ESMA publishes report on cross-border marketing of funds including statistics on notifications 06 January 2026 The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published its third report on marketing requirements and marketing communications under the Regulation on cross-border distribution of funds . For the first time, the report includes statistics on notifications of cross-border marketing of funds. Drawing on input from ...
ESMA signs Memorandum of Understanding with the Reserve Bank of India 27 January 2026 CCP International cooperation The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has signed a Memorandum of Understanding (MoU) with the Reserve Bank of India (RBI) to facilitate cooperation and exchange of information for the recognition of central counterparties (CCPs) established in India and supervised by RBI. This agreement marks a significant step...
FCA stunt launches new Firm Checker tool as around 700,000 people lose money to investment scams. Morning commuters at London Waterloo got more than their usual caffeine hit today when a mysterious 'ATM' promising to 'give away a fortune' stopped them in their tracks – and revealed an unexpected surprise.As curious passers-by approached the machine, the screen slid open to unveil Emil the Seal, the FCA's finance-friendly mascot, delivering a blunt message about the dangers of investment scams...
We’re working closely with the Office of Financial Sanctions Implementation (OFSI), UK law enforcement, and our regulatory partners to tackle the abuse of cryptoassets and associated money‑laundering activities. Read the full blog on the OFSI’s website.
We have signed a contract with Etrading Software (ETS) to deliver the UK bond consolidated tape. A high-quality tape will provide investors with a comprehensive overview of the bond market and support price formation and liquidity. It will help maintain the UK’s position as a highly competitive and compelling place to invest and grow.ETS has now launched a website that sets out key milestones and provides technical information for data contributors and users. We will continue to support ETS a...
The FCA has launched a review into the implications of advanced AI on consumers, retail financial markets and regulators. The Review will be led by Sheldon Mills and builds on the FCA’s existing work on AI. This includes its AI Discussion Paper, AI Sprint, and AI Lab including AI Live Testing and its groundbreaking Supercharged Sandbox supported by NVIDIA.AI is already embedded across financial services. Rapid advances in generative, agentic and emerging forms of AI mean the next phase of cha...
On 21 January 2026, Guavapay Limited entered compulsory liquidation. The Official Receiver, an officer of the Insolvency Service, is its liquidator. Guavapay is authorised by the FCA to issue E-money and provide payment services to its customers.On 17 September 2025, Guavapay agreed to a voluntary requirement with the FCA, restricting the activities it can undertake. See details on the Financial Services Register.As liquidator, The Official Receiver is responsible for:Managing customer claims...
Sanctions & settlements MAR Compliance Journalists Investment services providers The AMF Enforcement Committee fines an investment services provider and its director a total of €850,000
Securities and Exchange Commission Chairman Paul S. Atkins and Commodity Futures Trading Commission Chairman Michael S. Selig will hold a joint event, previously scheduled for Jan. 27, now rescheduled for Thursday, Jan. 29, from 2 p.m. to 3 p.m. at CFTC…
This FINRA Information Notice dated August 14, 2025, reminds registered persons and firms of annual continuing education (CE) requirements under FINRA Rule 1240, including 2025 Regulatory Element completion by December 31, 2025, and resources for Firm Element plans via the FLEX catalog. It matters because non-compliance triggers automatic CE inactive status, halting registered activities, with today's date (January 25, 2026) indicating the deadline has passed, requiring immediate remediation for affected individuals.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
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What Changed
Effective January 1, 2023, amendments to FINRA Rule 1240 mandate annual completion of both Regulatory Element and Firm Element for all registered persons, per CE Council recommendations.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Launched July 1, 2024, the Financial Learning Experience (FLEX) serves as an optional centralized catalog for Firm Element e-learning courses to support written training plans.[https://www.finra.org/rules-guidance/notices/information-notic
What You Need To Do
Registered persons
Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions
Key Dates
January 1, 2023- Effective date of CE rule amendments requiring annual Regulatory and Firm Elements.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
July 1, 2024- Launch of FLEX catalog for Firm Element resources.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
October 1 (annually)- FINRA publishes upcoming Regulatory Element topics by registration category.
December 31, 2025- Deadline to complete 2025 Regulatory Element courses; non-completion results in automatic CE inactive status.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]DEADLINE
Compliance Impact
Urgency: High - The December 31, 2025, deadline has passed (as of January 25, 2026), meaning non-compliant registered persons are already CE inactive and barred from registered functions until remediation, risking operational disruptions, exam retakes, or enforcement. Firms face supervisory liabilit
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
CP25/15 proposes prudential rules and guidance for UK firms issuing **qualifying stablecoins** and safeguarding **qualifying cryptoassets**, aiming to foster a safe, competitive crypto sector while prioritizing consumer protection and market integrity. This matters for compliance professionals as it introduces tailored prudential sourcebooks (COREPRU and CRYPTOPRU) to mitigate firm failure risks, aligning with the FCA's crypto roadmap and Treasury's statutory plans.
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What Changed
Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own funds adequacy, capital resources, and stress-adjusted internal capital assessments.
Own Funds and Capital Rules: Firms must hold financial resources adequate in amount and quality, including adjustments for valuation uncertainty, stress realizable values, and interim profits in CET1 capital; supplement
What You Need To Do
Respond to Consultation
Assess Applicability
Prepare Prudential Frameworks
Engage on Related CPs
Data and Reporting Readiness
Key Dates
28/05/2025- Consultation opens and CP first published.
31/07/2025- Consultation closes; submit feedback via online form, email ([email protected]), or post.
Post-31/07/2025- FCA considers feedback and publishes final rules (no specific date given).
Q3 2025- Upcoming Conduct and Firm Standards CP affecting all cryptoasset firms, including QS issuers and custodians.
Future (CP2 per Roadmap)- Consultation on remaining prudential sourcebook requirements.
Compliance Impact
Urgency: High – As of January 2026, the consultation closed over five months ago, signaling imminent final rules that could reshape prudential requirements for crypto firms; non-compliance risks authorization barriers, enforcement, or market exclusion in a regime prioritizing stability amid global c
The FCA's PS25/22 establishes a new regulatory framework for **targeted support**—a form of financial guidance that allows authorised firms to provide ready-made suggestions to consumer segments without conducting individualised suitability assessments. This framework addresses the UK's "advice gap" by enabling firms to deliver affordable, scalable financial support to an estimated 18 million consumers within a decade, fundamentally shifting how retail investors and pension savers access guidance on investment and retirement decisions.
What Changed
The framework introduces several material regulatory changes:
*New Specified Activity Status**
Targeted support will be designated as a new specified activity under the Regulated Activities Order, meaning only FCA-authorised firms can provide this service. This creates a regulatory boundary distinct from both unregulated guidance and regulated investment advice.
*Purpose Statement Refinement**
The FCA amended its original purpose statement from "better outcomes" to "better position" to clarify
What You Need To Do
*Immediate (January–February 2026)
*Pre-Implementation (March 2026)
Consumer segment definitions with supporting rationale
Ready-made suggestion frameworks
Communication templates explaining the nature of targeted support
Key Dates
29/08/2025- Consultation period closed (CP25/17 and CP25/26)
11/12/2025- Policy Statement PS25/22 published with near-final rules
March 2026- Firms may begin applying for targeted support permission
06/04/2026- New rules expected to come into force (subject to Government legislation making targeted support a specified activity)
ASIC successfully defends special leave application to the High Court by Cigno Australia director Mark Swanepoel and BSF Solutions director Brenton Harrison
ASIC takes action against MWL Financial Services, former director Nicholas Maikousis, and Imperial Capital Group Australia over alleged Shield advice failures
We urge consumers thinking of investing in high-risk securities, such as mini-bonds and loan notes, to continue to be cautious. On 19 January 2026, the Public Offers and Admissions to Trading regime came into force. The regime sets new rules and standards about when an offer of securities to the public can be made.A security is a financial instrument that represents some type of financial value (for example, shares, bonds and stock) that can be traded on a financial exchange.The types of secu...
We are seeking views on further rules for cryptoasset firms as the final step in our consultations on our crypto rules. We have made significant progress in delivering our crypto roadmap and are helping firms to meet our standards and get ready for when the gateway opens in September 2026.We have set out our proposals on how the Consumer Duty, conduct standards, redress and safeguarding will apply to cryptoasset firms. We are also seeking feedback on our proposed approach to international cry...
Securities and Exchange Commission Chairman Paul S. Atkins and Commodity Futures Trading Commission Chairman Michael S. Selig will hold a joint event on Tuesday, Jan. 27, from 10 a.m. to 11 a.m. at CFTC headquarters to discuss harmonization between the…
The Securities and Exchange Commission’s Small Business Capital Formation Advisory Committee announced that it will hold a public meeting at the SEC Headquarters in Washington, D.C., on Tuesday, Feb. 24, 2026, at 10 a.m. ET. The meeting will also be…
Speech by Sheree Howard at the FCA's Gateway to growth, Chicago Booth London Conference Centre. The first time I flew was in my teenage years, and like many of my generation, that was a flight to Europe for a family holiday. I didn’t make it further afield until I was in my mid to late twenties.Today, most, if not all of us, would think of international travel as the norm – especially given the global nature of our business.It is amazing, therefore, to think that right around this time in 197...
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered in WhatsApp groups operated by Leading Asset Management, Denver, USA. BaFin suspects the operators of offering consumers financial, investment and cryptoasset services in these groups without the required authorisation.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website skyvault(.)ltd. BaFin has information that the operators are offering banking business and/or financial services on this website without the required authorisation. The operators are not supervised by BaFin.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered by Aureus Trade. BaFin suspects the unknown operators of the website aureus-trade(.)com of offering consumers financial, investment and cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website bxforex(.)com. According to information available to BaFin, this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the company Rostock24 Limited and the services it is offering. BaFin suspects the unknown operators of the website rostock24(.)com of offering consumers financial, investment and cryptoasset services without the required authorisation. Rostock24 Limited, which purportedly has its head office in Nuremberg, claims to be registered with the British Companies House. This is not the case.
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address info[at]vcgmanagement.de. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from VC Germany Management GmbH. This is a case of identity theft.
The Securities and Exchange Commission is seeking candidates to fill a limited number of vacancies on the agency’s Small Business Capital Formation Advisory Committee, which provides advice and recommendations to the Commission on rules, regulations, and…
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website bb-consults(.)com. BaFin has information that this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
The Securities and Exchange Commission today announced the senior team from the Division of Corporation Finance responsible for advising division Director James Moloney on all matters the division has before the Commission. These include rulemaking…
The Securities and Exchange Commission today announced that Christina M. Thomas will rejoin the Division of Corporation Finance in February as deputy director and chief advisor on disclosure, policy, and rulemaking.“Christina brings her deep technical…
The Securities and Exchange Commission today announced that Keith E. Cassidy has been appointed Director of the Division of Examinations. Mr. Cassidy has served as Acting Director since May 2024 and previously was the division’s Deputy Director, Acting…
We have issued a joint statement with the Payment Systems Regulator (PSR) giving clarity on open banking pricing models. We and the PSR have issued the following statement (PDF).This confirms we will not, at this stage, prioritise a Competition Act 1998 (CA98) investigation into the centralised ‘access fee’ pricing model being developed by the UK Payments Initiative (UKPI) for commercial Variable Recurring Payments (cVRPs). cVRPs are an emerging open banking technology that allow consumers to...
AI Analysis
The FCA and PSR have jointly confirmed they will not prioritize a Competition Act 1998 investigation into the UK Payments Initiative's (UKPI) centralized access fee pricing model for commercial Variable Recurring Payments (cVRPs), with the CMA's concurrent agreement. This regulatory clarity provides temporary certainty for cVRP development ahead of anticipated legislation by end-2026, creating a critical window for firms to develop compliant commercial models in this emerging open banking technology.
What Changed
The regulatory statement establishes the following key positions:
Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase 1/Wave 1 cVRPs (limited to "lower risk" use cases).
Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services
What You Need To Do
*For UKPI and participating firms
*Governance documentation
*Pricing methodology transparency
*Phase 1/Wave 1 compliance
*Market engagement
Key Dates
15 January 2026- FCA and PSR wrote to CMA setting out their non-prioritization position
16 January 2026- CMA confirmed alignment with FCA/PSR position on CA98 prioritization
20 January 2026- Joint FCA/PSR statement issued on open banking pricing models
Q1 2026- Expected first live UKPI cVRP payments
End of 2026- Government anticipated to introduce legislative framework granting FCA new open banking powers
The FCA and PSR have issued a joint statement providing clarity on open banking pricing models, specifically regarding the centralised 'access fee' pricing model for commercial Variable Recurring Payments (cVRPs). This statement confirms that they will not prioritize a Competition Act 1998 investigation into this model at this stage. The goal is to support the development of cVRPs, giving consumers more control over their payments and lowering processing fees for businesses.
What Changed
The FCA and PSR have clarified their enforcement position on the UKPI's proposal for a commercial model for cVRPs, indicating they will not prioritize a Competition Act 1998 investigation at this stage.
What You Need To Do
Monitor market developments and updates on the legislative framework for open banking
Review and understand the implications of the centralised 'access fee' pricing model for cVRPs on your business operations
Ensure compliance with existing competition laws and regulations
Key Dates
31 Dec 2026Expected implementation of the government's legislative framework for open bankingDEADLINE
1 Jul 2027End of the temporary measure if the legislative framework is not implementedDEADLINE
Non-Compliance Risk
Enforcement action, fines, or other regulatory penalties for non-compliance with competition laws and regulations
PS3/26 is the PRA's final policy statement restating the remaining provisions of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook and related policy materials, effective 1 January 2027. This represents a critical step in the UK's transition away from assimilated EU law, consolidating fragmented regulatory requirements into a unified domestic framework while introducing targeted amendments to securitisation rules and External Credit Assessment Institution (ECAI) mapping.
What Changed
*Restatement of CRR Provisions**
The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation amendments. This follows the earlier PS12/25, which finalised the first tranche of restatement requirements in 2026.
*Policy Materials and Supervisory Guidance
PS3/26 introduces or amends multiple supervisory statements and statements of policy:
New: SS4/24 (Credit risk: Internal Ratings Based A
What You Need To Do
*Immediate (by Q2 2026)
*Review applicability
*Assess impact
*Identify policy changes
*Medium-term (by Q3 2026)
Key Dates
20 January 2026- PS3/26 final policy statement published
28 October 2025- PS19/25 (near-final policy) published
1 January 2027- All policies take effect; HM Treasury commencement regulations revoke relevant CRR provisions and replace them with PRA Rulebook rules and policy materials
The Prudential Regulation Authority (PRA) has published a policy statement (PS3/26) that restates the remaining relevant provisions in the Capital Requirements Regulation (CRR) within the PRA Rulebook and other policy materials. This change aims to ensure that the PRA's rules and policies are consistent with the UK's withdrawal from the EU. The policy statement is relevant to PRA-authorised banks, building societies, and other financial institutions.
What Changed
The PRA has restated the remaining relevant provisions in the CRR within the PRA Rulebook and other policy materials, including amendments to supervisory statements and the introduction of new statements of policy. The changes include updates to the securitisation requirements and the introduction of new rules on credit risk and internal ratings-based approaches.
