June 2026 Regulatory Updates

Key dates

10 November 2025

- Bank of England consultation paper issued on the proposed regulatory framework for sterling‑denominated systemic stablecoins and systemic payment system operators

Late 2026

- Bank of England intends to finalise the Code of Practice and supporting materials by the end of 2026, confirming the prudential and structural regime for systemic stablecoins

From 2026

- UK introduces new regulatory authorisation requirements for stablecoin issuers, including FCA authorisation for qualifying issuance and custody activities

10 February 2026

- Consultation period closes for the Bank of England’s systemic stablecoin regime proposals

June 2026

- Bank of England publishes its policy statement and draft Code of Practice for systemic stablecoin issuers, setting out detailed prudential and backing‑asset rules and confirming joint work with the FCA on an end‑to‑end regime

Suggested considerations

• Map all existing and planned sterling‑denominated stablecoin products against the UK’s systemic and non‑systemic regimes and assess whether their intended use in UK payments could trigger HM Treasury systemic recognition.
• Initiate or update FCA authorisation applications for stablecoin issuance and cryptoasset custody activities, ensuring business models, governance and safeguarding arrangements align with CP25/14 and the forthcoming stablecoin regime.
• Design and implement reserve‑management frameworks capable of maintaining backing assets equal to outstanding coins, in the proposed 70/30 mix between short‑term UK government debt and Bank of England deposits, with appropriate stress testing and liquidity risk oversight.
• Establish statutory trust and segregation structures for backing assets and liquid‑asset reserves, including appointing UK‑authorised third‑party custodians and aligning documentation with FCA client‑asset‑style protections and coinholder proprietary claims.
• Develop capital planning processes and ICAAP‑style assessments to meet the Bank of England’s requirements for capital against general business risk and dedicated reserves for financial risk and wind‑down costs.

What changed

• - UK stablecoin issuance will be subject to a dual regulatory regime: non‑systemic stablecoins will be supervised solely by the FCA, while systemic stablecoins used for payments will be jointly...
• Issuing a qualifying sterling‑denominated stablecoin in the UK will become a regulated activity, requiring FCA authorisation for non‑bank issuers and bringing them within the FCA’s prudential,...
• HM Treasury will apply statutory systemic tests under the Banking Act (e.g. scale, interconnectedness, substitutability, impact on confidence in sterling) to decide whether a stablecoin payment...
• Once recognised as systemic, stablecoin issuers and systemic payment system providers will fall under the Bank of England’s remit under the Banking Act 2009, including powers to obtain information,...
• Systemic sterling‑denominated stablecoin issuers will be required to maintain backing reserves equal to all outstanding coins, with backing assets held on statutory trust in the UK and ring‑fenced...

Key dates

31 July 2026

- Updated Form PL definitions are scheduled to be published by the Bank of England

Q1 2027

- First reference period for which the updated Form PL definitions are effective

May 2027 Deadline

- Submission deadline for Q1 2027 Form PL reporting using the revised definitions and tax treatment

Suggested considerations

• Review the updated Form PL definitions in full once they are published on 31 July 2026 to understand all changes to income, expenditure and tax classification.
• Map the revised Form PL tax definition (PL16 / PL.01.01.01 C0010 R1600) to internal chart of accounts and tax reporting structures, ensuring correct identification of taxes on production and related charges.
• Update internal regulatory reporting systems, data transformation rules and validation checks to reflect the new Form PL definitions ahead of the Q1 2027 reporting period.
• Revise internal reporting policies, procedures and documentation for Form PL to incorporate the updated tax treatment and any other definitional changes.
• Train finance, regulatory reporting and data teams on the revised Form PL guidance, with particular focus on the redefined tax items and their distinction from other tax and fee categories.

What changed

• - The Bank of England will update the Form PL definitions to improve consistency and alignment with the ONS UK National Accounts requirements, specifically for income and expenditure reporting.
• The definition and reporting guidance for tax (PL16 / PL.01.01.01 C0010 R1600) are being revised to clarify the treatment of items classified as taxes on production and related charges.
• The updated definitions will apply to all Form PL line items, with particular emphasis on ensuring more precise classification of tax-related items within profit and loss reporting.
• The Bank of England does not anticipate major changes in reported figures but expects improved clarity and consistency in how firms map internal accounting data to Form PL categories.
• The updated definitions will replace the current Form PL guidance and become the operative standard for all reporting institutions from the Q1 2027 reporting period.

Key dates

15 October 2013

- Council Regulation (EU) No 1024/2013 enters into force, granting the ECB sanctioning powers for prudential supervision of credit institutions (contextual basis for this enforcement)

Q4 2023

- Start of the period during which BIL failed to apply its approved internal models to expected loss calculation for defaulted retail and corporate exposures, leading to overstated capital

Q1 2024

- Second consecutive quarter in which incorrect expected loss and IRB shortfall calculations continued to affect reported capital and capital ratios

Q2 2024

- Third consecutive quarter of miscalculation; end of the period identified by the ECB as affected by the breach

29 June 2026

- The ECB publishes its decision imposing an administrative penalty of €3.255 million on BIL for the severe breach of its decision on internal models

Suggested considerations

• Review and confirm that all regulatory capital calculations, including expected loss and IRB shortfall for defaulted exposures, consistently use the approved internal models as authorised by the ECB or national competent authority.
• Map and reconcile the internal-model implementation across risk systems, finance, and regulatory reporting to ensure that there are no manual overrides, alternative methods, or parallel calculations that deviate from the approved model specifications.
• Strengthen model risk governance by ensuring that any proposed changes to expected loss methodologies, including for defaulted retail and corporate portfolios, are formally approved by the competent authority before being used in regulatory capital reporting.
• Implement robust controls and periodic testing within Finance, Risk, and Regulatory Reporting functions to detect and prevent misapplication or non-application of approved internal models, with clear escalation procedures for identified discrepancies.
• Ensure that the calculation of IRB shortfall (difference between expected loss and accounting provisions) is independently validated and appropriately deducted from CET1 capital in accordance with CRR and ECB internal models guidance.

