clients has ended; there is no longer any national carve‑out for PFOF in relation to clients resident or established in Germany.
• BaFin’s supervisory statement specifies how firms must interpret and apply the EU‑level PFOF ban in practice, including alignment with ESMA’s interpretative decisions on the scope of prohibited...
• The stated regulatory objective is to improve the quality of client order execution and prevent conflicts of interest arising from execution venues or market makers incentivising brokers to route...

Suggested Considerations

• Identify and map all current remuneration streams linked to order routing, including explicit PFOF arrangements, volume‑based rebates, and other benefits from market makers or venues, and cease any arrangements that constitute PFOF or similar third‑party inducements for forwarding orders.
• Review and update MiFID II / MiFIR inducement policies to explicitly classify PFOF and similar execution‑related rebates as prohibited benefits, ensuring no reliance on inducement disclosure or quality‑enhancement arguments to justify them.
• Amend best‑execution policies and procedures to remove any consideration of third‑party payments from venues or market makers in the execution‑venue selection process and to emphasise price, cost, speed, likelihood of execution, and other MiFID II best‑execution factors.
• Conduct a conflicts‑of‑interest assessment to identify any residual incentives or arrangements that could compromise the duty to act in the best interests of clients in order routing, and implement mitigation measures or remove such conflicts where necessary.
• Redesign pricing and revenue models for neobroker and low‑fee brokerage services to replace PFOF‑funded “zero‑commission” offerings with compliant alternatives, such as explicit commissions, spreads, subscription fees, or other transparent charges.

Key Dates

References

• [1] lrz.legal/de/lrz/eu-regulierung-von-neubrokern
• [2] bafin.de/SharedDocs/Veroeffentlichungen/DE/Aufsichtsmitte...
• [3] asscompact.de/nachrichten/bafin-positioniert-sich-zum-ges...
• [4] neuebanken.de/pfof-verbot-2026-neobroker/
• [5] onvista.de/news/2025/12-29-bye-bye-payment-for-order-flow...
• [6] dasinvestment.com/bafin-will-neobrokern-auf-den-zahn-fueh...
• [7] dasinvestment.com/payment-for-orderflow-verbot-neobroker-...
• [8] boersen-zeitung.de/english/neobrokers-brace-for-end-of-pa...

What Changed

• - CSSF Circular 21/783, which applied ESMA’s Guidelines on MiFID II/MiFIR obligations on market data in Luxembourg, will cease to be applicable as of 23 August 2026 and is formally classified as...
• The supervisory reference framework for market data obligations in Luxembourg shifts from ESMA soft-law Guidelines to binding regulatory technical standards contained in Commission Delegated...
• Requirements on making market data available to the public on a “reasonable commercial basis” are now set out in directly applicable EU law, including detailed RTS criteria on cost-based pricing,...
• ESMA’s interpretative role via Guidelines is replaced by binding RTS, which reduces reliance on national circulars and increases harmonisation of market data rules across EU trading venues and data...
• Luxembourg firms can no longer rely on Circular 21/783 as the primary interpretative document for market data obligations; instead, their compliance frameworks must directly reference Delegated...

Suggested Considerations

• Identify and catalogue all internal policies, procedures, contractual templates, and pricing frameworks that reference CSSF Circular 21/783 or ESMA’s MiFID II/MiFIR market data Guidelines.
• Review Commission Delegated Regulation (EU) 2025/1156 in detail and map its RTS requirements (e.g. cost-based pricing, non-discriminatory access, data unbundling, publication formats) against current market data practices.
• Update market data pricing policies to ensure that fees are demonstrably based on reasonable commercial basis criteria defined in Delegated Regulation (EU) 2025/1156, including documentation of cost allocation and margin methodology.
• Revise market data access policies and client terms to ensure non‑discriminatory conditions and appropriate unbundling of pre‑trade and post‑trade data, in line with the RTS.
• Amend compliance manuals, MiFID/MiFIR control frameworks, and training materials to remove references to CSSF Circular 21/783 and ESMA Guidelines, replacing them with references to Delegated Regulation (EU) 2025/1156.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/cssf21_783eng.pdf
• [2] cssf.lu/wp-content/uploads/cssf21_790_eng.pdf
• [3] cssf.lu/wp-content/uploads/cssf21_782eng.pdf
• [4] pwc.lu/en/newsletter/2026/cssf-circular-25-901.html
• [5] dechert.com/knowledge/onpoint/2024/4/new-cssf-circular-on...