What You Need To Do
Review and update internal policies and procedures to ensure compliance with the restated CRR provisions
Ensure that risk management practices are aligned with the updated rules on credit risk and internal ratings-based approaches
Review and update securitisation policies and procedures to ensure compliance with the amended requirements
Key Dates
1 Jan 2027The restated CRR provisions take effectDEADLINE
Non-Compliance Risk
Failure to comply with the restated CRR provisions may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Capital Requirements Regulation (CRR)Basel 3.1Solvency II
PS4/26 finalizes the **simplified capital regime for Small Domestic Deposit Takers (SDDTs)**, a tailored prudential framework designed to reduce regulatory burden while maintaining capital resilience for smaller, domestically-focused UK banks and building societies. This represents the completion of Phase 1 of the PRA's "Strong and Simple" initiative and introduces materially lighter capital, liquidity, and reporting requirements for qualifying firms, with implementation effective January 1, 2027.
What Changed
*Simplified Capital Framework
The final policy introduces a dedicated capital regime** for SDDTs that descopes them from standard CRR Firms requirements. SDDTs are now subject to tailored Pillar 2 methodologies (SoP5/25) and simplified ICAAP/SREP processes (SS4/25) rather than the standard frameworks.
*Liquidity Simplifications
Qualifying SDDTs with 50% or more retail deposit funding** are exempted from the Net Stable Funding Ratio (NSFR) requirements, replacing this with a simpler Retail Depos
What You Need To Do
*Immediate (by January 20, 2026)
*Assess SDDT eligibility – Determine whether your firm meets all seven qualification criteria, particularly the £20bn asset threshold and domestic asset location requirement
*Review consolidation group structure – If part of a group, confirm which entity will serve as the SDDT consolidation entity responsible for certification
*Implement SoP2/23 changes – Adopt updated operating procedures for the SDDT regime
*Update ICAAP/ILAAP processes – Implement new frequency requirements for capital and liquidity adequacy assessments
Key Dates
January 20, 2026– PS4/26 published; changes to SoP2/23 and ICAAP/ILAAP frequency requirements take effect
January 20, 2026– Revocation of ICR firm/consolidation entity definitions and deletion of SoP3/23 effective
January 1, 2027– Simplified capital regime for SDDTs takes effect; SS4/25 brought into effect in full; SDDTs removed from SS31/15 scope
The Prudential Regulation Authority (PRA) has introduced a simplified capital regime for Small Domestic Deposit Takers (SDDTs) to reduce regulatory complexity while maintaining adequate capital. The new regime will take effect on 2027-01-01. This change aims to simplify capital requirements for smaller banks and building societies.
What Changed
The PRA has introduced a new simplified capital regime for SDDTs, which includes changes to the PRA Rulebook, supervisory statements, and statements of policy. The regime also introduces new reporting templates and instructions.
What You Need To Do
Review and update capital adequacy assessments to ensure compliance with the new simplified capital regime
Implement new reporting templates and instructions for SDDTs
Update internal policies and procedures to reflect changes to the PRA Rulebook, supervisory statements, and statements of policy
Key Dates
20 Jan 2026Publication of the final policy statement
20 Jan 2026Early implementation of changes to ICAAP updates and reverse stress-testing
1 Jan 2027The SDDT capital regime takes effectDEADLINE
Non-Compliance Risk
Enforcement action, fines, or license revocation for non-compliance with the new simplified capital regime
We have opened applications for the second cohort of our AI Live Testing service. AI Live Testing is the first of its kind in the financial sector to help firms who are ready to use AI in UK financial markets. Participating firms receive tailored support from our regulatory team and our technical partner Advai to develop, assess and deploy safe and responsible AI.The service helps firms to consider key questions around evaluating AI including governance, risk management and monitoring to help...
The CFTC announced three major enforcement actions on January 16, 2026, resolving cases involving **market manipulation (spoofing), misappropriation of confidential information, and unregistered commodity pool operations**. These cases demonstrate the CFTC's continued enforcement focus on fraudulent trading practices and registration violations, with combined penalties exceeding $685,000 and criminal sentences totaling over six years in prison.
What Changed
The enforcement actions establish precedent in three critical areas:
*Market Manipulation (Spoofing): The CFTC secured consent orders against precious metals futures traders for spoofing—placing and canceling orders to create false market impressions. The orders impose three-year and six-month trading bans** and require cease-and-desist compliance with the Commodity Exchange Act's spoofing prohibition.
*Misappropriation and Fictitious Trading: The CFTC obtained permanent injunctive relief requ
What You Need To Do
*For Registered Futures Firms and Banks
trade and post-trade compliance controls
*For Commodity Pool Operators and Investment Advisors:
by-jurisdiction licensing analyses before soliciting investors
*For All Market Participants
Key Dates
September 2019- CFTC enforcement action filed against Smith and Nowak
December 2021- CFTC complaint filed against Miller and Omerta Capital; DOJ criminal charges filed
December 2022- CFTC complaint amended against Miller and Omerta Capital
August 2023- Smith and Nowak sentenced to prison (criminal case)
June 2024- Miller sentenced to prison (criminal case)
The CFTC has announced enforcement updates, including civil monetary penalties and trading bans for spoofing in precious metals futures markets and misappropriating confidential information. These updates highlight the importance of compliance with CFTC regulations. Firms must ensure they are registered and comply with anti-spoofing and anti-fraud regulations.
What Changed
The CFTC has obtained federal court orders imposing civil monetary penalties and trading bans on individuals and firms for spoofing and misappropriating confidential information. The CFTC has also charged an unregistered commodity pool operator with fraud and registration violations.
What You Need To Do
Verify registration with the CFTC at NFA BASIC before committing funds
Review and update anti-spoofing and anti-fraud policies and procedures
Ensure compliance with CFTC regulations regarding commodity pool operations and futures market participation
Key Dates
1 Sept 2021CFTC enforcement action filed against Gregg Smith and Michael Nowak
10 Dec 2021Department of Justice charged Peter Miller with conspiracy to commit commodities fraud
1 Jun 2024Peter Miller sentenced to five months in prison and five months of home confinement
10 Dec 2024Department of Justice charged Travis Ford with conspiracy to commit wire fraud
Non-Compliance Risk
Enforcement action, fines, trading bans, and registration revocation
The German Financial Supervisory Authority (BaFin) warns about offers from the website two-five-management(.)com. According to information available to BaFin, the unknown operators of the website are offering banking services, in particular fixed-term deposits, and financial services without the required authorisation. They give the impression that their offers originate from TwoFive Management GmbH, which is registered with BaFin as an AIF asset management company, Section 2 (4) of the Germa...
The Federal Financial Supervisory Authority BaFin warns against offers on the website whiterock-financial(.)eu and against the alleged operator White Rock Financial Consultancy Limited from London, United Kingdom. According to information available to BaFin, the operator is providing financial and investment services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address bancosantander.es-kundenservice[at]outlook.com. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from Banco Santander S.A. This is a case of identity theft.
The Federal Financial Supervisory Authority (BaFin) warns consumers about “Paragonix Edge” and the services it is offering. BaFin suspects the unknown operators of the websites paragonixedge(.)org, hhessel(.)com, funkmp(.)com und altenweerth(.)com of offering consumers cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers on the website coinbullvisionltd(.)com. According to information available to BaFin, the trading platform COIN Bull Vision Ltd. (also: COIN Bull Vision GmbH) is providing financial, investment and crypto asset services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers on website fragfinanz(.)com. According to information available to BaFin, banking transactions, especially fixed-term deposits, financial or investment services are being provided by FragFinanz without the required authorisation.
Alleged employees of Brookfield Asset Management GmbH are contacting investors unsolicited by telephone and email without the necessary permission to offer them alleged fixed-term deposits and alleged pre-IPO shares. In the past, they have also used the website deu-brookfield(.)com, which is no longer accessible. They give the impression that they are cooperating with licensed banks and issuers of pre-IPO shares. This is not the case.
The Federal Financial Supervisory Authority BaFin warns against offers on the websites ubpmanagement(.)co, commerzglobal(.)com, longsharks(.)com and paribasgroup(.)net. According to information available to BaFin, the companies UBP Management and Commerz Global, allegedly based in Frankfurt, and Longsharks Capital and Paribas Group, allegedly based in London, are offering financial or investment services and crypto asset services without the required authorisation. The offers do not originate...
Central Bank of Ireland and Banca d’Italia are launching the Innovation Data Challenge 2026, a joint initiative designed to foster cutting-edge research and innovation in the retail payments sector. The Challenge reflects the shared commitment of the two Institutions to promoting applied research, international collaboration, and the responsible use of data and technology to shape the future of payments. The initiative brings together leading Irish and Italian universities, including Universi...
The CSSF's January 2026 enforcement report documents the results of its 2025 examination campaign on 2024 financial and non-financial disclosures by issuers under Luxembourg's Transparency Law. This publication is critical for compliance professionals because it reveals systematic compliance gaps across financial reporting (IFRS), sustainability reporting (ESRS), and Alternative Performance Measures (APMs), with 27% of enforcement decisions resulting in injunctions for non-compliance.
What Changed
The regulatory landscape has evolved significantly with the introduction of new sustainability reporting requirements:
ESRS Implementation (First Year): 2024 marked the first full reporting year under the European Sustainability Reporting Standards (ESRS), with the CSSF conducting a fact-finding exercise to assess reporting quality. The CSSF noted an overall increase in reporting quality with better-structured reports and more relevant disclosures, though key improvement areas remain in compreh
What You Need To Do
*Financial Information (IFRS)
*Enhanced Note Disclosures
*Cash Flow Statement Presentation
*Segment Reporting Completeness
*Going Concern Assessment
Key Dates
4 July 2025- European Commission adopted Delegated Act amending Taxonomy Disclosures (Omnibus package)
18 August 2025- CSSF published full results of fact-finding exercise on ESRS reporting
5 December 2024- CSSF published enforcement priorities press release for FY2024 reporting
January 2026- CSSF published enforcement results report (current publication)
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website parex-am(.)com. BaFin has information that this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
The Securities and Exchange Commission today announced that J. Russell “Rusty” McGranahan has been named SEC General Counsel. As the SEC’s chief legal officer, Mr. McGranahan will oversee the provision of legal expertise and advice to the Office of the…
The Federal Financial Supervisory Authority (BaFin) warns consumers about the company Own Mood Space and the services it is offering. BaFin suspects the unknown operators of the website ownmoodspace(.)com of offering consumers financial, investment and cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers on the website fidelity-ag(.)com. According to information available to BaFin, banking transactions, especially fixed-term deposits, financial or investment services are being provided on this website without the required authorisation. The fixed-term deposit offers are sent, among others, from the email address festgeld[at]fidelity-ag(.)com. The offers do not originate from the Swiss company Fidelity Treuhand und Verwaltu...
On 07 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50.000 euros on pferdewetten.de AG.
AI Analysis
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on pferdewetten.de AG on November 7, 2025, for violations related to the publication of financial reports under German securities law (WpHG - Wertpapierhandelsgesetz). This enforcement action underscores regulatory expectations for timely and accurate financial disclosure compliance, particularly for publicly traded or regulated entities in the gaming/betting sector.
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What Changed
Based on the enforcement context, the regulatory requirements at issue involve:
Financial Reporting Obligations: Entities subject to WpHG must publish financial reports in accordance with statutory deadlines and content requirements
Disclosure Standards: Reports must meet quality and completeness standards established under German securities law
Enforcement Mechanism: The BfJ has authority to impose disciplinary fines for non-compliance with publication requirements
No Safe Harbor: Delayed or d
What You Need To Do
*Audit Current Compliance
*Strengthen Internal Controls
*Document Procedures
*Monitor Deadlines
*Legal Review
Key Dates
November 7, 2025- BfJ imposed €50,000 disciplinary fine on pferdewetten.de AG
January 15, 2026- BaFin published enforcement action notice
Ongoing- WpHG financial reporting obligations remain in effect with no stated grace period modifications
The Federal Financial Supervisory Authority (BaFin) suspects the unknown operators of the website fivepillarstoken(.)com of offering consumers cryptoasset services in Germany without the required authorisation. The offers include “crypto debit cards” and staking using Five Pillars Tokens.
Circular CSSF 19/708 mandates the electronic transmission of specified documents to the CSSF via secure platforms like e-file or SOFiE, effective from February 1, 2019, replacing prior paper or other methods. This updated annex (as amended by Circular CSSF 21/790 and further revisions up to April 1, 2025) standardizes submissions for investment funds and related entities, reducing administrative burdens while ensuring document integrity and CSSF accessibility. Compliance professionals must monitor the dynamic annex list on the CSSF website to avoid nullified submissions.
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What Changed
Mandatory Electronic-Only Submission: Documents listed in Annex I must be transmitted exclusively via e-file (http://www.e-file.lu) or SOFiE (http://www.cetrel-securities.lu/wp_static/what-do-we-offer/secured-reporting-channel-sofie-sort/), in PDF format supporting read access, printing, copy/paste, and word search; other methods post-February 1, 2019, are null and void.
Dynamic Annex Updates: The annex, published on the CSSF website, is regularly updated (e.g., latest noted April 1, 2025) and i
What You Need To Do
Register/access e-file or SOFiE platforms if not already (test/production environments available since February 2019)
Consult and adhere to the latest Annex I for document list, nomenclatures, and formats (PDF with full functionality)
Ensure submissions are final/official versions matching hard copies; use specified identifiers for UCIs/SIFs/SICARs
Implement processes for automatic/manual transmission (e
Train staff on responsibilities and integrate into reporting workflows; reference CSSF FAQs for closing documents
Key Dates
1 February 2019 - Entry into forceMandatory electronic transmission for listed documents; non-electronic submissions null and void.
28 January 2019 - Publication dateof original Circular CSSF 19/708.
22 December 2021 - Amendmentby Circular CSSF 21/790.
1 April 2025 - Latest annex updatenoted.
Ongoing - Regular checks requiredEntities must monitor CSSF website for annex updates.DEADLINE
Compliance Impact
Urgency: Low (for new implementations post-2019; medium for ongoing monitoring). This matters for operational efficiency and CSSF relations, as non-compliance risks rejected filings, delays (e.g., approvals under SFDR processes), or supervisory scrutiny, but long-standing rule (since 2019) with esta
According to information available to the Federal Financial Supervisory Authority (BaFin), unknown persons are using Telegram groups and chats to contact German investors. The initiators of these messenger groups purport to be the US company “MacKay Shields”. This is a case of identity fraud.
According to information available to the Federal Financial Supervisory Authority (BaFin), unknown persons are using WhatsApp groups and chats to contact German investors. The initiators of these WhatsApp groups purport to be the US company “Payden & Rygel”. This is a case of identity theft misusing the names of real employees.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website givhalbank(.)com. According to information available to BaFin, this website is being used to offer banking business and financial, investment and cryptoasset services without the required authorisation.
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website blitz365finance(.)org. According to information available to BaFin, the operators are offering financial and cryptoasset services on the website without the required authorisation. The unknown operators of the website are not supervised by BaFin. This is a case of identity fraud against a Swiss company.
The Financial Conduct Authority, Bank of England and Prudential Regulation Authority (UK regulators) have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 1 der Verordnung vom 28. März 2018 über Massnahmen gegenüber Venezuela (SR 946.231.178.5) publiziert.
AI Analysis
On January 13, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 1 of the Ordinance on Measures against Venezuela (SR 946.231.178.5), reflecting changes to the list of designated persons and entities subject to Swiss asset freezing measures. This update is critical for Swiss financial institutions and regulated entities as it directly impacts sanctions compliance obligations and requires immediate verification of client and counterparty lists against the revised designations.