What changed

• - The ECB has reaffirmed that institutions using internal ratings-based (IRB) approaches must apply their approved internal models consistently for expected loss calculation on defaulted retail and...
• The ECB has underscored that the IRB shortfall (difference between expected loss and accounting provisions) must be correctly calculated and deducted from regulatory capital whenever expected loss...
• The ECB has classified intentional failure to apply approved internal models to expected loss calculations as a “severe” breach under its Guide to the method of setting administrative pecuniary...
• The enforcement action confirms the ECB’s readiness to use its sanctioning powers under Article 18 of Council Regulation (EU) No 1024/2013 against internal-model users that misreport capital due to...
• The case highlights that miscalculation of expected loss and IRB shortfall over multiple reporting periods, even without an explicit capital ratio breach of minima, can be sanctioned where capital...

Key dates

31 July 2022

- FCA expected to make the original Consumer Duty rules following CP21/13, establishing the baseline regime and Principle 12

31 July 2023

- Consumer Duty comes into force for open (non‑closed‑book) products and services, triggering initial implementation across retail distribution chains

First half of 2026

- FCA planned consultation on revisions to the Consumer Duty scope and exemptions, including clearer delineation of business‑to‑business activity, reliance arrangements in distribution chains and removal of non‑UK customers from scope

Late 2026 (TBD)

- FCA to consult on further changes to client classification, sharpening the distinction between retail and professional markets and clarifying the treatment of sophisticated investors under the Consumer Duty

June 2026 (indicative)

- FCA expected to issue a consultation paper on Duty scope, proportionality and application to wholesale‑only and early‑chain firms, including potential changes to definitions and categorisation of manufacturers versus supporting firms

Suggested considerations

• Map all business lines and activities to identify which are genuinely wholesale, early‑chain or business‑to‑business, and assess where the firm does or does not “shape consumer outcomes” at the end of the chain.
• Review existing Consumer Duty scoping decisions for activities such as market making, custody, safeguarding and other wholesale services, and prepare to adjust those decisions in line with FCA case studies and clarified boundaries.
• Re‑evaluate cross‑border business conducted for non‑UK clients to determine which products and services may fall outside the Consumer Duty under the proposed narrowed territorial scope, and document the basis for this classification.
• Analyse multi‑party distribution chains and co‑manufacturing arrangements to clearly delineate responsibilities, reliance points and escalation mechanisms where other firms are expected to meet their Consumer Duty obligations.
• Update product governance and Consumer Duty frameworks to distinguish between “manufacturers” and supporting firms, ensuring manufacturers continue to meet full Duty requirements while supporting firms apply Principle 12 and cross‑cutting rules proportionately.

What changed

• - The FCA is consulting on clearer scope boundaries for the Consumer Duty to confirm that wholesale, business‑to‑business activities that do not shape retail consumer outcomes should normally be out...
• The FCA will provide case studies and examples of “grey areas” to illustrate when activities are, and are not, caught by the Duty, particularly for early‑chain and wholesale‑only firms.
• The FCA is clarifying accountability in multi‑firm arrangements, confirming that each firm is responsible for its own activities, can rely on other firms to meet their obligations where appropriate,...
• The FCA plans to reduce duplication of obligations across distribution chains, including refining how the “look‑through” concept and co‑manufacturing apply where firms do not directly interact with...
• The FCA is narrowing the territorial scope of the Consumer Duty so that business conducted for genuinely non‑UK customers will generally be out of scope, aligning with the principle that local...

Key dates

2025

- CSSF’s supervisory disclosure covers **measures and administrative penalties for the year 2025**

23 July 2025

- CSSF published the prior year’s supervisory disclosure page referencing the **2024** measures and penalties, showing the annual disclosure cycle

28 July 2025 Deadline

- CSSF issued an **administrative sanction** in an AML/CFT case, imposing a reprimand for non-compliance with the AML/CFT Law

Suggested considerations

• Review the firm’s AML/CFT control framework against the Luxembourg AML/CFT Law provisions that can trigger CSSF reprimands or sanctions, including governance, monitoring, and escalation controls.
• Verify that suspicious activity detection, investigation, and escalation procedures are documented, implemented, and tested for effectiveness.
• Reassess whether internal controls are sufficient to demonstrate timely compliance with professional AML/CFT obligations under CSSF supervision.
• Update remediation tracking to ensure supervisory findings are closed out promptly and supported by evidence of corrective action.
• Brief senior management on the reputational impact of public supervisory disclosures and ensure that recurring weaknesses are escalated to the board.

What changed

• - CSSF has published its 2025 supervisory disclosure covering supervisory measures and administrative penalties taken during the year.
• The publication serves as a public register-style disclosure of enforcement outcomes, increasing transparency around CSSF supervision and sanctioning activity.
• A related 2025 CSSF administrative sanction shows that AML/CFT non-compliance can result in a reprimand under the amended Luxembourg AML/CFT Law.
• The 28 July 2025 sanction confirms that CSSF can act where firms fail to maintain adequate professional AML/CFT obligations and related internal controls.