What Changed

• - The CBI has formally commissioned an independent review of its enforcement activities, covering both how enforcement is structured and how it operates in practice, rather than a narrow thematic or...
• The review mandate expressly covers the performance of enforcement activities and the role of enforcement within the wider supervisory framework, indicating that enforcement may be repositioned...
• The review will examine enforcement structures and processes, including decision‑making governance, which may result in new approval routes, escalation paths, or committee structures for opening,...
• The review will look at case‑selection criteria and processes, suggesting potential future changes to how and why firms or individuals are selected for enforcement action, and possibly the...
• Timeliness of enforcement actions is in scope, which may lead to explicit timelines or service standards for case progression, investigation milestones, and resolution, with potential knock‑on...

Suggested Considerations

• Review and document your enforcement‑facing governance, including Board and senior management oversight of investigations, decision‑making on settlement, and escalation paths, to ensure these are robust and can withstand a more structured or time‑bound enforcement approach.
• Assess whether your record‑keeping, data, and management information relating to regulatory breaches, incidents, and CBI interactions are sufficiently complete and organised to support faster and more transparent enforcement processes.
• Conduct a gap analysis of investigation procedures and response playbooks (e.g. dawn raid readiness, information requests, interviews, internal investigations) to ensure they can meet potentially tighter CBI timeliness and information‑quality expectations.
• Update Board and senior management on the launch of the enforcement review and agree a watching brief, including designation of a responsible function (e.g. Compliance or Legal) to monitor the review, its terms of reference, stakeholder engagements and eventual recommendations.
• Engage external counsel or industry associations, as appropriate, to prepare for possible consultation or stakeholder engagement opportunities during the review, including developing key messages on proportionality, timeliness, transparency and coordination with supervision.

Key Dates

References

• [1] bis.org/review/r180124b.pdf
• [2] kpmglaw.ie/pdf/ie-fitness-and-probity-august-2024.pdf
• [3] irishtimes.com/business/2024/07/11/central-bank-vetting-r...
• [4] oireachtas.ie/en/debates/debate/dail/2011-10-25/31/
• [5] lexology.com/library/detail.aspx?g=af4e0d93-8179-4ffd-9af...

What Changed

• - The SEC has formally announced that Principal Deputy Director of the Division of Enforcement Sam Waldon will leave the agency effective 31 July 2026, ending more than 14 years of service at the SEC.
• The Enforcement Division will have a new Principal Deputy Director (named in the release), who will assume responsibility for overseeing day‑to‑day enforcement operations, supervision of regional and...
• Waldon’s departure follows his recent tenure as Acting Director and Principal Deputy Director during a period of strategic restructuring of the Enforcement Division, including creation of multiple...
• The transition occurs against the backdrop of earlier Commission decisions to rescind delegation of formal order authority to the Enforcement Director, returning formal order approvals to the...
• Under Waldon’s leadership, the Division emphasized “quality over quantity” cases, focusing on traditional “core” areas (insider trading, accounting and disclosure fraud, market manipulation,...