What Changed
The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela. While the search results reference a separate FINMA ordinance (RS 196.127.85) adopted on January 5, 2026, which froze assets of 37 persons in the context of Venezuela, the January 13 update to SR 946.231.178.5 represents an amendment to Switzerland's broader sanctions ordinance framework. The specific changes to Annex 1 require Swiss entities to:
Update their sanctions
What You Need To Do
*Immediate Screening
*Asset Identification
*Freeze Implementation
*Notification
*Transaction Review
Key Dates
January 5, 2026- FINMA ordinance on asset freezing (RS 196.127.85) enters into force at 11 a.m., freezing assets of 37 designated persons
January 13, 2026- SECO publishes updated Annex 1 to SR 946.231.178.5 (the update referenced in your query)
Immediate- Compliance obligations commence upon publication; no grace period for implementationDEADLINE
The PRA and FCA have jointly issued consultation paper CP1/26 proposing to set the **Management Expenses Levy Limit (MELL) for the Financial Services Compensation Scheme (FSCS) at £113 million for 2026/27**, comprising a £108 million management expenses budget and a £5 million unlevied reserve. This consultation determines the maximum amount the FSCS can levy on authorised financial services firms to fund its statutory compensation scheme operations, directly affecting compliance costs for all regulated entities.
What Changed
The proposed MELL for 2026/27 introduces the following material changes:
Budget increase of £4.4 million from 2025/26 (from approximately £103.6 million to £108 million), broadly aligned with inflation
Nominal reduction of £6.6 million on a like-for-like basis when excluding the cost of enhancements to the FSCS's revolving credit facility (RCF)
Real terms reduction of £11 million when accounting for inflation adjustments
RCF enhancement to £3 billion to support the Bank of England's recapitalis
What You Need To Do
*Review the consultation paper (CP1/26) in detail, particularly Appendices 3 and 4 detailing budget line items and PRA/FCA funding class allocations
*Assess levy impact on your firm's 2026/27 budget based on your regulated business volume and funding class allocation
*Prepare internal stakeholder communication regarding the £4
*Monitor the FSCS January 2026 budget update for detailed cost breakdowns and compensation levy forecasts
*Submit consultation responses if your firm wishes to comment on the proposal by 10 February 2026
Key Dates
10 February 2026– Consultation deadline for comments on CP1/26DEADLINE
1 April 2026– Effective date: proposed MELL applies from start of FSCS financial year
This CSSF publication, dated January 12, 2026, identifies the specific population (likely a firm or individual) subject to an enforcement action, such as an administrative sanction, as part of the CSSF's transparency in supervisory measures. It matters because it signals CSSF's active enforcement priorities, potentially in areas like AML or reporting failures, enabling firms to assess similar risks in their operations and strengthen compliance to avoid parallel actions. Published amid rising focus on financial crime typologies like sexual extortion, it underscores the regulator's commitment to public accountability.
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What Changed
No new regulatory changes or requirements are introduced in this publication, as it is an enforcement notice rather than a circular or guideline. It serves as a disclosure of an ongoing or concluded enforcement case, aligning with CSSF's practice of publishing sanction details to deter non-compliance and inform the market, without altering existing rules.
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What You Need To Do
For the named population
For all supervised firms
Update internal policies, train staff on enforcement precedents, and ensure robust reporting under Circular CSSF 19/726 or Transparency Law obligations
Compliance Impact
Urgency: High – Immediate relevance for the named party facing direct consequences; medium-to-high for peers due to CSSF's pattern of public enforcements signaling heightened scrutiny on financial crime, especially amid rising OCSE/FSEC cases noted in recent CSSF guidance. It matters as it could pre
We reviewed how firms sell complex exchange traded products (ETPs) to retail consumers. Complex ETPs are a subset of the wider ETP market and include high-risk investment strategies that can be difficult for retail consumers to understand.We assessed how firms of different sizes and business models evaluate these products, communicate key risks and monitor outcomes under the Consumer Duty.Given the complexity and risk profile of ETPs, it is essential firms make sure investors have the knowled...
The Securities and Exchange Commission today announced it will hold its third and final outreach event to help firms comply with amendments to Regulation S-P. The event, which is focused on small firms, is open to in-person or virtual attendance, and is…
Administrative sanction imposed on the alternative investment fund manager Premium Capital Management (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on 11 September 2025 against alternative investment fund manager (AIFM) Premium Capital Management for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation amid ongoing AML risks in Luxembourg. Compliance teams should view this as a reminder of the low tolerance for even administrative lapses, with potential for escalated fines in repeat cases.
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What Changed
This is not a regulatory change but an enforcement precedent under existing rules: non-compliance with Article 5(1) of the AML/CFT Law, which mandates annual submission of a financial crime questionnaire ("Questionnaire") to the CSSF. The fine was calculated per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), considering circumstances under Article 8-5(1). Publication followed Article 8-6(1) after a proportionality assessment, confirming no market stability risks. No new requirements were introduced;
What You Need To Do
Immediately review internal processes for annual Questionnaire submission, ensuring calendar invites and automated reminders for the 4 April deadline (covering prior year-end data)
Conduct a gap analysis on AML/CFT cooperation obligations under Article 5(1), including response protocols to CSSF reminders or queries
Update compliance calendars and train staff on escalation procedures; document all submissions with proof (e
If late, proactively submit overdue items and request meetings if needed, as non-response forfeits mitigation opportunities
Key Dates
31 December 2024- Reference year-end for the financial crime Questionnaire.
4 April 2025- Statutory deadline for Questionnaire submission to CSSF.DEADLINE
11 September 2025- Date CSSF imposed the €10,000 administrative fine after non-submission despite reminders.
9 January 2026- Publication date of the sanction decision.
Compliance Impact
Urgency: Medium – This €10,000 fine for a straightforward reporting failure demonstrates CSSF's willingness to penalize non-cooperation swiftly, even without aggravating factors, but the amount is modest and targeted at administrative breaches. It matters as a warning shot in Luxembourg's AML landsc
Administrative sanction imposed on the alternative investment fund manager Sunbricks GP S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a **€10,000 administrative fine on Sunbricks GP S.à r.l.**, an alternative investment fund manager, for failing to submit a mandatory annual financial crime questionnaire by the April 4, 2025 deadline, despite two formal reminders. This enforcement action demonstrates the CSSF's strict approach to cooperation obligations under Luxembourg's anti-money laundering and counter-terrorist financing (AML/CFT) framework and signals that non-submission of required compliance documentation—even without evidence of underlying financial crime—triggers regulatory penalties.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All professionals supervised, authorized, or registered by the CSSF must submit an annual questionnaire on financial crime by April 4 each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, which includes timely su
What You Need To Do
regulated entities must
*Establish Calendar Controls
*Designate Responsible Parties
*Prepare Documentation
*Monitor Communications
Key Dates
April 4, 2025– Annual financial crime questionnaire submission deadline (for year ending December 31, 2024)DEADLINE
Before September 11, 2025– Two reminder notices issued by CSSF to Sunbricks GP
September 11, 2025– Administrative fine decision date; questionnaire still not submitted
January 9, 2026– Publication date of enforcement decision
Administrative sanction imposed on the alternative investment fund manager Capitalis Premiere Group (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Capitalis Premiere Group on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation for Luxembourg-regulated entities. Compliance teams should note this as a low-value but public reminder of potential fines for administrative lapses in AML processes.
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What Changed
This is not a regulatory change or new requirement but an enforcement precedent under existing rules: non-compliance with the annual financial crime questionnaire submission, mandated by Article 5(1) of the AML/CFT Law, triggers fines per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a). The CSSF considered all relevant circumstances under Article 8-5(1) to set the €10,000 fine amount and published the sanction nominatively after proportionality assessment per Article 8-6(1), confirming no market stabi
What You Need To Do
Ensure timely submission of annual financial crime questionnaires by 4 April each year (for prior calendar year data); implement calendar reminders and escalation processes for CSSF requests
Respond promptly to CSSF reminders or queries on AML/CFT compliance to avoid escalation to fines; document any delays with justification evidence
No retroactive actions needed for this case, but conduct gap analysis on reporting workflows to prevent similar breaches
Key Dates
4 April 2025- Deadline for submitting the annual financial crime questionnaire covering the year ending 31 December 2024.DEADLINE
11 September 2025- Date CSSF imposed the €10,000 administrative fine on Capitalis Premiere Group for non-submission.
9 January 2026- Date of CSSF publication of the sanction decision.
Compliance Impact
Urgency: Medium - This €10,000 fine is modest but publicly names the firm, amplifying reputational risk in Luxembourg's competitive fund domicile; it matters as a clear CSSF signal of zero tolerance for basic cooperation failures in AML, potentially foreshadowing stricter enforcement amid EU AML har
Administrative sanction imposed on the alternative investment fund manager Lion Management (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on Lion Management, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the 4 April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing framework, with direct implications for all AIFMs regarding timely compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations. However, it reinforces critical compliance requirements:
Mandatory Annual Questionnaire Submission: All CSSF-supervised professionals, including AIFMs, must submit an annual questionnaire on financial crime by the specified deadline (in this case, 4 April 2025 for the year ending 31 December 2024).
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on the fight against mon
What You Need To Do
*Establish Calendar Controls
*Designate Responsible Parties
*Monitor CSSF Communications
*Document Submission
*Escalate Non-Compliance Immediately
Key Dates
4 April 2025- Deadline for submission of annual financial crime questionnaire for year ending 31 December 2024DEADLINE
11 September 2025- Date CSSF imposed administrative fine after two reminders went unheeded
9 January 2026- Publication date of the administrative sanction decision
Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on Max Gain Capital S.à r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.
What Changed
This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
Enforcement Escalation: The CSSF will issue reminders before imposin
What You Need To Do
regulated entities must
*Identify Reporting Obligations
*Calendar Management
*Documentation
*Escalation Protocol
Key Dates
4 April 2025- Deadline for submission of financial crime questionnaire for the year ending 31 December 2024DEADLINE
Before 11 September 2025- CSSF issued two reminders to Max Gain Capital after the missed deadlineDEADLINE
11 September 2025- CSSF imposed the €10,000 administrative fine
9 January 2026- CSSF published the administrative sanction decision
Administrative sanction imposed on the alternative investment fund manager Agriland Management S.A. (“AIFM”)
AI Analysis
The Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial regulator, imposed a **EUR 10,000 administrative fine on Agriland Management S.A.**, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing (AML/CFT) framework and signals heightened scrutiny of compliance with supervisory reporting requirements.
What Changed
This is not a regulatory change but rather an enforcement action that clarifies existing obligations:
Mandatory Annual Reporting: All CSSF-supervised professionals must submit an annual questionnaire on financial crime by 4 April each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, including timely submission of requested documentation.
Enforcement Esc
What You Need To Do
*Establish Reporting Calendars
*Designate Responsible Personnel
*Respond to Regulatory Requests
*Document Justifications
*Monitor Supervisory Communications
Key Dates
4 April 2025– Deadline for submission of financial crime questionnaire for year ending 31 December 2024DEADLINE
Before 11 September 2025– Two reminder notices issued by CSSF to Agriland Management S.A.
Administrative sanction imposed on the alternative investment fund manager Bedrock I GP S.à r.l. (“AIFM”)
AI Analysis
The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Bedrock I GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on timely supervisory compliance. It matters because it demonstrates that even modest fines are pursued for basic reporting lapses, potentially signaling heightened scrutiny on AIFMs' AML processes amid ongoing regulatory focus on financial crime risks.
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What Changed
This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing (AML/CFT Law). Specifically, it reaffirms the mandatory annual submission of the CSSF's financial crime questionnaire ("Questionnaire") by supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, as part of the cooperation duty in Article 5(1). The fine was cal
What You Need To Do
Immediately verify submission status of the 2024 Questionnaire (or any outstanding); if overdue, submit promptly with justification to mitigate further escalation
Implement automated calendar alerts and internal workflows for all CSSF reporting deadlines, including annual AML/CFT Questionnaire
Conduct a compliance gap analysis on cooperation obligations under Article 5(1) AML/CFT Law, documenting reminder responses and evidence retention
Train senior managers and compliance teams on supervisory interactions, including rights to request in-person meetings before fines
Review governance for timely escalation of CSSF reminders to decision-makers
Key Dates
31 December 2024- Reference period end for the Questionnaire covering financial crime compliance.DEADLINE
4 April 2025- Statutory deadline for Questionnaire submission to CSSF.DEADLINE
11 September 2025- Date of administrative fine imposition (€10,000) after non-submission despite reminders.
9 January 2026- Publication date of the sanction decision by CSSF.
Compliance Impact
Urgency: Medium - This is a post-facto enforcement on a past breach (2024 reporting cycle), with the €10,000 fine relatively low, indicating proportionality for a first-time or isolated lapse. It matters as a leading indicator of CSSF's 2025-2026 focus on AML cooperation, with multiple similar AIFM
Administrative sanction imposed on JTC (Luxembourg) S.A.
AI Analysis
The CSSF imposed a €102,000 administrative fine on JTC (Luxembourg) S.A. on 23 July 2025 for breaches in its professional obligations as a depositary of non-financial assets under the AIFM Law, identified during an on-site inspection from February 2023 to January 2024 covering activities up to December 2022. This enforcement action highlights CSSF's scrutiny of depositary functions, particularly risk assessment and oversight controls, serving as a warning for similar entities to strengthen compliance amid rising supervisory focus on AIFM depositaries.
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What Changed
This is an enforcement action, not a regulatory change; it enforces existing requirements under Article 51(1) (1st and 7th indents) and Article 51(2) (1st sub-paragraph, 3rd indent) of the amended Law of 12 July 2013 on AIFMs (AIFM Law), and related provisions like Article 92(1) of Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013). Key breaches include: failure to properly assess risks tied to AIFs' strategies and AIFMs' organization for oversight processes; lack of processes to ve
What You Need To Do
related entities) must
Conduct immediate gap analyses on risk assessment processes for AIF strategies and AIFM organization per Article 92(1) CDR 231/2013
Implement robust verification processes for AIFM compliance with asset delegation rules
Ensure availability of key documentation and evidence of controls for the depositary function, addressing pre-2022 gaps if applicable
Develop and test oversight processes, leveraging self-identified improvements and action plans as mitigating factors, as JTC did prior to inspection
Key Dates
February 2023 - January 2024Period of CSSF on-site inspection on depositary obligations, covering activities up to December 2022.
23 July 2025Date CSSF imposed the €102,000 administrative fine on JTC (Luxembourg) S.A.
9 January 2026Date of official CSSF publication announcing the sanction.
Compliance Impact
Urgency: High – This matters due to the fine's size (€102,000), reflecting breach accumulation, severity, and duration, despite JTC's partial remediation; it signals intensified CSSF on-site scrutiny of depositary functions post-2023 inspections, with potential for higher penalties absent proactive
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address wise[at]wisefestgeldkonto(.)com. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from Wise Europe SA. This is a case of identity theft.
The Federal Financial Supervisory Authority BaFin warns against offers on the website ellis-ag(.)net. According to information available to BaFin, financial or investment services and crypto asset services are being offered on this platform without the required authorisation. According to the current state of knowledge, there is no connection to the Swiss company Ellis AG, Zurich. This is likely to be a case of identity fraud.