Key dates

26 June 2026

- CBI publishes the warning notice against Loan Empower Solution as an unauthorised retail credit firm and lists the firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Review and update internal unauthorised-firm and scam monitoring procedures to ensure Loan Empower Solution and its identifiers (name, website, address, email, telephone number) are captured in watchlists, fraud rules, and staff guidance.
• Screen recent and ongoing customer transactions and communications for any references to Loan Empower Solution or similar lending scams requesting upfront “loan fees”, and escalate any matches to fraud and compliance teams.
• Update customer-facing communications and website scam warnings to highlight the risk of advance fee fraud in retail credit, referencing the need to check the CBI registers and unauthorised-firms list before engaging with lenders.
• Ensure call centre, branch, and digital support staff are trained to identify and respond to customers approached by unauthorised lenders, including how to advise customers to verify authorisation status on the CBI website and to report suspected scams.
• Incorporate checks against the CBI unauthorised firms search into onboarding, due diligence, and third-party risk management processes for any lending-related partnerships, introducers, or lead generators.

What changed

• - The CBI has added Loan Empower Solution (website: lesolution.eu) to its public list of unauthorised firms and explicitly categorised it as an unauthorised retail credit firm operating without the...
• The CBI has publicly stated that Loan Empower Solution appears to be operating an advance fee fraud model, where upfront payments are requested for credit services that are never provided.
• The CBI has confirmed that the firm is using a purported Irish business address (The Merrion Buildings, 18–20 Merrion Street, Dublin 2, D02 XH98), a non-Irish telephone number, and a specified...
• The firm’s name has been published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reaffirming the CBI’s use of its statutory power to publicly identify entities...
• The CBI has directed the public to its unauthorised firms search and financial scams information pages, implicitly reinforcing expectations that firms promote use of these tools in their consumer...

Key dates

18 June 2025

- FATF adopts modifications to Recommendation 16 to enhance payment transparency, including strengthened travel‑rule standards

24 June 2026

- FATF launches public consultation on guidance for the implementation of the updated Recommendation 16

21 August 2026 Deadline

- FATF public consultation period closes; this is the deadline for private‑sector contributions highlighted by the CSSF

End 2030

- FATF’s revised Recommendation 16 framework is expected to be fully effective, with jurisdictions having implemented the standard into national law or regulation by this date

Suggested considerations

• Map and document all existing and planned cross‑border payment and value‑transfer flows (including virtual asset transfers) to identify where FATF Recommendation 16 and travel‑rule obligations currently apply or will apply by 2030.
• Review the June 2025 FATF modifications to Recommendation 16 and the current consultation materials, and perform a gap analysis against your existing AML/CTF, KYC and payments data standards, including thresholds, data fields, and monitoring use‑cases.
• Establish an internal project for travel‑rule implementation and enhancement that spans AML, operations, technology, legal and data‑protection teams, with explicit ownership and governance.
• Strengthen beneficiary‑side transaction‑monitoring rules to use incoming travel‑rule data for sanctions, fraud and AML detection, including controls to identify misdirected or unusual payments based on name, location, and other attributes.
• Review and, where necessary, update customer due diligence and KYC procedures to ensure the availability and verification of data fields that will be required to travel with transactions (for example, address, town and country, identification numbers, date of birth).

What changed

• *(Based on the CSSF notice plus the 2025 FATF revisions to Recommendation 16 and existing travel‑rule standards; details may be further refined by the new guidance now under consultation.)*
• FATF is issuing implementation guidance for the updated Recommendation 16, which already increased obligations regarding payment transparency, including more granular beneficiary data and expanded...
• Cross‑border payments and value transfers above 1,000 USD/EUR are expected to include additional mandatory beneficiary information, such as beneficiary name, account or unique reference, and at least...
• Beneficiary institutions are given enhanced responsibilities to use travel‑rule information (not just receive it) for transaction monitoring, including detecting misdirected payments and indicators...
• The revised travel rule continues to apply to both traditional wire transfers and value transfers involving virtual assets, reinforcing that Virtual Asset Service Providers (VASPs) must collect,...

Key dates

26 June 2026

- ECB announces the comprehensive review of around 130 supervisory guidance publications, confirms discontinuation of about 40 outdated documents, and signals targeted and in‑depth revisions for the remaining guidance set

Q3 2026 (approx.)

- Revised **Guide to the internal capital adequacy assessment process** is expected to be published “shortly” after the press release, incorporating clarified treatment of the management buffer and its relationship to Pillar 2 guidance

Q3–Q4 2026 (approx.)

- Removal of supervisory expectations on **credit conversion factor (CCF)** from the **Guide to internal models** and the removal of **CVA references** from the **Guide on assessment methodology** and the **Guide on materiality assessment** are implemented as part of the ongoing review and alignment with EBA guidance and CRR III

Q4 2026–2027 (TBD)

- **Public consultations** will be launched on those guidance documents identified as needing substantial revision, ahead of finalising the updated versions

Q1 2027

- Publication of the new **report on good practices in governance and risk culture**, replacing the existing Draft guide on governance and risk culture, following finalisation of the revised EBA Guidelines on internal governance

Suggested considerations

• Review the ECB press release and associated lists of discontinued publications to identify any ECB guides, reports, letters or methodologies currently referenced in your internal policies, risk frameworks or model documentation that are now labelled as discontinued.
• Update internal policy inventories, regulatory mapping and compliance registers to reflect the new classification of ECB supervisory guidance as non‑binding and to distinguish clearly between binding EU/national law and non‑binding ECB expectations.
• For banks using the ICAAP Guide, perform a gap analysis of capital planning and management buffer practices against the forthcoming clarified expectations, ensuring internal documentation clearly differentiates management buffers from Pillar 2 requirements and guidance.
• For institutions using internal models for credit risk, remove any reliance on the ECB’s former CCF expectations by re‑mapping modelling policies and documentation to forthcoming EBA guidelines on credit conversion factors and to CRR/CRD provisions, once those guidelines are finalised.
• For risk and finance functions, review the CVA treatment in internal capital and risk methodologies to verify alignment with CRR III and ensure that internal references to ECB guidance (assessment methodology, materiality assessment) are updated to reflect the removed CVA content.