Suggested Considerations

• Review and update enforcement‑risk assessments to reflect the forthcoming change in SEC Enforcement Division Principal Deputy Director, with particular focus on core fraud, insider trading, and accounting‑related risks.
• Re‑evaluate internal investigation, Wells process, and SEC engagement protocols to ensure they align with current Enforcement Manual practices and anticipate any refinements under the new Principal Deputy Director.
• Brief senior management, boards, and audit committees on the SEC enforcement leadership transition and its implications for prioritization of accounting, disclosure, and gatekeeper cases, particularly in light of the SOX‑focused enforcement unit.
• Reassess crypto and digital asset exposure, including ongoing or threatened SEC matters, to account for potential shifts in enforcement posture under new leadership while maintaining preparedness for fraud‑focused actions involving retail investors.
• Reinforce insider trading surveillance, market‑abuse monitoring, and controls around material non‑public information, reflecting the Enforcement Division’s continued emphasis on traditional trading‑related misconduct.

Key Dates

References

• [1] bloomberg.com/news/articles/2026-03-20/sec-lays-out-polic...
• [2] sec.gov/newsroom/press-releases/2024-162
• [3] angelinvestorsnetwork.com/regulatory-compliance/sec-enfor...
• [4] sec.gov/newsroom/press-releases/2026-27-sec-announces-enf...
• [5] reuters.com/world/us/sec-focus-traditional-cases-under-ne...
• [6] hklaw.com/en/insights/publications/2026/04/sec-speaks-are...
• [7] morganlewis.com/pubs/2026/04/securities-enforcement-round...
• [8] ainvest.com/news/sec-enforcement-inflection-point-directo...

What Changed

• - BaFin has formally confirmed an enforcement action where late or missing voting rights notifications under sections 33 et seq.
• The publication reiterates that shareholders must notify both the issuer and BaFin within four trading days when their voting rights reach, exceed, or fall below certain statutory thresholds in...
• BaFin explicitly links failures to notify or late notifications to administrative offences under the WpHG, with potential fines for legal persons of up to €10 million or up to 5% of total turnover,...
• The communication reflects BaFin’s continued focus on the proper functioning and attractiveness of EU capital markets, framing voting rights notification compliance as a core transparency tool rather...
• The case signals that BaFin is prepared to sanction non‑German firms (such as US‑based Brown Capital Management LLC) when their holdings in German issuers trigger WpHG thresholds and the resulting...

Suggested Considerations

• Map all portfolios and mandates to identify direct and indirect holdings of shares and related instruments in German issuers subject to WpHG voting rights notification rules.
• Implement or enhance an automated monitoring tool that aggregates positions at group level (including funds, managed accounts and derivatives) and flags when WpHG thresholds are approached or crossed.
• Review and document internal procedures to ensure that notifications to affected issuers and to BaFin are drafted, approved and submitted within the four‑trading‑day statutory deadline.
• Ensure that legal and compliance teams fully understand the WpHG threshold framework (including initial thresholds and subsequent incremental thresholds, and attribution rules) and maintain up‑to‑date written guidance and checklists.
• Establish a clear allocation of responsibilities between portfolio management, trading, operations, legal and compliance for detecting threshold crossings and preparing notification forms.

Key Dates

References

• [1] bafin.de/SharedDocs/Veroeffentlichungen/DE/Massnahmen/40c...
• [2] fxnewsgroup.com/forex-news/regulatory/bafin-fines-brown-c...
• [3] bafin.de/EN/Aufsicht/BoersenMaerkte/Emittentenleitfaden/M...
• [4] bafin.de/EN/home_node_en.html
• [5] bafin.de/SharedDocs/Veroeffentlichungen/EN/Massnahmen/40c...
• [6] bafin.de/SharedDocs/Veroeffentlichungen/EN/Fachartikel/20...
• [7] fintrx.com/firms/firm/brown-capital-management-llc-105633

What Changed

• - The PRA proposes to set out a typical sequence of steps firms would follow when undertaking a Part VIII transfer.
• The PRA proposes to provide greater transparency on its decision-making considerations for Part VIII transactions.
• The PRA proposes to explain when it may waive the requirement for a member vote by the transferee.
• The PRA proposes to explain when it may require an independent actuary’s report.
• The PRA proposes to clarify the scope of applicability of the process for both friendly societies and non-friendly-society firms.