The Securities and Exchange Commission’s Office of the Advocate for Small Business Capital Formation today published and delivered to Congress its 2025 staff report that serves as a comprehensive and data-rich resource on capital-raising dynamics…
The Securities and Exchange Commission today proposed amendments to the rules that define which registered investment companies, investment advisers, and business development companies qualify as small entities for purposes of the Regulatory Flexibility…
AI Analysis
The SEC proposed amendments on January 7, 2026, to expand the definitions of "small entities" under the Regulatory Flexibility Act (RFA) for registered investment advisers (RIAs), investment companies, and business development companies by significantly raising asset thresholds last updated in 1998. This would increase the number of qualifying small entities, enabling the SEC to better assess regulatory impacts and potentially provide tailored relief like extended compliance timelines during rulemaking. It matters because it could indirectly reduce compliance burdens for mid-sized firms by influencing future SEC rules to minimize disproportionate effects on smaller players.
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What Changed
Raise the RAUM threshold for RIAs to qualify as small entities from $25 million to $1 billion, with conforming changes for control affiliates.
Increase the net asset threshold for investment companies from $50 million to $10 billion.
Update aggregation of related funds from "group of related investment companies" to "family of investment companies" as defined in Form N-CEN for easier identification.
Introduce inflation adjustments to thresholds every 10 years via SEC order, without formal rulema
What You Need To Do
Submit public comments by the deadline to influence thresholds, alternatives (e
Monitor Federal Register for exact publication and comment instructions; review proposed rule and fact sheet on SEC site (https://www
Assess internal status
No immediate compliance changes, as this affects SEC rulemaking process only; prepare for potential indirect impacts via future rules
Key Dates
January 7, 2026- SEC issues proposal and press release.
60 days after Federal Register publication- Public comment period closes (publication expected shortly after January 7; exact date TBD, likely March 2026 based on estimates).
No stated adoption date- Typically at least one year post-comment period under normal processes.
Every 10 years post-adoption- Inflation adjustments to thresholds via SEC order.
Compliance Impact
Urgency: Medium. This proposal does not impose direct new requirements or alter existing obligations—it's procedural for SEC's RFA analyses during rulemaking. However, adoption could lead to meaningful indirect benefits for mid-sized RIAs and funds, such as longer compliance phases or reduced burden
In the WhatsApp groups, investors are recommended to invest in financial instruments that can then be traded via the platform h5.bluealphasystem(.)net or the aforementioned app.
The Federal Financial Supervisory Authority BaFin warns against offers in WhatsApp groups, which are allegedly operated by Cantor Fitzgerald and led by Leopold Schneider. BaFin is not aware of the existence of this person. According to information available to BaFin, recommendations for the purchase of financial instruments and cryptocurrencies, which can allegedly be traded via CDAfin app, are offered in various WhatsApp groups. According to the current state of knowledge, there is no connec...
The German Financial Supervisory Authority (BaFin) warns about offers on the website capitalholdings(.)icu. According to information available to BaFin, the unknown operators of the websites are offering banking transactions and financial services without the required authorisation.
The German Financial Supervisory Authority (BaFin) warns about fixed-term deposit offers from the website sicherangelegt(.)de. According to information available to BaFin, the unknown operators of the website are offering banking services, in particular fixed-term deposits, without the required authorisation.
The Federal Financial Supervisory Authority BaFin warns against offers in WhatsApp groups, which are allegedly operated by Baird Capital and led by a Thomas Becker. BaFin is not aware of the existence of this person. According to information available to BaFin, recommendations for the purchase of financial instruments and cryptocurrencies are offered in WhatsApp groups and the so-called Baird Capital Investment Program III is being promoted. According to the current state of knowledge, there ...
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website blauline(.)ai. BaFin has information that this website is being used to offer financial, investment and cryptoasset services without the required authorisation.
Warning Forex and binary options Warning Savings protection The AMF and the ACPR warn the public against several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
ESMA publishes report on cross-border marking of funds including statistics on notifications 06 January 2026 The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published its third report on marketing requirements and marketing communications under the Regulation on cross-border distribution of funds . For the first time, the report includes statistics on notifications of cross-border marketing of funds. Drawing on input from Na...
The Securities and Futures Commission (SFC) reprimanded and fined Saxo Capital Markets HK Limited (SCMHK) HK$4 million on 6 January 2026 for breaching regulations by distributing unauthorised virtual asset (VA) funds and VA-related products to retail clients via its online platform from 1 November 2018 to 25 November 2022. This enforcement action underscores the SFC's strict enforcement of suitability, due diligence, and professional investor-only restrictions for complex VA products, serving as a warning to intermediaries about online distribution risks. It matters because it highlights gaps in group-wide protocols and the need for robust VA-specific controls, especially post-SFC circulars mandating PI-only access.
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What Changed
This is an enforcement action, not a new rule change, but it reinforces existing SFC circulars requiring VA products (including unauthorised funds and exchange-traded VA derivatives) to be offered exclusively to professional investors (PIs). Key requirements reiterated include: conducting VA-specific product due diligence; assessing client knowledge of VA investments; providing sufficient VA-specific information and warnings; and implementing platform controls to restrict retail access to comple
What You Need To Do
Conduct immediate VA product due diligence using SFC-specific procedures, not just group-wide protocols, to identify unauthorised VA funds and derivatives
Implement client knowledge assessments for VA investments before transactions, especially for retail clients
Provide VA-specific warnings and information on platforms and ensure retail access is blocked for PI-only products
Review and enhance online platform controls for suitability checks on complex products; audit historical VA trades for compliance gaps
Update internal policies to align with SFC circulars on VA distribution, including staff training on breaches like those at SCMHK
Key Dates
1 November 2018 - 25 November 2022Period of breaches where SCMHK distributed VA products to retail clients in violation of applicable SFC circulars.
6 January 2026Date of SFC announcement, reprimand, and HK$4 million fine imposition on SCMHK.
Compliance Impact
Urgency: High – This action signals intensified SFC scrutiny on VA online distribution post-2018 circulars, with fines for suitability failures even years later; firms risk similar penalties (HK$4m here) if platforms lack VA controls, especially amid Hong Kong's growing VA regime. It matters for ope
The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website bit500(.)eu. BaFin has information that the operators are offering banking business and/or financial services on this website without the required authorisation. The operators are not supervised by BaFin.
ESAs’ Joint Board of Appeal rules on reimbursement of costs in an appeal brought by NOVIS Insurance Company against the European Insurance and Occupational Pensions Authority (EIOPA) 05 January 2026 Board of Appeal Joint Committee The Joint Board of Appeal (“The Board”) of the European Supervisory Authorities (ESAs) – the EBA, ESMA, EIOPA – has issued its decision on costs arising in the appeal brought by NOVIS Insurance Company, NOVIS Versicherungsgesellschaft, NOVIS Compagnia di Assicurazio...
The Swiss Federal Council adopted a new ordinance (RS 196.127.85) on 5 January 2026, mandating the immediate freezing of all assets in Switzerland belonging to Nicolás Maduro and 36 associated persons, under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA). This precautionary measure prevents asset outflows amid Venezuela's political upheaval, complementing existing sanctions since 2018, and enables future mutual legal assistance for potential restitution to the Venezuelan people. It matters for Swiss financial institutions as it imposes immediate reporting and freezing obligations with severe penalties for non-compliance.
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What Changed
Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously sanctioned under the Embargo Act.
Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA provisions.
Duration: The freeze is valid for four years until 4 January
What You Need To Do
Screen and identify
Freeze assets
Report to MROS
Internal updates
Document compliance
Key Dates
5 January 2026, 11 a.m.Ordinance enters into force; immediate asset freezing and reporting required.DEADLINE
4 January 2030Asset freeze expires after four years, unless extended or revoked.
5 January 2026.
Compliance Impact
Urgency: Critical. This demands immediate action as the freeze took effect on 5 January 2026 at 11 a.m., with custodial penalties up to three years for failures; given today's date (25 January 2026), firms must confirm compliance now to avoid fines up to CHF 250,000 or enforcement. It heightens AML/
ESMA launches selection of Consolidated Tape Provider for OTC derivatives 05 January 2026 MiFID - Secondary Markets Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, is launching the first selection procedure for the Consolidated Tape Provider (CTP) for over the counter (OTC) derivatives. Entities interested to apply are encouraged to register and submit their requests to participate in the selection procedure by 11 February 20...
AI Analysis
ESMA has launched the first selection procedure for a **Consolidated Tape Provider (CTP) for OTC derivatives**, with applications due by 11 February 2026 and a decision expected by early July 2026. This initiative establishes a critical market infrastructure component to enhance transparency and efficiency in the EU's OTC derivatives market by consolidating post-trade data into a single, continuous electronic stream.
What Changed
The regulatory framework introduces several substantive requirements:
CTP Mandate: The selected provider will consolidate post-trade data from trading venues and other data contributors into a unified electronic stream, enabling market participants to access accurate, timely information.
Data Scope: The CTP will collect and disseminate OTC derivatives data in accordance with ESMA's Final Report on transparency for derivatives, with specific technical standards governing pre- and post-trade tra
What You Need To Do
*For prospective CTP applicants
*For trading venues and data contributors
trade OTC derivatives data to the selected CTP from 1 March 2027
minute maximum delay for real-time dissemination
*For market participants
Key Dates
11 February 2026– Deadline for entities to register and submit requests to participate in the selection procedureDEADLINE
Early July 2026– ESMA to adopt reasoned decision on selected applicant
1 September 2026– Mandatory use of new OTC derivatives identifying reference data (Commission Delegated Regulation (EU) 2025/1003)
1 March 2027– Single application date for all derivatives-related changes: amendments to RTS 2, Package Order RTS, and OTC derivatives CTP data requirements
The FCA has opened an enforcement investigation into The Claims Protection Agency Limited (TCPA) following concerns about its advertising and sales tactics in relation to potential motor finance claims. The FCA is investigating what customers were told about the amount of redress they might obtain, whether they were told they could make a claim for free, and whether they were pressurised to sign up.Announcing the investigation allows TCPA customers to consider their options.The FCA has not re...
The Berne Financial Services Agreement (BFSA) is a mutual recognition agreement between the UK and Switzerland, effective from 1 January 2026. This agreement enhances cross-border market access for financial services between the two countries.
The Federal Financial Supervisory Authority (BaFin) has sufficient grounds to suspect that TPK Vermögensverwaltungs KG is offering securities to the public in Germany in the form of shares in AuA 24 AG without the required prospectus. There are no indications that the conditions for exemption from the prospectus requirement are met.
The Securities and Exchange Commission today announced that Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), concluded her tenure with the agency on December 26, 2025.“I am thankful to Nekia for answering the call to…
AI Analysis
This SEC press release announces the departure of Nekia Hackworth Jones, Deputy Director of the Division of Enforcement (Southeast), who concluded her tenure on December 26, 2025, after overseeing enforcement investigations and litigations across Washington D.C., Atlanta, and Miami offices. It matters to compliance professionals as personnel changes in SEC Enforcement leadership can signal potential shifts in enforcement priorities, investigation focus, or regional scrutiny intensity in the Southeast U.S.
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What Changed
There are no main regulatory changes, new requirements, or policy updates in this announcement; it is solely a personnel departure notice with no substantive regulatory implications.
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What You Need To Do
related delays and monitor for successor announcements via https://www
Key Dates
December 26, 2025- Nekia Hackworth Jones concludes her tenure at the SEC.
December 29, 2025- SEC issues press release announcing the departure.
Compliance Impact
Urgency: low - This is a routine leadership transition with no immediate regulatory or enforcement changes; it matters peripherally for firms anticipating shifts in SEC Enforcement priorities under new leadership, but lacks direct compliance obligations.
The Securities and Exchange Commission today announced that Cicely LaMothe, Deputy Director of the Division of Corporation Finance, has retired from the agency.“Cicely has gone above and beyond the call of duty over the past twenty-four years to serve…
The Financial Services and the Treasury Bureau (FSTB) and Securities and Futures Commission (SFC) have concluded consultations launched on 27 June 2025 on licensing regimes for virtual asset (VA) dealers and VA custodians, confirming legislative proposals to regulate these activities while further consulting on new regimes for VA advisers and asset managers. This advances Hong Kong's comprehensive VA regulatory roadmap, mandating SFC licensing for core VA dealing (e.g., VA-to-VA conversions, broker-dealer services) and custody (focusing on private key safekeeping), with strict requirements for asset segregation and use of licensed custodians to mitigate risks like insolvency, fraud, and cyberattacks. It matters for compliance professionals as it closes gaps in VA oversight, enforces Type 1/Type 13-equivalent standards, and signals accelerated implementation in 2026, potentially reshaping market structures for trading, custody, and related services.
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What Changed
VA Dealer Regime: Introduces licensing for VA dealing activities (e.g., VA conversions, broker-dealer services at physical outlets or otherwise), excluding tokenized securities/derivatives (regulated under existing regimes) and HK-licensed stablecoin issuers; dealers must use only SFC-licensed VA custodians (not overseas) for client assets and may need to partner with SFC-licensed VA trading platforms (VATPs) for liquidity, mirroring Type 1 (dealing in securities) financial resources rules.
VA C
What You Need To Do
Pre-Application Engagement
License Applications
Custody Segregation
Compliance Mapping
Monitor Further Consults
Compliance Impact
Urgency: High – Conclusions signal imminent 2026 legislation and licensing without transitional relief, requiring firms to build infrastructure (e.g., licensed custody partnerships, RO appointments) amid a two-tier market (trading segregated from custody) to avoid operating unlicensed post-implement
Warning Warning Savings protection Crypto-assets Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
On 21 November 2025, Michael Pettifer Insurance Brokers Limited, trading as MPI Brokers, entered creditors’ voluntary liquidation. Robert Cooksey of Bridgestones Limited has been appointed as liquidator. MPI Brokers was authorised and regulated by the FCA to sell and arrange insurance policies. The firm specialised in travel insurance.If you need to contact the liquidator, please contact Bridgestones using the details below:Email: mail@bridgestones.co.ukIn writing: MPI Brokers (In Liquidation...
Warning Warning Savings protection Miscellaneous assets The AMF is warning the public against several entities proposing to invest in miscellaneous assets without being authorized to do so
The German Financial Supervisory Authority (BaFin) warns against WhatsApp groups such as „S373 Robeco Kernmitgliedergruppe“, “M2 Robeco Value Investing Kreis“ and „999 Robeco Investment Strategiezentrum - Blockhandel“, which are allegedly operated by the Frankfurt a.M.-based company Robeco Deutschland, Zweigniederlassung der Robeco Institutional Asset Management B.V. („Robeco“). In the WhatsApp groups consumers are enticed to trade financial products via the app „RBC NL“. It is suspected that...
The Securities and Exchange Commission today filed charges against purported crypto asset trading platforms Morocoin Tech Corp., Berge Blockchain Technology Co. Ltd., and Cirkor Inc. and investment clubs AI Wealth Inc., Lane Wealth Inc., AI Investment…
Sanctions & settlements professional obligations Journalists Investment management companies Listed companies and issuers AMF Enforcement Committee fines the depositary CACEIS Bank for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning on 17 December 2025 for breaches of its professional obligations as depositary for seven French-law UCITS funds managed by H2O AM LLP (later transferred to H2O AM Europe). This decision underscores the AMF's strict enforcement of depositary oversight duties, particularly in verifying fund managers' investment monitoring systems, asset valuations, and compliance with prospectus constraints like issuer limits and security ratings. It matters for compliance teams as it highlights personal accountability risks and potential fines for inadequate due diligence in fund depositary roles, signaling heightened scrutiny amid past H2O fund issues.