What changed

• - The ECB is conducting a comprehensive review of around 130 supervisory publications (guides, reports, letters, methodologies) to assess their relevance, effectiveness and clarity and to align them...
• Approximately 40 supervisory documents have been classified as outdated, superseded or no longer relevant and have been formally discontinued, with the texts remaining accessible but clearly labelled...
• The ECB has updated its classification of supervisory guidance documents to emphasise explicitly that they are non‑binding, do not create new legal obligations and do not replace binding EU or...
• The Guide to the internal capital adequacy assessment process (ICAAP Guide) will be revised to clarify supervisory expectations on the management buffer, explicitly positioning it as the bank’s own...
• The ECB has removed all content on supervisory expectations for the credit conversion factor (CCF) from the Guide to internal models, in anticipation of forthcoming EBA guidelines on CCF, thereby...

Key dates

2026-06-25

FDIC Board met in open session and approved three notices of proposed rulemaking

Suggested considerations

• Compliance teams may wish to assess whether the institution would fall above the proposed resolution-submission threshold if raised to $100 billion in assets.
• Firms may wish to inventory current resolution-planning, interim supplement, and public-section processes to identify work that could be reduced or repurposed if the proposal is finalized.
• Assessment and finance teams may wish to model the impact of a $10 billion to $30 billion threshold change and any indexed future adjustments on deposit insurance assessments.
• Legal and information-governance teams may wish to review confidentiality-agreement templates and third-party-sharing controls in anticipation of broader permitted disclosure under Part 309.
• Institutions currently subject to FDIC resolution submissions may wish to monitor whether the proposed filing-cycle change to every three years alters internal preparation calendars and governance approvals.

What changed

The Board approved a notice of proposed rulemaking to revise resolution-submission requirements for covered insured depository institutions; secondary reporting indicates the proposal would raise the applicability threshold from $50 billion to $100 billion in total assets, move covered institutions to a three-year filing cycle, eliminate certain interim supplements and public sections, and remove a substantial portion of current narrative content requirements.

Key dates

2017

- Staff no-action letters began providing the interim reporting approach for certain fully collateralized event contracts

TBD (est. late 2026)

- The proposal will proceed through the public-comment process and could later be finalized, subject to Commission action

13 May 2026

- CFTC staff issued a no-action letter regarding swap data reporting and recordkeeping for event contracts, reinforcing the temporary relief framework

25 June 2026

- The CFTC published the Notice of Proposed Rulemaking seeking public comment on amendments to Parts 15, 16, and 17

Suggested considerations

• Firms that list, clear, intermediate, or report covered event contracts should inventory all event-contract products and map each product to the current reporting regime and the proposed Parts 15 through 18 framework.
• Compliance teams should identify all reporting fields, systems, and workflows currently relying on Parts 38, 39, 43, or 45 for event-contract reporting and assess whether those processes would need redesign.
• FCMs, clearing members, and foreign brokers should review their data governance and source-of-truth controls to ensure they can produce the reporting elements required under §16.00, §16.01, Part 17, and Part 18 if the proposal is adopted.
• Firms should track the public-comment process and prepare comments if the proposed framework creates operational gaps, duplicated reporting, or ambiguities in product scope.
• Market participants should review reliance on existing no-action letters and prepare contingency plans for a transition from interim relief to a codified rule.

What changed

• - The CFTC proposes an alternate reporting framework for certain fully collateralized event contracts, replacing reliance on certain reporting provisions in Parts 38, 39, 43, and 45 with reporting...
• The proposal would amend Part 15, Part 16, and Part 17 of the CFTC’s regulations.
• The proposal would add a new §16.03 titled “Covered Event Contracts” to Part 16.
• The proposal would require reporting pursuant to §16.00, §16.01, Part 17, and Part 18 for covered event contracts.
• The proposal would apply to reporting by certain reporting markets, futures commission merchants, clearing members, and foreign brokers.

Key dates

2026-06-25

Federal Reserve Board announced the consent cease-and-desist order against Jason Burns

Suggested considerations

• Compliance teams may wish to review lending approval, exception, and escalation controls for any patterns that could be characterized as unsafe lending.
• Firms may wish to assess whether board and senior management oversight of credit extensions is documented clearly enough to withstand supervisory scrutiny.
• Institutions may wish to confirm that conflicts of interest, insider influence, and related-party lending safeguards are operating effectively.
• Banks may wish to ensure that examination issues identified in credit administration are remediated before they become individual enforcement matters.

What changed

The publication records a new formal enforcement action: a consent cease-and-desist order against Jason Burns. The stated basis is unsafe lending practices, but the press release does not describe the underlying factual findings, operational requirements, monetary penalties, or remediation deadlines. The action is an individual supervisory response connected to an Oklahoma bank and its holding company, indicating the Fed viewed the conduct as serious enough to warrant public enforcement.