Suggested Considerations

• Firms planning a Part VIII transfer should map their transaction timetable against the PRA’s proposed step-by-step process and identify where the revised guidance may affect sequencing.
• Firms should assess whether their proposed transaction could qualify for a waiver of the transferee member vote and prepare supporting rationale and evidence accordingly.
• Firms should determine early whether the PRA is likely to expect an independent actuary’s report and build that workstream into the transaction plan.
• Firms should confirm whether the proposal applies to their structure, including whether they are a friendly society or another type of firm within scope.
• Firms and advisers should review current transaction playbooks and board papers to align them with the PRA’s stated approach before the consultation closes.

Key Dates

References

• [1] bankofengland.co.uk/news/2026/july/pra-consults-on-update...
• [2] bankofengland.co.uk/prudential-regulation/publication/202...
• [3] bankofengland.co.uk/prudential-regulation/publication/202...
• [4] bankofengland.co.uk/prudential-regulation/publication/202...
• [5] milliman.com/en/insight/PRA-policy-statement-insurance-bu...
• [6] pinsentmasons.com/out-law/guides/insurance-business-trans...

What Changed

• - The PRA proposes a more detailed, codified description of the end‑to‑end Part VIII process for friendly society amalgamations and transfers, organised into stages such as planning and preparation,...
• The PRA intends to update and integrate its Statement of Policy on insurance business transfers to explicitly cover friendly society amalgamations and transfers under the Friendly Societies Act 1992,...
• For transfers, the PRA sets out circumstances in which it may exercise its statutory discretion to dispense with the requirement for the transferee friendly society to hold a member vote, subject to...
• The PRA proposes to clarify when it may direct the transferor and/or transferee to appoint an independent actuary to report on the proposed transfer’s effects on members and policyholders, including...
• Firms undertaking a Part VIII transfer will be expected to provide robust actuarial analysis and supporting evidence demonstrating that statutory preclusion grounds are not met and that the transfer...

Suggested Considerations

• Map all current and planned amalgamations or transfers involving friendly societies against the proposed five‑part process (planning, analysis, member engagement and votes, application/notifications/representations, confirmation meetings) and identify procedural and evidential gaps.
• Review internal policies, governance frameworks, and transaction playbooks for friendly society restructurings to ensure they reflect the PRA’s codified expectations under Part VIII of the Friendly Societies Act 1992, including early regulatory engagement and documentation standards.
• Develop or enhance internal guidance for actuaries and finance teams on the required actuarial analysis for Part VIII transfers, ensuring the ability to evidence that preclusion grounds are not met and that the transaction is in the interests of members and policyholders.
• Implement procedures to identify all classes of members and policyholders affected by proposed amalgamations or transfers, assess whether their existing terms and conditions are preserved or materially changed, and document the implications for benefit levels and distribution.
• For partial transfers, establish a formal framework to assess and document how the interests of members remaining with the transferor society are considered, including any continuing obligations, capital support, and benefit expectations.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] prarulebook.co.uk/guidance/statements-of-policy/the-pras-...
• [3] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [4] milliman.com/en/insight/PRA-policy-statement-insurance-bu...
• [5] skadden.com/insights/publications/2026/04/pra-proposes-fu...
• [6] pwc.co.uk/financial-services/assets/pdf/pra-finalises-new...
• [7] regulationtomorrow.com/2026/05/pra-cp8-26-funded-reinsura...
• [8] cliffordchance.com/insights/resources/blogs/insurance-ins...