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What Changed
This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and
What You Need To Do
Conduct gap analysis
Enhance oversight processes
Training and audits
Monitor appeals
Key Dates
17 December 2025- AMF Enforcement Committee decision date: €3.5M fine and warning imposed on CACEIS Bank.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision directly impacts depositaries with €3.5M precedent for oversight failures, amid AMF's pattern of multi-million fines (e.g., €5.67M total in related 2024 case involving CACEIS). It elevates risks for UCITS/AIF depositaries handling non-standard assets,
A growing number of investment schemes are being promoted unlawfully, are high risk and may even be scams. We've identified a growing number of investment schemes in holiday lodges and holiday homes being promoted to UK consumers by companies that are not FCA authorised.They may be unregulated collective investment schemes, where several investors invest their money. The schemes are being promoted unlawfully, are high risk and may even be scams. We remind consumers that if you invest in an un...
AI Analysis
The FCA has issued a consumer warning about unregulated investment schemes in holiday lodges and holiday homes, which are often promoted unlawfully by unauthorised firms, posing high risks or outright scams. These schemes typically involve collective investments without FCA authorisation, breaching UK financial promotion and collective investment scheme (CIS) rules. This matters for compliance professionals as it signals heightened FCA scrutiny on unauthorised promotions, potential enforcement actions, and the need for firms to review marketing materials and client referrals to avoid facilitation risks.
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What Changed
This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include:
Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA).
Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal.
No new requirements are introduced, but the FCA emphasises its on
What You Need To Do
Immediate verification
Client communication review
Training and monitoring
Internal reporting
Due diligence
Compliance Impact
Urgency: High. This alert indicates active FCA enforcement priority on consumer-facing scams in property-linked investments, with risks of fines, bans, or asset freezes for non-compliance (e.g., similar to past actions against mini-bond issuers). Firms face heightened supervisory visits or thematic
The Federal Financial Supervisory Authority (BaFin) warns consumers about “bearer bonds” being offered for subscription by Marketplace24-7 GmbH on the website non-dom(.)group. BaFin suspects the company of conducting banking business without the required authorisation. The company is furthermore suspected of making an unauthorised public offer of securities without a prospectus. Under the German Securities Prospectus Act (Wertpapierprospektgesetz - WpPG), a prospectus is required for an offer...
ESMA publishes 2024 data on cross-border investment activity of firms 22 December 2025 Investor protection The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, in cooperation with National Competent Authorities (NCAs), completed an analysis of the cross-border provision of investment services in 2024 . Data was gathered from investment firms across 30 jurisdictions in the EU/EEA. The main findings include: Around 370 financial firms provid...
The FCA has removed all regulatory permissions from Verus Financial Services Limited requiring it to stop conducting all regulated activities and imposed a more stringent assets restriction. The action follows concerns that the firm has repeatedly breached an existing asset restriction, which prevented it from selling, transferring or diminishing its assets without our approval. It also failed to comply with a Financial Ombudsman Service decision. We issued a First Supervisory Notice (PDF) on...
The Federal Financial Supervisory Authority (BaFin) warns consumers about the website paragonixedge(.)app. BaFin suspects the unknown operators of offering consumers cryptoasset services without the required authorisation.
relating to specialised investment funds, investment companies in risk capital and undertakings for collective investment subject to Part II of the Law of 17 December 2010
AI Analysis
Circular CSSF 25/901 consolidates and modernizes the supervisory framework for Luxembourg specialised investment funds (SIFs), investment companies in risk capital (SICARs), and undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs), including their sub-funds. It streamlines investment rules, diversification limits, borrowing, disclosures, and risk management while enhancing flexibility for sophisticated investors and formalizing prior informal guidance, reducing regulatory complexity without compromising investor protection.
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What Changed
Diversification and investment limits: Introduces tailored percentage-based thresholds; for funds marketed to unsophisticated retail investors, limits remain at 25% per issuer/UCI/asset, raised to 50% per issuer/UCI/asset or 70% per infrastructure investment for well-informed/professional investor funds, with CSSF derogations possible on justification. Limits apply on assets/commitments basis with look-through for intermediary vehicles.
SICAR-specific rules: Confirms risk capital investments (e.
What You Need To Do
Review and update fund documents (e
Assess and document compliance with new/relaxed diversification, borrowing, and SICAR investment rules; apply for CSSF derogations where justified
Ensure risk-spreading in derivatives/collateral and deployment of SICAR cash into eligible assets; confirm look-through for intermediaries
For retail-marketed funds
Maintain robust governance/documentation to leverage flexibility; reference CSSF's Compilation for concepts
Key Dates
late 2025/early 2026 publications, but no explicit dates are provided.
Compliance Impact
Urgency: High – Formalizes prior informal guidance into binding rules with enhanced flexibility but stricter retail protections and disclosure mandates, requiring immediate document reviews/updates for non-compliant SIFs/SICARs/Part II UCIs to avoid supervisory scrutiny or authorization issues; crit
The Federal Financial Supervisory Authority (BaFin) warns customers about online trading platforms that use the slogan “[...] invest your money in the world of cryptocurrencies with [...]”. BaFin suspects the unknown operators of offering consumers cryptoasset services without the required authorisation. The websites have the same text design and layout.
Revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment (“UCI”) are subject
AI Analysis
Circular IML 91/75, as amended up to CSSF Circular 25/901, consolidates and modernizes the supervisory framework for Luxembourg Part II UCIs, SIFs, and SICARs, refining rules on diversification, borrowing, risk-spreading, and disclosures while tailoring requirements to investor profiles. It matters because it streamlines fragmented regulations, enhances fund competitiveness, and formalizes CSSF expectations without mandating immediate changes for pre-existing funds, reducing compliance burdens while promoting transparency and flexibility. This update aligns administrative practices with market realities, repealing outdated circulars to eliminate ambiguity.
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What Changed
Consolidation and Repeals: Repeals CSSF Circulars 02/80, 07/309, 06/241, and Chapters G and I of IML 91/75; renders CSSF 08/356 and Chapter H of IML 91/75 inapplicable to Part II UCIs.
Flexible Diversification Rules: Introduces investor-category-based thresholds (e.g., stricter for retail, looser for sophisticated investors); allows CSSF derogations for SIFs/Part II UCIs with justification; applies look-through for intermediary vehicles; harmonizes ramp-up (up to 12 months for liquid strategies,
What You Need To Do
Review and update offering documents/prospectuses for enhanced transparency on risks, limits, borrowing, liquidity tools (e
Align fund documentation/terminology with CSSF Compilation of key concepts for consistency in filings and communications
Disclose ramp-up/wind-down periods, potential derogations, and life extensions clearly; seek CSSF approval for exemptions where justified
Assess portfolio compliance for new funds/compartments; leverage flexibility for sophisticated investors but maintain robust governance
No immediate changes required for pre-19 Dec 2025 funds, but proactive alignment recommended to avoid future issues
Compliance Impact
Urgency: Medium – Not critical as existing funds are grandfathered with no retroactive changes required, but high relevance for new launches or material updates post-19 Dec 2025. It matters for operational efficiency (streamlined rules reduce fragmentation) and investor protection (tailored risks/di
The Federal Financial Supervisory Authority BaFin warns against offers, in particular offers to purchase shares and alleged pre-IPO shares, which are purportedly brokered by Ambassador. According to information available to BaFin, Ambassador Management GmbH, supposedly based in Frankfurt am Main, Ambassador Financial Group Ltd. and Ambassador Global Systems LLC are providing financial or investment services without the required authorisation. According to the current state of knowledge, there...
The financial supervisory authority BaFin is warning against WhatsApp and Telegram groups where consumers are lured into trading cryptocurrencies via the fraudulent trading platform TradeNova, which can currently be accessed through the website m.tradenovaeo(.)com. According to their findings, the trading platform TradeNova provides financial services, securities transactions, as well as cryptocurrency-related services without authorization.
Provisional dates for Monetary Policy Committee (MPC) announcements on Bank Rate and publication of MPC meeting minutes and the quarterly Monetary Policy Report.
The Financial Supervisory Authority BaFin has issued warnings regarding offerings found on websites maxfuledge(.)com and trading-area.maxfuledge-v2(.)com/auth/register. Based on its investigations, the purportedly London or Singapore-based trading platform MaxFulEdge offers unauthorised financial services, securities transactions, and cryptocurrency-related services. The platform promotes its offerings through supposed customer service representatives (maja.weis(at)maxfuledge.team and sophia....
The Federal Financial Supervisory Authority BaFin warns against offers on the website senvix(.)de. According to information available to BaFin, the trading platform Senvix, allegedly based in Frankfurt, is providing financial, investment and crypto asset services without the required authorisation.
Krypto Holdings Ltd., allegedly based in Frankfurt am Main and Widnau, Switzerland, offers crypto asset services on its website krypto-holdings(.)com and via unsolicited telephone calls and emails. The necessary authorisation for this has not been granted.
The Securities and Exchange Commission today announced that financial economist and academic scholar Dr. Joshua T. White will return to the agency beginning the week of Jan. 5, 2026, to serve as its Chief Economist and Director of the Division of…
The FCA welcomes the Government’s consultation on a new benchmarks regime for the UK. Since the introduction of the current regulatory framework, the financial landscape has evolved significantly. We now have an opportunity to build a regime that is more targeted to current market conditions and to reduce unnecessary burdens on industry, without compromising high standards. We are working with the Government to reform the current benchmarks regime to ensure that the regulatory framework remai...
AI Analysis
The FCA welcomes HM Treasury's consultation on reforming the UK Benchmarks Regulation (BMR) to create a narrower, risk-based **Specified Authorised Benchmarks Regime (SABR)**, reducing regulatory scope by 80-90% to target only systemically important benchmarks and administrators while easing burdens on industry. This matters for compliance professionals as it shifts from broad regulation of all benchmarks to targeted oversight, requiring firms to reassess benchmark usage, prepare for transition, and adapt to FCA rules on risk management, enhancing UK competitiveness post-FSMA 2023 repeal of assimilated laws.
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What Changed
Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or markets; reduces coverage by 80-90%, with no distinction between critical/significant/other types or benchmark categories (e.g., interest rate, commodity).
FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; remov
What You Need To Do
Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios
Participate in HMT consultation (responses via gov
Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance
Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility
Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules
Key Dates
17 December 2025- HM Treasury publishes consultation on benchmarks regime reform.
1 January 2026- Reforms take initial effect; UK becomes only jurisdiction regulating all local benchmarks pre-reform; EU BMR reforms effective, highlighting UK divergence.
Due course 2026- FCA consults on regulatory requirements for designated administrators/users.
2026- FCA expected to publish updated guidance on critical benchmarks and implement SABR refinements.
Compliance Impact
Urgency: High - Significant scope reduction eases burdens but introduces transition risks, new FCA rules, and designation uncertainty; firms must act now on consultation (post-Dec 2025) and prep for 2026 FCA changes to avoid non-compliance during shift, especially with 1 Jan 2026 milestone amplifyin
amending Circular CSSF 22/811.Authorisation and organisation of entities acting as UCI administrators.
AI Analysis
Circular CSSF 25/900, issued on 16 December 2025, amends Circular CSSF 22/811 to clarify governance principles, authorisation requirements, and operational standards for UCI (Undertakings for Collective Investment) administrators in Luxembourg, while reforming annual reporting obligations. It matters because it strengthens supervisory oversight, aligns with DORA for ICT outsourcing, and simplifies reporting to enhance efficiency and compliance in the fund administration sector.
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What Changed
Repeals Annex B of Circular CSSF 22/811 with immediate effect, replacing it with streamlined annual reporting via a core compliance-focused Self-Assessment Questionnaire (SAQ) that assesses governance, internal controls, operational organization, and risk management; detailed instructions are now on the CSSF website.
Introduces prior CSSF authorisation requirements for entities acting as UCI administrators, including a defined administrative procedure with application details in Annex A; authori
What You Need To Do
Assess eligibility and obtain prior CSSF authorisation via Annex A application (or notify substantial changes); ensure ongoing validity by monitoring operational model and delegations
Adapt internal processes for revised annual UCIA reporting (SAQ-focused, integrated where applicable); submit using CSSF website instructions starting for FY ending 31 Dec 2025
Review/update contracts with UCIs/IFMs to define roles, responsibilities, and oversight; implement delegation monitoring, remediation plans, and ICT compliance (DORA/Circular 25/882 or 20/750)
For DORA-scope entities, align outsourcing arrangements with Circular CSSF 25/882
Key Dates
16 December 2025- Issuance date; repeal of Annex B of Circular CSSF 22/811 effective immediately.
January 2025- DORA entry into force, applying to ICT outsourcing for in-scope UCIAs.
31 December 2025- New reporting framework (SAQ and updated modalities) applies to all financial years ending on or after this date.
Compliance Impact
Urgency: High - Immediate repeal of prior reporting Annex requires prompt process updates; new framework applies to FY 2025 year-ends (just past as of Jan 2026), risking supervisory scrutiny or penalties for non-compliance; DORA alignment adds operational resilience pressure amid ongoing CSSF focus
We’re seeking feedback on whether tailored market risk rules for non-bank trading firms could remove unnecessary barriers, free up capital and attract new market participants, ultimately supporting economic growth. The rules in place today were originally designed for banks to ensure they held enough capital to absorb major trading losses and protect depositors.While that approach is sensible, it means non-bank trading firms face the same standards even though the potential harm from their fa...
We are asking for views on new proposals as the next step in shaping the UK’s crypto rules. These proposals continue our progress towards an open, sustainable and competitive crypto market that people can trust. We want a market where innovation can thrive, but where people understand the risks. Regulation cannot – and should not – remove all risk. Instead, it should make sure anyone investing in crypto does so with their eyes open.Our proposals apply a similar approach to crypto as we do in ...
On 16 December 2025, the Swiss Financial Market Supervisory Authority FINMA launched the consultation on the partially revised Circular 2016/7 “Video and online identification”. The consultation will go on until 27 February 2026.
Authorisation and organisation of entities acting as UCI administrators
AI Analysis
Circular CSSF 22/811, as amended by Circular CSSF 25/900, establishes CSSF requirements for the authorisation, governance, internal organisation, and oversight of entities acting as UCI (Undertakings for Collective Investment) administrators in Luxembourg. It matters because it standardises practices amid regulatory, technological, and market evolutions, ensuring robust controls, risk management, and supervision for fund administration activities critical to Luxembourg's fund industry.
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What Changed
Authorisation Requirements: Prior CSSF authorisation is mandatory for appointment as UCI administrator, via full application under sectoral laws or a simplified administrative procedure; application must include details per Annex A, with ongoing updates for substantial changes.
Scope of UCI Administration: Defines three core functions—registrar, NAV calculation/accounting, and client communication—requiring only one designated service provider per function per UCI (or compartment); UCI/IFM may p
What You Need To Do
Submit authorisation application to CSSF with Annex A information before commencing UCI administration; notify substantial changes and keep file updated
Establish/implement governance, controls, escalation processes, resource adequacy, ICT/business continuity per circular; ensure single provider per function
For delegations
Conclude written contracts with UCI/IFM; submit annual UCIA activity reports
Compliance Impact
Urgency: High – Non-compliance risks CSSF sanctions, as authorisation is prior and ongoing; critical for Luxembourg fund ecosystem given evolutions in tech/markets/DORA. Firms must act promptly if unauthorised or misaligned, especially with annual reporting since 2023 and DORA integration; impacts o
Earlier this year, we undertook a refresh of our Sustainable Finance Advisory Committee. In line with good governance, we planned to refresh the membership on a staggered basis, allowing us to bring in new expertise whilst benefiting from some continuity. Following this process, we are pleased to announce the appointment of two new members to the Committee:Elly Dowding, Director of ESG AccordFarnam Bidgoli, Independent AdviserThese appointments reflect our commitment to drawing on diverse exp...