Key dates

01 April 2025

- Start of the reporting period for the Bank of England and PRA’s 2025/26 Prescribed Persons whistleblowing report

31 March 2026

- End of the reporting period for the 2025/26 whistleblowing disclosures referenced in the Bank and PRA report

By 30 September 2026 (within six months of 31 March 2026) Deadline

- Latest date by which the Bank and PRA are required under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 to publish the written annual report on disclosures for the 2025/26 period

Suggested considerations

• Establish clear internal processes for responding when the PRA or Bank contacts the firm following a whistleblowing disclosure, including immediate escalation to Compliance, Legal, and relevant Senior Managers, coordinated responses, and robust documentation of remedial actions.

What changed

• - Prescribed Persons reporting obligations under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 continue to apply, requiring the Bank and PRA to publish, within six...
• For the 2025/26 period, the Bank and PRA report that 271 disclosures were received and assessed against the Public Interest Disclosure Act 1998 and their own statutory requirements to determine...
• Of the 271 disclosures, 257 were reasonably believed to be protected disclosures within Part IVA of the Public Interest Disclosure Act 1998 and within the Bank’s and PRA’s remit as Prescribed...
• Fourteen disclosures were assessed as not protected, including disclosures about firms not regulated by the Bank or PRA, issues outside the Bank’s or PRA’s regulatory remit, and individuals who do...
• Regardless of statutory protection status, the Bank and PRA’s whistleblowing team provided supervisory colleagues with all disclosures (protected and non‑protected) for consideration or for...

Key dates

01 March 2025

- Start of the reporting period covered by the EDMC annual report

Summer 2026 Deadline

- Remaining EDMC members, including the incoming Chair and Deputy Chair, are due to be appointed

28 February 2026

- End of the reporting period covered by the EDMC annual report

28 February 2026

- As of this date, the PRA enforcement team was overseeing five cases, including investigations into five firms and five individuals

June 2026

- The EDMC annual report for 2025/26 was published

Suggested considerations

• Review your firm’s PRA enforcement response plan to ensure it supports rapid collection, review, and production of material that may be disclosed in a contested case.
• Ensure legal and compliance teams are prepared to make both written and oral representations to the EDMC if the firm becomes subject to a contested enforcement matter.
• Confirm that internal governance provides for independent escalation and board-level oversight when a PRA investigation enters the decision stage.
• Maintain an updated settlement strategy for PRA matters, including documented positions on fairness, scope of admissions, and mitigation, because the EDMC may review settlement processes retrospectively.
• Map exposure across all PRA enforcement regimes relevant to the business, including prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties, and S&NI banknote matters.

What changed

• - The EDMC completed its annual reporting cycle for the period 1 March 2025 to 28 February 2026, confirming the continued operation of the PRA’s contested-case decision framework.
• The report confirms that the EDMC continues to provide functional separation between investigation/enforcement staff and decision-makers in PRA contested enforcement cases.
• The report confirms that the EDMC’s role covers enforcement cases under the Bank’s statutory regimes for prudential regulation, financial market infrastructure, resolution, securitisation, wholesale...
• The EDMC confirms that contested enforcement decisions are made independently, with disclosure of relevant material and the opportunity for both written and oral representations.
• The EDMC confirms that its decision is the final stage of administrative decision-making in contested PRA enforcement cases, after which the subject may refer the matter to the Upper Tribunal.

Key dates

10 January 1994

- Summit Ascent Holdings Limited is listed on the Main Board of the Stock Exchange of Hong Kong

22 February 2007

- LET Group Holdings Limited is listed on the Main Board of the Stock Exchange of Hong Kong

September 2024

- The SFC commences legal proceedings under section 214 SFO against Mr Lo, LET and Summit Ascent

27 September 2024

- The SFC issues a press release giving further details of the section 214 proceedings against Mr Lo, LET and Summit Ascent

01 September 2025

- The shares of LET and Summit Ascent are delisted from the Main Board of the Stock Exchange of Hong Kong

Suggested considerations

• Review and map all relationships with controlling shareholders, directors and their offshore vehicles to identify where client assets may be exposed to SFC-driven freezing orders or Chabra relief.
• Update internal litigation and regulatory investigations playbooks to explicitly cover section 214 SFO risks, including the potential for worldwide asset-freezing and receiver appointments even after an issuer is delisted.
• Implement enhanced due diligence on beneficial ownership and control structures, particularly BVI and other offshore vehicles used by controlling shareholders of Hong Kong-listed and recently delisted issuers.
• For banks, broker dealers and custodians, review current accounts, credit exposures, collateral and custody arrangements for clients who are directors, controlling shareholders or their vehicles in Hong Kong issuers, and identify those at heightened risk of SFC enforcement.
• Enhance early-warning triggers in compliance monitoring to escalate promptly when the SFC announces section 214 SFO proceedings or issues press releases suggesting asset preservation measures may be sought.

What changed

• - The Court of First Instance has granted a worldwide freezing injunction over the assets of Mr Lo Kai Bong, prohibiting him from removing, disposing of, dealing with or diminishing the value of his...
• The Court has concurrently granted a worldwide Chabra injunction over the assets of Major Success Group Limited, a BVI company wholly owned and controlled by Mr Lo, on the basis that its assets may...
• The injunctions apply to assets in Hong Kong and worldwide, significantly expanding enforcement risk beyond Hong Kong-situs assets for controlling shareholders and their offshore structures.
• The Court has ordered that both injunctions remain in effect at least until 26 August 2026, subject to further order, meaning the assets will be frozen through the lead-up to trial.
• The injunctions are explicitly tied to ongoing section 214 SFO proceedings seeking remedies for unfair prejudice and misconduct, including a share repurchase order for independent shareholders of LET...