What Changed

• - ESMA is explicitly positioned as the central supervisory authority for selected capital‑markets activities, with national competent authorities (NCAs) expected to operate within a more formalised...
• Supervisory objectives are reframed towards risk‑based and adaptive supervision, meaning firms should expect more differentiated supervisory intensity based on risk profile, business model, and...
• The paper supports proportionate and transparent funding for ESMA, indicating a future where firms may be subject to EU‑level supervisory levies or fee structures in addition to national regimes,...
• AFM and AMF call for independent, transparent, and accountable EU‑level supervisory governance, foreshadowing changes to ESMA’s decision‑making bodies, oversight processes, and accountability...
• Data centralisation is identified as a core enabler, implying a stronger move towards EU‑wide data hubs, harmonised reporting formats, and central access for ESMA to transaction, position, and...

Suggested Considerations

• Review and update the firm’s supervisory engagement strategy to include structured, proactive engagement with ESMA (not just NCAs), anticipating more direct interactions, thematic reviews, and data requests at EU level.
• Assess current risk‑assessment and risk‑reporting frameworks to ensure they are compatible with a risk‑based and adaptive supervisory approach, including the ability to demonstrate how your firm identifies, measures, and mitigates emerging risks and new business models.
• Conduct a gap analysis of data architecture and regulatory reporting, focusing on data quality, standardisation, and ability to feed into centralised EU data hubs; plan upgrades to systems, controls, and data governance to support ESMA‑level data centralisation.
• Prepare for potential changes in supervisory levies and funding, by modelling the impact of EU‑level ESMA fees in addition to national contributions and incorporating them into medium‑term budgeting and pricing strategies.
• Review governance arrangements, including board oversight, senior management responsibilities, and internal escalation processes, to ensure they can meet higher expectations of independent, transparent, and accountable governance under an ESMA‑centric model.

Key Dates

References

• [1] afm.nl/en/sector/themas/over-het-toezicht-en-beleid-van-d...
• [2] amf-france.org/sites/institutionnel/files/private/2025-01...
• [3] amf-france.org/sites/institutionnel/files/private/2025-01...
• [4] afm.nl/~/profmedia/files/publicaties/2021/position-paper-...
• [5] amf-france.org/en/news-publications/amfs-eu-positions/fre...
• [6] loyensloeff.com/insights/news--events/news/looking-ahead-...
• [7] elibrary.imf.org/downloadpdf/view/journals/002/2011/204/a...
• [8] regulationtomorrow.com/2026/01/afm-publishes-supervisory-...

What Changed

• As the 21 July 2026 CSSF notice is an enforcement publication (not a new rule), it does not introduce new regulatory requirements; it applies existing Transparency Law obligations.
• Issuers with Luxembourg as home Member State under the Transparency Law must publish annual financial reports within the statutory deadline, typically within four months of financial year-end, and...
• Failure to publish periodic financial information within the required time limits can result in administrative fines imposed by the CSSF under Article 25(2) of the Transparency Law.
• The CSSF will publicly disclose administrative fines imposed on issuers, including naming the issuer and the amount, in line with Article 26b of the Transparency Law.
• Issuers retain the right to challenge CSSF decisions before the Luxembourg Administrative Court within the period set by Article 27 of the Transparency Law (three months from notification), but...

Suggested Considerations

• Map all Transparency Law obligations applicable to your entity, including periodic (annual and half‑yearly) reporting and ongoing disclosure of regulated information, and document them in a compliance obligations register.
• Review and, where necessary, strengthen internal processes to ensure annual and half‑yearly financial reports are prepared, approved, and published within statutory deadlines for issuers with Luxembourg as home Member State.
• Implement a formal disclosure governance framework assigning clear responsibilities to senior management and the board for oversight of regulated information, including escalation procedures where delays or issues arise.
• Establish a calendar of regulatory reporting and publication deadlines, including internal cut‑off dates and contingency plans, and ensure it is monitored by compliance and finance functions.
• Conduct a gap analysis of prior disclosures (financial reports, major holdings notifications, inside information) to confirm that all items required under the Transparency Law have been published correctly and on time; remediate any deficiencies promptly.