An update on our investigation into Mirabella Advisors LLP. On 4 May 2021, we announced that we had opened an investigation into the oversight of Greensill Capital Securities Limited, an appointed representative, by its principal, Mirabella Advisors LLP. Our investigation reviewed the nature, conduct and scope of Mirabella’s business. We did not identify breaches by Mirabella that require further action. The investigation has therefore now closed. Mirabella applied to have its authorisation c...
AI Analysis
The FCA has closed its investigation into Mirabella Advisors LLP's oversight of its appointed representative (AR), Greensill Capital Securities Limited, finding no breaches warranting further action. This closure, announced after reviewing Mirabella's business nature, conduct, and scope, signals effective AR oversight in this high-profile case tied to the Greensill collapse, while Mirabella voluntarily cancelled its authorisation effective 12 September 2025. It matters for compliance professionals as it reinforces FCA expectations on principal-AR relationships without imposing new penalties or rules, but underscores ongoing scrutiny in trade finance and supply chain finance sectors.
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What Changed
There are no new regulatory changes, requirements, or rules introduced by this publication. The statement solely announces the closure of an existing investigation with no identified breaches by Mirabella, maintaining the status quo on AR oversight obligations under FCA rules such as SUP 12 (Appointed Representatives). The FCA reserves the right to reopen if new information emerges, but no policy shifts or guidance updates are provided.
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Key Dates
4 May 2021- FCA announced opening of investigation into Mirabella's oversight of Greensill Capital Securities Limited as AR.
12 September 2025- Mirabella's authorisation cancelled; firm no longer provides financial services.
Compliance Impact
Urgency: Low - This is a positive closure with no findings of misconduct, new rules, or enforcement, reducing immediate compliance burdens. It matters indirectly by exemplifying robust AR oversight meeting FCA standards amid Greensill fallout, offering reassurance for similar firms while signaling c
Der Bundesrat hat die Sanktionslisten betreffend Russland und Belarus am 12. Dezember 2025 ausgeweitet. Die Schweiz übernimmt damit diverse Änderungen, welche die EU im Rahmen ihres 19. Sanktionspakets beschlossen hat.
AI Analysis
The Swiss Federal Council expanded sanctions lists against Russia and Belarus on December 12, 2025, adopting changes from the EU's 19th sanctions package to align Swiss measures with EU restrictions. This matters for Swiss financial institutions as it imposes immediate asset freezes, transaction bans, and reporting obligations on newly listed entities, strengthening efforts to counter Russia's military-industrial complex and shadow oil fleet while preventing sanctions evasion.
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What Changed
Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists.
Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans.
Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector.
Fi
What You Need To Do
Immediate screening
Asset freezing
Transaction halts
Ongoing monitoring
Key Dates
13 December 2025- Measures enter into force; immediate implementation required.DEADLINE
29 October 2025- Prior expansion decision (related 18th EU package adoption).
30 October 2025- Entry into force of October measures (export restrictions, RDIF transaction bans).
31 December 2025- Extension of certain derogations (e.g., Russia investment withdrawals).
Compliance Impact
Urgency: Critical - Effective immediately (13 Dec 2025), with no grace period for asset freezes/transaction bans, exposing non-compliant firms to severe penalties amid FINMA's active enforcement on sanctions (type: enforcement). This escalates existing Russia/Belarus regimes, targeting evasion vecto
We're providing guidance to support firms to tackle bullying, harassment and violence in financial services, after they asked for additional support. In July, we changed our rules – setting clearer standards for how financial services firms should address non-financial misconduct.This more closely aligned the rules for banks and non-banks. We wanted to give firms the confidence to act against serious misconduct, drive consistency and make it clearer when non-financial misconduct is a breach o...
MiCA Crypto-assets Financial products Marketing Journalists Investment management companies Listed companies and issuers The AMF adapts its policy on complex financial products in response to the rise of crypto-assets
Given at the 20th High-level meeting on financial stability and regulatory and supervisory priorities (jointly organised by the Arab Monetary Fund, the Basel Committee on Banking Supervision and the Financial Stability Institute of the Bank of International Settlements).
The Securities and Exchange Commission today charged Canadian citizen Nathan Gauvin and three entities he controls—Blackridge, LLC, Gray Digital Capital Management USA, LLC, and Gray Digital Technologies, LLC—with orchestrating two fraudulent securities…
New report outlines the Central Bank’s approach to more effective and efficient regulatory and supervisory framework, reducing complexity and improving clarity while maintaining resilience and important protections in the system. This work builds on the Central Bank’s strategy to transform regulation and supervision, including the introduction of our new integrated supervisory approach and the improvements made in our gatekeeping processes in recent years. The roadmap sets out a comprehensive...
AI Analysis
The Central Bank of Ireland published a comprehensive multi-year roadmap on December 10, 2025, aimed at streamlining its regulatory and supervisory framework across four pillars: supervision, regulation, gatekeeping, and reporting. This initiative represents a strategic shift toward more effective and efficient oversight while explicitly maintaining resilience standards and consumer protections, responding to EU calls for regulatory reform to enhance competitiveness.
What Changed
The roadmap encompasses four major reform areas:
*Supervision: Implementation of a new integrated, risk-based supervisory approach** introduced in January 2025, consolidating multidisciplinary teams and sharpening risk focus with clearer supervisory communications. This delivers more coherent firm engagement, stronger proportionality, and streamlined processes.
*Regulation: Comprehensive updates to the domestic rulebook, including:
Insurance: Major compatibility review to eliminate duplication
What You Need To Do
*Immediate actions for compliance professionals
*Monitor consultation releases
*Assess rulebook changes
*Evaluate supervisory engagement
*Prepare for gatekeeping changes
Key Dates
January 2025- New integrated supervisory model became effective
2026- Public consultation on new Regulatory Impact Assessment Framework
2026 to first half of 2028- Multi-year programme implementation period for all roadmap initiatives
2025- Strategic review of Industry Funding Levy approach (consultation expected during 2025)
The Board of Directors of the Swiss Financial Market Supervisory Authority FINMA has appointed Hedwig Ulmer Busenhart as the new Head of the Insurance division. The qualified mathematician and actuary has over 25 years of management experience in the insurance sector and will take up her position on 1 April 2026. She succeeds Birgit Rutishauser, who left FINMA in April 2025.
The Securities and Exchange Commission today announced it will hold the second in its series of compliance outreach events regarding the 2024 adoption of amendments to Regulation S-P. The event, for transfer agents, is a webinar scheduled for December 17…
A raft of new measures designed to support the growth of the mutuals sector have been announced today by the financial regulators. They include a review of credit union regulations and the launch of a Mutual Societies Development Unit by the Financial Conduct Authority (FCA).
This report has been informed by the PRA and FCA’s ongoing regulation and supervision of mutuals and by direct engagement with mutuals and their trade associations in sessions around the country throughout 2025.
Financial disclosures & corporate financing Journalists Listed companies and issuers The Autorité des Marchés Financiers takes note of the Cour de Cassation ruling in the Vivendi SE case
The Board of Directors of the Swiss Financial Market Supervisory Authority FINMA has extended Beat Fellmann’s term of office by one year until the end of 2026.
The Securities and Exchange Commission’s Investor Advisory Committee will hold a virtual public meeting on Dec. 4, 2025, at 10 a.m. ET. The meeting will be webcast on the SEC website.The committee will host two panels:Regulatory Changes in Corporate…
The CFTC filed a civil enforcement action on November 21, 2025, against Brian Mitchell, Kevin Mack Jr., and their unregistered entity Young Pros Investment Group LLC (YPIG) for fraudulently soliciting ~$1 million from 33 pool participants to trade commodity futures, using misrepresentations, Ponzi payments, false statements, and registration violations, including Mitchell's breach of a prior 2021 CFTC order. This case underscores the CFTC's aggressive enforcement against unregistered commodity pools and fraud, seeking restitution, disgorgement, penalties, trading bans, and injunctions under the Commodity Exchange Act (CEA). Compliance teams must prioritize registration checks and fraud prevention to avoid similar actions, as it highlights personal liability for controlling persons.
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What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reinforces longstanding CEA and CFTC rules on:
Mandatory registration as a Commodity Pool Operator (CPO) and Associated Persons (APs) for pools trading commodity futures (CFTC Regulation 4.13 exemptions do not apply here due to fraud and public solicitation).
Prohibitions on fraud, misrepresentations, guarantees of profit, non-disclosure of risks, commingling funds, and operating pools as
What You Need To Do
Verify registration
Implement controls
Conduct due diligence
Train staff
For SEC-registered advisers
Key Dates
2025.
November 21, 2025- CFTC files complaint in U.S. District Court for the Eastern District of Michigan.
~December 2020 - May 2022- Alleged fraudulent solicitation and trading period.
2021- Prior CFTC administrative order against Mitchell (Press Release 8427-21) prohibiting trading and registration activities for three years.
Compliance Impact
Urgency: High - This action signals intensified CFTC scrutiny on unregistered pools amid rising crypto/futures fraud (e.g., similar January 2026 case against Wolf Capital). It matters because penalties include personal bans, multimillion restitution/disgorgement, and whistleblower awards (10-30% of
This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.
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What Changed
New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13 to include "targeted support" activities (Category 2 variation fee for existing firms, Category 4 for new entrants); registration fees for Deferred Payment Credit (DPC/buy-now-pay-later) activities aligned with Temporary Permissions Regime, added to FOS consumer credit fee-block but excluded from FSCS.
What You Need To Do
Review current fee/levy exposure and model impacts of new blocks (e
Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates
Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026
Budget for potential fee increases; monitor Spring 2026 fee-rates CP
For applicants
Key Dates
9 January 2026- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7).DEADLINE
16 January 2026- Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk.
February 2026- FCA publishes feedback and rules on targeted support in Handbook Notice.
March 2026- FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation.
April 2026- PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March).
Compliance Impact
Urgency: High – Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities
The CFTC today announced the U.S. District Court for the Central District of California entered a final judgement against Safeguard Metals LLC and Jeffrey Ikahn (aka Jeffrey Santulan and Jeffrey Hill) ordering them to pay $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for operating a nationwide, precious metals fraud. Released: 11/20/2025
AI Analysis
The CFTC, alongside 30 state regulators, secured a final judgment on November 20, 2025, against Safeguard Metals LLC and Jeffrey Ikahn, imposing $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for a nationwide precious metals fraud scheme from October 2017 to July 2021 that defrauded over 450 elderly investors of more than $52 million. This enforcement action, resolving a February 2022 complaint, highlights coordinated federal-state-SEC efforts to combat commodity fraud and underscores personal liability for controlling persons under CEA Section 6(c)(1) and Regulation 180.1(a). It matters for compliance as it reinforces aggressive penalties for misrepresentations, overcharges, and targeting vulnerable populations, with offsets across parallel SEC proceedings.
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What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reaffirms existing CEA prohibitions on fraud, including Section 6(c)(1), 7 U.S.C. § 9(1), and 17 C.F.R. § 180.1(a)(1)-(3), covering material misrepresentations, omissions, and deceptive schemes in precious metals sales. Key takeaways include joint-and-several liability for entities and controlling individuals (Ikahn held liable for not acting in good faith), systematic overcharges as fraud
What You Need To Do
Conduct immediate fraud risk assessments on precious metals sales scripts, disclosures, and pricing markups to ensure no material misrepresentations or undisclosed overcharges
Enhance senior investor protections, including suitability reviews, cooling-off periods, and training on vulnerable customer targeting bans
Review controlling person policies for good faith oversight, documenting supervisory failures to avoid personal liability
Audit parallel SEC/CFTC exposures in commodity-linked activities, preparing for offset calculations in multi-agency actions
Update compliance manuals with this case as precedent for CEA fraud in physical commodities; monitor whistleblower notices for internal reporting incentives
Key Dates
February 1, 2022- CFTC and states file initial complaint alleging fraud scheme.
May 5, 2022- Plaintiffs file First Amended Complaint.
September 6, 2023- Second Amended Complaint filed.
May 2, 2025- Court enters SEC remedies judgment ($25.6M disgorgement/penalty, with offsets).
September 30, 2025- Court issues Statement of Decision granting restitution ($25.6M) and civil penalty ($25.6M).
Compliance Impact
Urgency: Medium - This resolved enforcement sets precedent for precious metals fraud penalties but imposes no new rules or immediate deadlines beyond whistleblower claims (March 9, 2026). It matters due to escalating CFTC-state coordination, personal liability risks, and focus on elder fraud amid ri
The Federal Council has appointed Katia Villard to the Board of Directors of the Swiss Financial Market Supervisory Authority FINMA. A professor of criminal law, Ms Villard will succeed Ursula Cassani Bossy who is stepping down from FINMA's Board of Directors at the end of the year.
The Securities and Exchange Commission’s Division of Examinations today released its 2026 examination priorities. The Division publishes its annual examination priorities to provide transparency to registrants and investors about the topics that the…
Sustainable Finance MIFID Investment advice Long term investment Other professionals Journalists Investment services providers Investment management companies The ACPR and the AMF present their joint approach helping...
The PRA's Discussion Paper 2/25 (published November 14, 2025) invites UK life insurers to provide feedback on potential regulatory reforms that would enable them to access **alternative forms of capital through risk transfer to capital markets**, outside traditional equity and debt issuance. This initiative aims to address capital constraints in the UK life insurance sector while maintaining policyholder protection and supporting long-term economic growth.
What Changed
The PRA is considering policy reforms centered on six core principles:
*Capital Quality & Quantity**: Alternative life capital structures must not lower the quality or quantity of capital required to support insurance risks.
*Risk Transfer Focus**: Structures should enable patient capital investment aligned with long-term liability profiles, allowing investors to forgo immediate returns for substantial future gains.
*Capital Relief Priority**: Alternative life capital should predominantly del
What You Need To Do
*For UK life insurers
*Assess capital needs
*Prepare consultation response
*Engage with policy development
*Assess structural readiness
Key Dates
6 February 2026– Deadline for stakeholder responses to DP2/25DEADLINE
2026– PRA planned policy design and cost-benefit analysis (alongside HM Treasury work)
The Securities and Exchange Commission today announced that Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), will conclude her tenure with the agency effective Dec. 1, 2025. “I thank Antonia for her steadfast leadership in…
AI Analysis
This SEC press release announces the departure of Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), effective December 1, 2025. It signals ongoing leadership transitions within the restructured Enforcement Division under new SEC Chair Paul Atkins, which may influence enforcement priorities, transparency, and regional consistency, requiring firms to adapt compliance strategies amid a "return to basics" approach focused on core investor protection.
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What Changed
This announcement itself introduces no new regulatory changes or requirements; it is a personnel update. However, it occurs amid broader Enforcement Division restructuring, including:
Consolidation from one Deputy Director to four (three regional: Northeast, Southeast, West; one for specialized units), reducing reporting lines for a more unified nationwide enforcement program.
Rescission in March 2025 of delegated authority for the Enforcement Director to issue formal orders of investigation, no
What You Need To Do
Review ongoing Northeast Regional Office investigations for potential leadership changes and engage early with new deputies on cooperation opportunities
Enhance internal self-reporting and remediation protocols to align with Enforcement's stated rewards for cooperation and robust Wells processes
Update compliance training on restructured reporting lines and Commission-authorized formal orders, ensuring defenses stick to established securities laws rather than novel theories
Monitor SEC staff directory for replacement announcements, such as potential roles for Samuel Waldon or others in the Northeast
Key Dates
December 1, 2025- Antonia M. Apps concludes her tenure as Deputy Director of Enforcement (Northeast).[User Query]
December 26, 2025- Nekia Hackworth Jones concluded her tenure as Deputy Director of Enforcement (Southeast).