Key dates

15 July 2025

– Payments Vision Delivery Committee agrees the new public‑private model to deliver the next‑generation UK retail payments infrastructure under the National Payments Vision

Late 2026

– HM Treasury and the Bank of England are expected to publish conclusions on whether, and in what form, to proceed with a digital pound, which will influence infrastructure design and multi‑money functionality (date inferred as “later this year”)

25 June 2026

– Retail Payments Infrastructure Board consultation on the design of the future UK retail payments infrastructure is launched

11 September 2026 Deadline

– Deadline for stakeholders to submit responses to the RPIB consultation on the next‑generation retail payments infrastructure

Suggested considerations

• Identify internal stakeholders (payments product, technology, operations, legal, compliance, risk) and establish a formal project to coordinate your firm’s response to the RPIB consultation.
• Perform a gap analysis of your firm’s current use of Faster Payments, Bacs and cheque imaging, focusing on account‑to‑account capabilities, cross‑border flows, fraud and financial crime controls, customer authentication and operational resilience.
• Map and document key payment journeys relevant to your firm (e.g. point‑of‑sale account‑to‑account payments, bill payments, peer‑to‑peer transfers, ecommerce, cross‑border transactions) to enable substantive feedback on user needs and design priorities.
• Assess your firm’s strategic interest in account‑to‑account payments at the point of sale and enhanced cross‑border services, and identify functional requirements (APIs, messaging, reconciliation, chargeback‑like protections) that should be reflected in the consultation response.
• Review emerging regulatory publications under the National Payments Vision and Payments Forward Plan to ensure your consultation input aligns with expected regulatory outcomes on access, competition, resilience and innovation.

What changed

• - The RPIB has opened a consultation to develop a high‑level “blueprint” for the future UK retail payments infrastructure, which will underpin the National Payments Vision and inform the design to be...
• The consultation scope explicitly covers payment journeys, key design choices and priorities for the next‑generation infrastructure, rather than setting immediate prescriptive rules for firms.
• The next‑generation infrastructure is intended to support new payment methods, including account‑to‑account payments at the point of sale (in‑store and online) as a complement to card payments, and...
• Existing retail interbank payment systems (Faster Payments, Bacs, Image Clearing System) operated by Pay.UK will continue to run safely and resiliently during the transition, implying a multi‑year...
• The new infrastructure is being designed to support a multi‑money ecosystem, including existing commercial bank money and emerging forms of digital money (e‑money, tokenised deposits, systemic...

Key dates

May 2023

- The PRA published Consultation Paper CP9/23, which proposed changes later reflected in the updated enforcement approach

30 January 2024

- The Bank of England unveiled changes to the PRA’s enforcement approach, including the Early Account Scheme and the Enhanced Settlement Discount

24 June 2026

- David Chaplin delivered the speech at the 5th Conference on Financial Law and Regulation at the University of Leeds School of Law

Suggested considerations

• Review current investigation-response procedures to ensure the firm can produce a factually complete written account and supporting evidence at short notice.
• Build escalation protocols that trigger early internal fact-finding when a potential prudential breach is identified.
• Train relevant staff to distinguish between cooperation, factual admissions, and without-prejudice settlement positions so that engagement does not inadvertently prejudice legal strategy.
• Reassess whether current incident-management playbooks are aligned with the PRA’s expectation of early candour and remediation.
• Ensure legal, compliance, and business stakeholders can rapidly agree on breach acknowledgment, remediation steps, and document preservation.

What changed

• - The PRA is now explicitly encouraging earlier engagement by investigation subjects, including proactive identification, acknowledgement, and remediation of breaches.
• The familiar enforcement pattern is changing from a late-stage admission model toward a front-loaded investigative model in which firms provide information earlier in the process.
• The PRA’s enforcement approach now places greater emphasis on written factual accounts and supporting materials during the initial investigative stage.
• Firms that participate early and make early admissions may obtain enhanced settlement discounts, while non-participants remain on a lower discount path.
• The Bank says this is not a new policy launch but an explanation of how the existing approach is operating in practice across live cases.

Key dates

TBD (from AMLA operational go‑live date in 2025–2026)

- AMLA formally designates its first batch of directly supervised obliged entities at EU level, potentially including entities identified under this circular

25 June 2026

- CSSF publishes Circular 26/914 identifying obliged entities eligible for direct supervision by AMLA and setting the framework for Luxembourg’s contribution to AMLA’s selection and supervisory process

TBD (periodic, post‑AMLA go‑live)

- Periodic reviews by AMLA and the CSSF of eligible entities’ status and updates to the list of entities subject to, or proposed for, direct AMLA supervision

Suggested considerations

• Determine whether your firm is likely to fall within the “eligible for AMLA direct supervision” perimeter by assessing your cross‑border footprint, ML/TF risk profile, group structure, and relative size against AMLA’s high‑risk and cross‑border criteria.
• Review and update the firm‑wide AML/CFT risk assessment to ensure it is robust, data‑driven, and aligned with an EU‑level supervisory perspective, including explicit consideration of cross‑border risks, complex group structures, and high‑risk products.
• Strengthen AML/CFT governance and oversight, including Board and senior management reporting, to demonstrate clear ownership of ML/TF risk, documented risk appetite, and effective challenge consistent with what AMLA expects from directly supervised entities.
• Review and, where necessary, enhance customer due diligence, transaction monitoring, screening and suspicious activity reporting frameworks to withstand more intrusive and harmonised EU‑level scrutiny.
• Map and document cross‑border business lines and passporting activities (branches, agents, tied intermediaries, distributors) to ensure you can provide complete and up‑to‑date information to the CSSF and AMLA on request.