March 2025- SEC rescinded delegation of formal order authority to Enforcement Director.
April 2025- Nekia Hackworth Jones appointed Deputy Director (Southeast).
September 2, 2025- Margaret A. Ryan appointed Director of Enforcement.
Compliance Impact
Urgency: Low - This is a routine personnel change with no immediate regulatory shifts or deadlines post-December 1, 2025. It matters indirectly as part of 2025's Enforcement Division overhaul (15% headcount reduction, regional consolidation), likely leading to prioritized, transparent enforcement on
An investigation by the Insurance Industry Vocational Training Association (VBV) has revealed that VBV intermediary certificates were wrongly issued in around 100 cases as a result of manipulation. The VBV is not supervised by FINMA. The association acts on behalf of the insurance and intermediary industry and will restore compliance with the law for these certificates. It has also filed a criminal complaint. Untied intermediaries are subject to direct supervision by FINMA. If there is eviden...
The Bank of England (the Bank) has today published a consultation paper (CP) setting out its proposed regulatory regime for sterling-denominated systemic stablecoins.
AI Analysis
The Bank of England has published a consultation paper (issued November 10, 2025) proposing a comprehensive regulatory regime for **sterling-denominated systemic stablecoins**, establishing requirements for backing assets, capital, redemption procedures, and operational safeguards. This represents a pivotal step toward implementing the UK's stablecoin framework, with the regime designed to maintain financial stability while enabling viable business models for systemic stablecoin issuers.
What Changed
The proposed regulatory regime introduces several material requirements for systemic stablecoin issuers:
*Backing Asset Composition
Systemic stablecoin issuers will be permitted to hold up to 60% of backing assets in short-term sterling-denominated UK government debt, with the remaining 40% held as deposits at the Bank of England. For stablecoins recognized as systemic at launch, a temporary "step-up" regime allows up to 95% of backing assets in UK government securities**, which would reduce to
What You Need To Do
*For Systemic Stablecoin Issuers
*Monitor and respond to consultation - Submit detailed comments on proposals before February 2026 deadline, particularly on:
Alternative tools to achieve regulatory objectives
Backing asset composition and holding limits
Safeguarding regime design
Key Dates
November 10, 2025- Bank of England published consultation paper on proposed regulatory regime
February 2026- Consultation deadline (industry to submit comments)DEADLINE
2026- Expected implementation of UK stablecoin regime (timeline subject to consultation outcomes)
Further consultation expected- On detailed design of safeguarding regime and central bank liquidity arrangements
Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services
AI Analysis
Circular CSSF 07/325, as amended by Circulars CSSF 21/765, CSSF 22/827, and most recently CSSF 25/898, establishes supervisory requirements for EU credit institutions and investment firms operating in Luxembourg via branches or free provision of services (FOPS). It matters for compliance professionals as it defines CSSF's host authority role, notification obligations, reporting, and enforcement powers, ensuring alignment with CRD and MiFID II while adapting to evolving EU rules.
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What Changed
CSSF 21/765: Updated provisions following amendments to CSSF Regulation No 12-02, refining notification and operational requirements for branches and FOPS.
CSSF 22/827: Further amendments to align with CRD and MiFID II changes, including enhanced notifications for programme alterations (e.g., one-month prior written notice for changes in operations, services, or activities).
CSSF 25/898: Latest update (noted in CSSF Newsletter No 298, November 2025), incorporating recent legal/regulatory develop
What You Need To Do
Notifications
Supervision cooperation
Key Dates
One month before change effective date- Notify CSSF and home authority in writing of programme changes (e.g., operations, services, additional places of business) per CRD Article 36(3) and MiFID II Article 35(10).
Within 3 months of receipt- Home state authority communicates notification file to CSSF for branch/FOPS establishment.
Six months after financial year-end- Submit electronically signed SAQ (via eDesk), annual AML/CFT and conduct of business report (per Circular CSSF 19/731, to be repealed by CSSF 25/902), reviewed by REA.
Compliance Impact
Urgency: Medium - Matters due to recurring annual reporting (e.g., SAQ, AML/CFT within six months post-year-end) and prior notifications for changes, with CSSF enforcement powers (e.g., measures under LFS Article 46(2)) for non-compliance. Recent CSSF 25/898 update (Nov 2025) requires immediate revi
Update of Circular CSSF 07/325 on Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services, as amended by Circulars CSSF 21/765 and CSSF 22/827
AI Analysis
Circular CSSF 25/898 updates Luxembourg's supervisory framework for EU-origin credit institutions and investment firms operating in Luxembourg through branches or free provision of services. This amendment enhances the self-assessment questionnaire (SAQ) used by the CSSF to align supervisory oversight with current regulatory priorities, particularly adding UCI administration as a new thematic module. The update reflects the CSSF's evolving supervisory focus and requires affected institutions to demonstrate compliance with expanded assessment criteria.
What Changed
The circular introduces the following material modifications to Circular CSSF 07/325:
*New Supervisory Module
UCI administration** has been added as a thematic module to the self-assessment questionnaire, reflecting increased regulatory attention to fund administration practices.
*Enhanced Self-Assessment Framework**
Existing modules have been updated to better align with supervisory objectives and current regulatory priorities.
The revised SAQ now captures a broader range of supervisory point
What You Need To Do
*Update Self-Assessment Processes
Revise internal SAQ completion procedures to address the new UCI administration module
Ensure all thematic modules reflect current supervisory expectations
*Assess UCI Administration Compliance
If the institution provides or is involved in UCI administration services, conduct a detailed assessment of compliance with CSSF expectations
Key Dates
31 October 2025- Circular CSSF 25/898 published by the CSSF
19 December 2025- Related modernization framework (Circular CSSF 25/901) entered into force for Part II UCIs, SIFs, and SICARs
No specific implementation deadline stated- Institutions should align their SAQ responses and compliance documentation with the updated framework immediately upon publicationDEADLINE
Warning Warning Savings protection The AMF warns the public against fraudulent communications offering investment services impersonating Financière du Nogentais
Die Schweiz schliesst sich den weiteren Massnahmen des 18. Sanktionspakets der Europäischen Union (EU) gegenüber Russland sowie den zusätzlich zum 18. Sanktionspaket erlassenen Massnahmen gegenüber Belarus an. Dies hat der Bundesrat am 29. Oktober 2025 beschlossen. Im Fokus stehen Massnahmen im Güter-, Finanz und Energiebereich. Der Bundesrat hat dafür die Verordnung über Massnahmen gegenüber Belarus (SR 946.231.116.9) geändert.
AI Analysis
Switzerland has aligned with additional EU measures from the 18th sanctions package against Russia and specific Belarus measures, amending the Ordinance on Measures against Belarus (SR 946.231.116.9) to focus on goods, financial, and energy sectors. This strengthens the sanctions regime against Belarus to mirror Russia's more closely, aiming to enhance effectiveness and prevent circumvention. Compliance teams must prioritize asset freezes, transaction prohibitions, and reporting to avoid enforcement risks from FINMA and SECO.
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What Changed
Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine.
Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening), financial services (e.g., transaction bans on additional banks), and energy sectors.
Requirements for financial intermediaries to
What You Need To Do
Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists)
Freeze assets of newly sanctioned persons/entities and prohibit dealings (e
Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist
Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e
Review third-party exposures (e
Key Dates
18 July 2025- EU adopts 18th sanctions package against Russia and additional Belarus measures.
29 October 2025- Swiss Federal Council decides to align and amends SR 946.231.116.9.
30 October 2025- New provisions enter into force.
13 December 2025- Related expansion of Russia/Belarus lists (22 persons, 42 entities, 116 ships, 45 trade firms) takes effect, relevant for harmonization context.
Compliance Impact
Urgency: High - Effective 30 October 2025, these changes demand immediate portfolio screening and reporting, with non-compliance risking FINMA enforcement, asset seizure, or criminal penalties under sanctions laws. Matters due to rapid alignment with evolving EU packages, increasing circumvention ri
Europe & international Sanctions & settlements Publication of the annual ESMA Report on Sanctions and Measures for 2024: AMF imposes the highest amounts in Europe
AI Analysis
The ESMA Annual Report on Sanctions and Measures for 2024, published on 16 October 2025, aggregates enforcement data from EEA national competent authorities (NCAs), highlighting that the French AMF imposed the highest total sanctions at €29.4 million—nearly a third of the EEA's €100 million aggregate—primarily under MAR and MiFID II. This matters for compliance professionals as it signals intensified enforcement focus on market abuse and investor protection across Europe, with France leading in both fine amounts and settlement usage, underscoring a trend toward higher penalties and agile resolution mechanisms.
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What Changed
This is not a new regulation but a retrospective report documenting 2024 enforcement trends; no direct regulatory changes are introduced. Key observations include a significant rise in total fine amounts to over €100 million (from €71 million in 2023) despite stable sanction volumes (975 vs. 976), with MAR (377 sanctions, €45.5 million) and MiFID II/MiFIR (294 sanctions, €44.5 million) dominating. Notable shifts: increased settlement usage (94 agreements for €21.9 million, 22% of total), with AM
What You Need To Do
sanction areas
Key Dates
16 October 2025- ESMA publishes second consolidated Annual Sanctions Report for 2024 data.
covering 2024activities.
Compliance Impact
Urgency: medium – This report reinforces existing rules without new requirements, but signals escalating financial penalties (up 40% YoY) and settlement trends, pressuring firms to prioritize MAR/MiFID compliance to avoid outsized AMF-style fines, especially in France or cross-EEA operations. Matter
**PS20/25** represents the second and final phase of the PRA's "Strong and Simple Framework," establishing a significantly simplified capital regime for Small Domestic Deposit Takers (SDDTs) while maintaining their resilience. This near-final policy statement, published on 28 October 2025, fundamentally restructures capital requirements, liquidity rules, and operational frameworks for SDDTs—a critical development for smaller deposit-taking institutions seeking regulatory relief from disproportionate compliance burdens.
What Changed
The simplified capital regime introduces structural changes across all three pillars of capital requirements:
*Pillar 1 (Risk-Weighted Assets)
SDDTs must apply Basel 3.1 standardised approaches for credit risk and operational risk, with specific simplifications.
Due diligence requirements in the standardised approach to credit risk are disapplied for SDDTs.
Counterparty credit risk (CCR) for derivatives and credit valuation adjustment (CVA) risk are disapplied (with minor exceptions).
Market ri
What You Need To Do
*For SDDTs Currently Operating or Considering Entry:
*Notification Decision – Determine whether to enter the SDDT regime and submit notification to the PRA by 31 March 2026 if seeking to benefit from simplified rules
*Policy Review – Conduct comprehensive review of PS20/25, related policy statements (PS18/25, PS19/25, PS8/25, PS14/25), and supporting methodologies (SoP5/25, SS4/25, amendments to SoP2/23)
*Capital Calculation Transition – Prepare systems and processes to transition from current capital calculation methodologies to Basel 3
Removal of CCR and CVA calculations for derivatives
Key Dates
31 March 2026– Deadline for firms wishing to enter the SDDT regime to notify the PRA and benefit from the simplified framework at implementation.DEADLINE
1 January 2027– Implementation date for the simplified capital regime for SDDTs; the Interim Capital Regime will no longer apply.
2026 (specific date TBD)– PRA to make final rules and policy covering the entire Basel 3.1 package once HM Treasury makes commencement regulations to revoke relevant CRR provisions.
2027 (specific date TBD)– PRA to implement restatement of CRR requirements (PS19/25).
Crypto-assets Investment services Financial services providers The Financial Stability Board and the International Organisation of Securities Commissions publish two reports assessing the implementation of recommendations on crypto-asset and stablecoin activities
Financial disclosures & corporate financing Public offer Prospectus Executive & other private individuals Professional investors Journalists Listed companies and issuers The AMF announces new measures to facilitate access to listing
Deutsche Bank Wealth Management (CLONE) / Deutsche Bank AG (CLONE) / DB UK Bank Limited (CLONE) - Central Bank of Ireland Issues Warning on Unauthorised Firm
Warning Savings protection Warning Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
Supervision Asset management Governance Journalists Investment management companies The Autorité des Marchés Financiers publishes the findings of its thematic inspections on governance and role of senior managers at asset management companies
The Swiss Financial Market Supervisory Authority FINMA takes note of the Federal Administrative Court’s partial decision concerning the write-down of AT1 capital instruments. FINMA will contest the judgment of 1 October 2025 and appeal to the Federal Supreme Court.
Warning Warning Crypto-assets Savings protection Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
The Securities and Exchange Commission today announced that Stacey Bowers, who has served as the Director of the Office of the Advocate for Small Business Capital Formation, will depart the agency effective October 17, 2025. She has served as Director…
The Securities and Exchange Commission today published a concept release soliciting public comment on how to improve current SEC rules governing residential mortgage-backed securities (RMBS) and certain aspects of asset-backed securities (ABS) generally…
The Swiss Financial Market Supervisory Authority FINMA and the UK Financial Conduct Authority FCA and Prudential Regulation Authority PRA today signed a memorandum of understanding. The memorandum sets out details of the co-operation under the Berne Financial Services Agreement and opens up new cross-border opportunities in insurance and investment services.
Supervision Other professionals Fintech Market Infrastructures Professional investors Journalists Investment management companies Listed companies and issuers European supervision of capital markets: the AMF calls for an enhanced...
CP20/25 is a PRA consultation paper published on 16 September 2025 that proposes targeted updates to the regulatory framework governing third-country insurance branches operating in the UK. The consultation addresses inconsistencies introduced during the Solvency II review, clarifies supervisory expectations, and increases the subsidiarisation threshold—matters that directly affect the operational and compliance costs of non-UK insurers seeking to maintain branch operations rather than establish subsidiaries in the UK market.
What Changed
The consultation proposes four primary regulatory modifications:
*Subsidiarisation Threshold Increase
The PRA proposes raising the FSCS liability threshold above which third-country branches must establish a UK subsidiary from £500 million to £600 million**. The PRA attributes this increase to inflation rather than organic growth, aiming to prevent branches from artificially approaching the current threshold and incurring unnecessary subsidiarisation costs.
*ORSA Reporting Clarification
Curren
What You Need To Do
*Threshold Assessment
*Reporting Requirement Review
*Quantitative Metrics Compliance
*Three-Year Notification Obligation
*Asset Holding Verification
Key Dates
16 September 2025- CP20/25 published by the PRA
16 December 2025- Consultation response deadlineDEADLINE
H1 2026- Statement of Policy (SoP) expected to be published; subsidiarisation threshold update anticipated upon SoP publication
31 December 2026- Planned implementation date for rulebook changes
MiCA Other professionals Fintech Journalists Listed companies and issuers The French, Austrian and Italian markets authorities call for a stronger European framework for crypto-asset markets
The Swiss Financial Market Supervisory Authority FINMA is transferring the FINMA Banking Insolvency Ordinance, FINMA Insurance Bankruptcy Ordinance and FINMA Collective Investment Schemes Bankruptcy Ordinance to a new consolidated FINMA Insolvency Ordinance. The existing regulations have been revised and adapted where necessary – based on findings from practical experience and academia. In addition, the FINMA Insolvency Ordinance implements the amendments made necessary by the revisions to th...