What changed

• - The CSSF formally identifies Luxembourg “obliged entities” under AML/CFT law that are potentially eligible for direct AMLA supervision, clarifying which categories of firms fall into the EU‑level...
• The circular operationalises, at CSSF level, the EU allocation mechanism for direct supervision, building on Regulation (EU) 2024/… establishing AMLA and the forthcoming directly applicable AML...
• The CSSF establishes a process for providing information to AMLA on Luxembourg obliged entities (e.g. size, cross‑border activities, risk profile) to support AMLA’s periodic selection and review of...
• The circular clarifies that CSSF‑supervised entities identified as “eligible” remain under CSSF supervision unless and until AMLA formally designates them for direct supervision, at which point AMLA...
• The circular anticipates enhanced data and reporting requirements for entities assessed as eligible for AMLA direct supervision, including more granular information on cross‑border business,...

Key dates

23 June 2026

- CFTC files its lawsuit against Kentucky to block enforcement actions and special transaction fees against CFTC‑registered DCMs

TBD (2026–2027)

- Key procedural milestones in *CFTC v. Kentucky* (motion practice, preliminary injunction hearings, and potential appellate review), which will shape how quickly and broadly federal preemption over prediction markets is clarified

TBD (aligned with ongoing cases in Minnesota, Illinois, Rhode Island)

- Progression of related CFTC suits and amicus‑briefed appeals in the Sixth Circuit, Ninth Circuit, and Massachusetts Supreme Judicial Court, which will collectively define the jurisdictional perimeter for event contracts

Suggested considerations

• Review and update state‑law risk assessments for all CFTC‑regulated DCM activities, with a specific focus on gambling, consumer‑protection, tax, and licensing regimes in Kentucky and other active states.
• Conduct a targeted legal analysis of whether existing or planned event‑based or prediction‑market contracts might be recharacterised as gambling under relevant state laws, and document the basis for treating them as CFTC‑regulated derivatives.
• Map all customer‑facing operations, servers, marketing, and on‑the‑ground presence in Kentucky and other contentious states, and evaluate whether operational changes (e.g. geofencing, revised onboarding flows) are warranted pending judicial outcomes.
• Engage external counsel to monitor *CFTC v. Kentucky* and related state and federal cases, and establish an internal escalation protocol so that material developments (e.g. injunctions, adverse rulings) trigger prompt compliance and product‑governance review.
• Update board and senior management reporting to include a standing item on state–federal jurisdictional conflicts affecting prediction markets, highlighting litigation exposure, revenue at risk, and contingency plans.

What changed

• - The CFTC has initiated federal litigation against Kentucky seeking declaratory and injunctive relief to prevent the state from enforcing civil actions and special transaction fees against...
• Kentucky has filed civil enforcement actions in state court against CFTC‑regulated DCMs, characterising their event contracts as illegal gambling and seeking substantial monetary penalties.
• Kentucky has adopted a new “special transaction fee” (functionally an excise or levy) specifically targeting transactions on CFTC‑regulated DCMs, intended to incentivise these platforms to cease...
• The CFTC is explicitly framing Kentucky’s actions as an impermissible interference with Congress’s federal preemption framework and the CFTC’s exclusive jurisdiction over futures, options, and swaps,...
• The Commission is building a broader litigation strategy, noting parallel proceedings against Minnesota, Illinois, and Rhode Island and amicus participation before the Sixth and Ninth Circuits and...

Key dates

2026-06-23

BIS published the press release and pre-released the relevant Annual Economic Report 2026 chapter

2026-06-28

BIS plans to publish the full Annual Economic Report 2026 and the BIS Annual Report 2025/26

Suggested considerations

• Compliance teams may wish to assess whether any stablecoin-related business line depends on assumptions about parity redeemability, interoperability, or reserve quality that BIS identifies as weak points.
• Firms involved in tokenisation initiatives may wish to map their proposed operating model against the two-tier framework BIS endorses, especially where central bank money, commercial bank money, and tokenised assets would interact on programmable platforms.
• Banks and payment providers may wish to review funding, liquidity, and settlement assumptions for any products that could materially increase stablecoin usage or tokenised-money circulation.
• Crypto-facing firms may wish to examine whether current controls for financial crime, ledger interoperability, and customer redemption rights would satisfy a more stringent supervisory approach if stablecoins are used at scale.
• Market infrastructure and capital markets firms may wish to consider whether a unified-ledger or tokenised-deposit architecture could reduce reconciliation and settlement frictions in cross-border or wholesale workflows.
• Risk and policy teams may wish to monitor BIS follow-on publications, including the full Annual Economic Report 2026, for more detailed supervisory or implementation signals when it is published on 2026-06-28.

What changed

The publication is a policy signal, not a binding rule. BIS argues that tokenisation—digital representation of assets on programmable platforms—can be embedded in the current monetary architecture, where central banks provide the monetary anchor and commercial banks provide services to the public, to enable programmable payments and other efficiencies. BIS also states that current stablecoin designs fall short of the key properties of money, particularly singleness, meaning the ability to redeem different forms of money exactly at par for central bank money.

Key dates

22 September 2025

- SFC consultation on HKIDR‑DM published (page last updated on this date)

22 December 2025

- End of three‑month consultation period; last date for submissions to SFC on HKIDR‑DM proposals

Q2 2028

- Target implementation of HKIDR‑DM, concurrent with HKEX’s launch of the Orion Derivatives Platform, subject to completion of system testing and market rehearsals

Suggested considerations

• Conduct a gap analysis comparing existing HKIDR‑S securities processes with expected HKIDR‑DM derivatives requirements, covering data fields, identifiers, and order tagging for futures and options.
• Identify all business lines and systems that submit or route HKFE on‑exchange futures, options and stock options orders, and map required integration points with the HKIDR‑DM centralised data repository.
• Design and implement or adapt a client identification and coding framework (e.g. investor IDs or broker‑to‑client numbers) for derivatives clients, ensuring consistency across securities and derivatives where clients trade both.
• Review and update client onboarding, KYC and data collection forms to ensure capture of all identity information required under HKIDR‑DM, including for existing derivatives clients.
• Develop and implement data protection and privacy controls to manage personal data submitted under HKIDR‑DM, including access controls, retention policies, and compliance with Hong Kong’s Personal Data (Privacy) Ordinance.

What changed

• - The SFC will implement the Hong Kong Investor Identification Regime for the Derivatives Market (HKIDR‑DM), extending investor ID requirements from securities (HKIDR‑S) to exchange‑traded...
• HKIDR‑DM will apply to on‑exchange orders for futures contracts, options contracts and stock options executed through the trading system of Hong Kong Futures Exchange Limited (HKFE).
• Licensed corporations and registered institutions which offer brokerage services or conduct proprietary trading in HKFE‑traded derivatives will be required to submit clients’ names and identity...
• The operational model of HKIDR‑DM will be similar to HKIDR‑S, implying the use of unique client identifiers and order‑level tagging across trading, middle office and reporting systems.
• Implementation of HKIDR‑DM is targeted for the second quarter of 2028, subject to successful completion of system testing and market rehearsals.

Key dates

2026-06-22

OCC bulletin announcing the notice of proposed rulemaking was issued

2026-07-22 Deadline

Planned deadline for comments, if the Federal Register publication date aligns with the bulletin date and the OCC’s 30-day comment period is measured from publication

Suggested considerations

• Compliance teams may wish to assess whether the entity falls within the OCC-supervised PPSI category or within the state-qualified issuer population covered by OCC authority under the GENIUS Act.
• Firms may wish to review existing AML/CFT and sanctions controls against the BSA, FinCEN, and OFAC requirements referenced in the proposal, including reporting, monitoring, and risk assessment procedures.
• Compliance teams may wish to map governance, escalation, and record-sharing workflows to the proposed OCC-FinCEN consultation framework, particularly for potential significant supervisory or enforcement matters.
• Firms may wish to consider whether their current policies, procedures, and internal controls are sufficiently tailored to stablecoin-specific risks and whether additional board or senior management oversight would be needed.
• Compliance teams may wish to evaluate whether they should submit comments during the 30-day Federal Register comment period if aspects of the proposed framework could affect operating models or compliance design.

What changed

The proposed rule would require OCC-supervised PPSIs to comply with the BSA, sections 4(a)(5) and 4(a)(6)(B) of the GENIUS Act, and applicable FinCEN and OFAC regulations, including AML/CFT program, sanctions program, and reporting requirements. It would also create a supervision and enforcement framework for PPSI AML/CFT programs, so the OCC can take AML/CFT supervisory and enforcement action against covered issuers. The rule would establish a formal consultation process between the OCC and FinCEN when the OCC intends to initiate an AML/CFT enforcement action or a significant AML/CFT...

Key dates

27 October 2022

- Circular CSSF 22/822 was issued, establishing the framework for using FATF statements on high-risk jurisdictions and jurisdictions under increased monitoring

19 June 2026

- The annex was updated to this version date, reflecting the current FATF jurisdiction lists and associated risk posture

22 June 2026

- CSSF published the annex on its website, making the updated reference document operationally relevant for supervised firms

Suggested considerations

• Review your AML/CFT country-risk methodology and update it to reflect the 19 June 2026 FATF/CSSF jurisdiction list.
• Re-screen customers, beneficial owners, counterparties, and transactions against the updated high-risk and monitored jurisdiction lists.
• Apply enhanced due diligence for relationships and transactions involving high-risk jurisdictions, and escalate where counter-measures may be required.
• Reassess risk ratings for customers linked to jurisdictions under increased monitoring and document the rationale for any continued onboarding, retention, or exit decisions.
• Update automated screening rules, transaction-monitoring scenarios, and onboarding checklists so they use the current CSSF annex version.

What changed

• - CSSF republished the annex to Circular CSSF 22/822 in a Version of 19 June 2026, meaning firms should treat this as the current Luxembourg reference point for FATF jurisdiction screening and...
• The annex distinguishes between high-risk jurisdictions subject to enhanced due diligence and, where appropriate, counter-measures, and jurisdictions under increased monitoring that require...
• The publication incorporates the FATF’s current statements on jurisdictions with strategic AML/CFT/CPF deficiencies, which is the basis for operational country-risk controls used by...
• The related Circular CSSF 22/822 remains the framework document that instructs professionals to use FATF statements when assessing jurisdictional ML/TF/PF risk.