Warning Warning Miscellaneous assets Savings protection The AMF is warning the public against several entities proposing to invest in miscellaneous assets without being authorized to do so
Warning Savings protection Warning Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in the unregulated foreign exchange market (Forex) and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Warning Crypto-assets Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Crypto-assets Innovation The ACPR and AMF publish the summary of responses to the consultation conducted by the Working Group on Smart Contract Certification
AI Analysis
The ACPR and AMF have published a summary of responses to a public consultation on a 2024 Working Group report exploring smart contract certification in DeFi, addressing technical standards, audit practices, and potential regulatory frameworks. This matters for compliance as it signals preparatory steps toward possible EU-level DeFi regulation, emphasizing risk reduction and trust-building without immediate mandates, influencing future operational and audit strategies for crypto firms.
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What Changed
No binding regulatory changes are introduced; this is an exploratory summary confirming industry support for proposed principles on technical standards (security, governance, compliance), audit methods (third-party, self-certification), and regulatory avenues (preference for voluntary certification over mandatory). Respondents endorsed alignment with industry best practices, risk-based approaches, and proportionality, with calls for technologically neutral standards and continuous monitoring mod
What You Need To Do
Monitor developments
Review internal practices
Enhance documentation
Engage stakeholders
Key Dates
2024- Working Group conducts analysis and drafts report on smart contract certification.
3 February 2025- Report published for public consultation.
14 March 2025- Industry responses submitted (e.g., GDF, Adan).
16 July 2025- Summary of consultation responses published by ACPR and AMF.
Compliance Impact
Urgency: Medium – This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
Thomas Hirschi has decided to leave the Swiss Financial Market Supervisory Authority FINMA effective 31 August 2025. The Head of the Banks division will pursue a new career outside FINMA. FINMA’s Board of Directors and Executive Board thank Thomas Hirschi for his valuable contribution during his time at FINMA.
Supervision Governance Sustainable Finance Journalists Investment management companies The AMF publishes a summary of its SPOT inspections on asset management companies' voting and engagement policies
MiCA Crypto-assets Innovation Implementation of MiCA: The AMF applies ESMA and EBA Guidelines on the assessment of the suitability of members of the management body
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen betreffend Guatemala (SR 946.231.137.6) publiziert.
AI Analysis
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Guatemala (SR 946.231.137.6), aligning Swiss sanctions with international developments targeting threats to democracy and rule of law in Guatemala. This matters for Swiss financial institutions as it mandates immediate screening and blocking of newly designated persons/entities to prevent sanctions violations, reinforcing Switzerland's commitment to international sanctions regimes amid ongoing geopolitical tensions in Central America. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/
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What Changed
Amendment to Annex 2 of SR 946.231.137.6, likely adding or updating designations of individuals, groups, or entities involved in undermining Guatemala's democracy, rule of law, or election integrity, consistent with parallel EU actions.
Measures include asset freezes (prohibiting Swiss persons from dealing with designated assets) and transaction prohibitions, with independent freezing by FINMA where required under Swiss law.
Updates are published in the Federal Gazette and integrated into FINMA'
What You Need To Do
Immediate screening
Enhanced due diligence
System updates
Key Dates
26 June 2025- Publication of annex amendment by WBF; immediate effectiveness for screening and blocking obligations.
Ongoing (continuous)- Annex updates published in Federal Gazette; firms must integrate changes without specified delay.DEADLINE
15 December 2025- Reference date for related FINMA sanctions annex maintenance (not specific to this update but indicative of cycle). https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/ https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/
Compliance Impact
Urgency: High - Swiss sanctions take effect immediately upon publication, exposing non-compliant firms to FINMA enforcement (fines up to CHF 1M, reputational damage). This aligns with rising geopolitical risks flagged in FINMA Risk Monitor 2025, where sanctions evasion amid corruption flows could tr
At its meeting on 25 June 2025, the Federal Council was informed of the resignation of Rene W. Keller from the Board of Directors of the Swiss Financial Market Supervisory Authority FINMA.
Asset management Collective investments Savings protection Crowdfunding: the AMF urges investors to exercise extreme caution due to the risks of project owner default or crowdfunding platform failure
Supervision Professional certification Asset management Journalists Investment management companies The AMF publishes the findings of its inspections on the verification and assessment of employee knowledge within asset management companies
Annual report Savings protection Marketing Retail investors Journalists The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment has published its 2024 Annual Report
MiCA Crypto-assets Crypto-assets: the AMF clarifies its policy on DASPs authorised under the PACTE Law to take account of the transitional period and facilitate the transition to MiCA
Financial disclosures & corporate financing Journalists Listed companies and issuers The AMF orders DANAE GROUP to file a draft takeover bid for ENTREPRENDRE shares
AI Analysis
The AMF has ordered Danae Group to file a draft takeover bid for shares in Entreprendre, enforcing mandatory public offer rules triggered by a shareholding threshold crossing. This matters for compliance professionals as it exemplifies AMF's strict oversight of takeover regulations, ensuring market integrity, equal treatment of shareholders, and timely disclosures in listed company transactions. It underscores the risks of non-compliance, potentially leading to enforcement actions.
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What Changed
No new regulatory changes are introduced; this is an enforcement decision applying existing AMF rules on mandatory takeover bids under the General Regulation (RGAMF), particularly Articles 234-2 et seq. Key requirements include: filing a draft offer with the AMF for compliance review within 10 trading days; mandatory cash offers at the highest price paid by the offeror (alone or in concert) in the prior 12 months; adherence to principles of free play of bids, equal treatment, transparency, marke
What You Need To Do
File draft takeover bid immediately
Appoint independent appraiser
Inform AMF and publish
Prepare target response
Monitor thresholds
Key Dates
Within 4-6 weeks of triggering event- Danae Group must file draft takeover bid (practice standard; exact trigger date not specified in publication).DEADLINE
10 trading days from offer period start- AMF reviews draft for compliance and issues visa (extendable if appraiser or works council involved, min. 5 trading days post-target reply).DEADLINE
Pre-offer period (post-announcement)- Strict trading rules apply; offeror may acquire shares until opening, with restrictions.
Offer period- From AMF filing notice to results publication; minimum success threshold 50% (waivable by AMF).
Compliance Impact
Urgency: High - Immediate filing obligation for Danae Group risks escalation to sanctions if ignored; for others, it signals AMF's proactive enforcement, heightening scrutiny on share acquisitions in listed firms. Matters due to potential market disruption, shareholder protection mandates, and prece
Governance Journalists Listed companies and issuers Women on Boards Directive: the AMF is now the competent authority for analysing and monitoring gender balance among the directors of listed companies
Asset management MMF The AMF applies ESMA's guidelines on updating stress scenario parameters, in accordance with Article 28 of the Money Market Funds Regulation
Warning Savings protection Warning Crypto-assets Crypto-assets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Cooperation Europe & international The AMF applies the joint guidelines issued by the European Supervisory Authorities to facilitate the exchange of information between National Competent Authorities
Marketing Investment advice The AMF reminds financial investment advisors of their professional obligations when using financial product listing platforms
Anti-money Laundering Asset management Crypto-assets Anti-money laundering and countering the financing of terrorism: the AMF applies the guidelines of the European Banking Authority on restrictive measures for crypto-asset service providers
Warning Savings protection Warning Forex and binary options Crypto-assets The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Market infrastructures Innovation Europe & international Cooperation Other professionals Market Infrastructures Journalists Investment management companies The French and Italian authorities make proposals for a more competitive...
AI Analysis
The French (AMF) and Italian (Consob) financial authorities have jointly proposed amendments to the EU's DLT Pilot Regime to increase its competitiveness and attract market participants. The Pilot Regime, which became operational in March 2023, has underperformed with only three authorized infrastructures and minimal live trading activity, prompting regulators to recommend structural changes including greater proportionality, expanded eligible instruments, and raised activity thresholds.
What Changed
The proposed amendments address the Pilot Regime's limited uptake by introducing the following regulatory modifications:
*Scope Expansion
Expand eligible financial instruments from current restrictions to all financial assets**
Remove categorical limitations that previously restricted participation
*Activity Thresholds
Raise activity thresholds from €6 billion to €100 billion
Introduce greater proportionality based on project scale**, allowing smaller players simplified requirements
*Operatio
What You Need To Do
*For Market Infrastructure Operators
*Reassess Business Cases
*Prepare Applications
*Monitor Commission Decisions
*Compliance Documentation
Key Dates
March 24, 2026- ESMA report deadline to European Commission on Pilot Regime functioning and recommendationsDEADLINE
June 30, 2026- End of MiCA transitional period; full crypto-asset regime implementation
Q2 2026- Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
April 9, 2025- AMF and Consob formal proposals submitted
Mid-2022- Original DLT Pilot Regime legislation enacted
Employee savings scheme Retail investors Journalists Employee savings: employees and firms are genuinely satisfied, but there is still a great need for support and education
Supervision Asset management Collective investments UCIT Other professionals Journalists Investment services providers Investment management companies The AMF publishes the findings of its thematic inspections of asset management...
Asset management The Autorité des Marchés Financiers (AMF) has published an analysis of the performance of the French real estate crowdfunding market, based on data collected from the 10 largest platforms in terms of inflows.
Crypto-assets Innovation The ACPR and the AMF publish the findings from the Working Group on Smart Contract Certification, and launch a Public Consultation
AI Analysis
The ACPR and AMF have published findings from their 2024 Working Group on Smart Contract Certification in DeFi, launching a public consultation on February 3, 2025, to explore certification frameworks for smart contracts, focusing on standards, audits, and regulatory options. This matters as it signals proactive French regulatory preparation for potential EU-level DeFi rules under MiCA, aiming to enhance security, governance, and compliance without immediate mandates, while industry feedback favors voluntary schemes.
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What Changed
No binding regulatory changes yet; this is exploratory work anticipating future regulation. The report proposes:
Standards for security, governance, and compliance across execution environments.
Audit frameworks including public authority, third-party auditors, or self-certification.
Regulatory avenues from voluntary certification to obligations, with proportionate approaches.
Consultation responses (summarized post-March 2025) confirmed support for technical standards and audits but preferred v
What You Need To Do
Participate/Review
Assess Smart Contracts
Monitor Developments
Engage Stakeholders
Key Dates
February 3, 2025- Working Group report published and public consultation launched.
March 10, 2025- Public consultation closed (per some reports; responses summarized afterward).
July 16, 2025- ACPR/AMF published summary of consultation responses.
2025 (TBD)- Conclusions from consultation responses to be presented.
July 2026- DASP regime fully phased out under MiCA transitional period.
Compliance Impact
Urgency: Medium. This is non-binding exploratory work with consultation closed, but it foreshadows potential mandatory smart contract certification in DeFi, aligning with MiCA's risk mitigation goals. Firms face low short-term risk but high long-term impact if voluntary standards evolve into obligat
Warning Savings protection Warning Forex and binary options Crypto-assets The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Warning Forex and binary options The AMF warns the public about the fraudulent Forex investment offering on the LIVAXXEN trading platform
Warning Savings protection Crypto-assets Warning Cryptoassets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Asset management Marketing Innovation Other professionals Professional investors Journalists Investment management companies Listed companies and issuers The AMF awards its 2024 prize for young researchers in economics to Maxime...
Savings protection Financial Scams Crypto-assets Retail investors Journalists The authorities are taking action to combat the massive phenomenon of financial scams catching out an increasing number of individuals
Asset management Anti-money Laundering Crypto-assets Combating money laundering and terrorist financing: the AMF applies the guidelines issued by the European Banking Authority regarding certain transfers of crypto-assets
Financial disclosures & corporate financing Periodic & ongoing disclosures Regulatory developments The Listing Act is entering into force on December 4, 2024
Cooperation Markets Executive & other private individuals Professional investors Journalists Investment services providers Investment management companies Listed companies and issuers The AMF and the AMMC are strengthening their...
Asset management Marketing The Autorité des Marchés Financiers (AMF) has published a recommendation governing the distribution of actively managed certificates (AMCs) to retail clients
Warning Savings protection Warning Forex and binary options Crypto-assets The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several entities proposing atypical investments without being authorised to do so
Warning Savings protection Warning Crypto-assets Cryptoassets: the Autorité des Marchés Financiers warns the public about the activities of several unauthorized entities
Asset management The Autorité des Marchés Financiers (AMF) announces withdrawal of the authorisation of the portfolio asset management company Wide Asset Management as of 8 July 2024
Asset management Notification forms for the cross-border exercise of the activities of passemanagement companies, and the marketing of UCITS and AIFs: the AMF updates its doctrine
Sustainable Finance Asset management Other professionals Journalists Investment management companies The Autorité des Marchés Financiers (AMF) publishes the findings of three supervisory initiatives on sustainable finance
Crypto-assets Innovation The AMF publishes the summary of responses received to its Discussion Paper on Decentralised Finance
AI Analysis
The Autorité des Marchés Financiers (AMF) has published a summary of stakeholder responses to its June 2023 Discussion Paper on Decentralised Finance (DeFi), analyzing regulatory challenges posed by automated, decentralized crypto-asset activities. This matters for compliance professionals as it signals the AMF's ongoing commitment to developing a balanced DeFi framework amid MiCA's implementation, potentially shaping future supervision of decentralized protocols while emphasizing investor protection and innovation.
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What Changed
No immediate regulatory changes or new requirements are introduced; this is a non-binding summary of consultation feedback from July 2024, intended to inform future discussions rather than enact rules. It highlights stakeholder views on DeFi's challenges, such as decentralization's impact on traditional oversight, with the AMF planning continued ecosystem engagement to outline proportionate responses. Related updates include clarifications on DASP transitions to MiCA CASP licensing (e.g., abolit
What You Need To Do
Monitor and engage
MiCA compliance
Assess decentralization
Update policies
Key Dates
June 2023- AMF publishes initial Discussion Paper on DeFi regulatory challenges.
July 2024- AMF publishes summary of responses to DeFi Discussion Paper.
December 30, 2024- MiCA enters force for CASPs.
June 30, 2026- End of MiCA transitional period for DASPs; full CASP licensing required.DEADLINE
July 2027- EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence.DEADLINE
Compliance Impact
Urgency: Medium - This consultation summary does not impose new obligations but underscores evolving DeFi scrutiny within MiCA's firm deadlines (e.g., June 2026 transition end), making it critical for crypto firms to align now to avoid sanctions like DASP withdrawals. It matters for maintaining comp
Warning Savings protection Forex and binary options Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Artificial intelligence Innovation Financial products Financial services providers Artificial intelligence: the AMF encourages market stakeholders to take part in two European Commission initiatives on issues specific to the financial sector
Supervision Asset management Journalists Investment management companies The AMF has published a summary of its SPOT inspections of financial management delegation arrangements at asset management companies
Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee has issued multiple enforcement decisions against financial investment advisors and their management for breaches of professional obligations, with the most recent and significant case involving Carat GP and its directors receiving combined fines of €2.5 million and permanent/extended bans from operating as financial investment advisors. These cases establish critical precedent regarding advisor duties around client disclosure, product authorization, conflict of interest management, and honest/fair conduct—requirements that apply across the entire financial investment advisory sector.
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What Changed
The enforcement decisions clarify and reinforce several core professional obligations for financial investment advisors:
*Transparency and Disclosure Obligations**
Financial investment advisors must inform clients of any remuneration received for their advice and justify improvements to advisory services in return for compensation received. Advisors cannot recommend financial products without first ensuring their marketing is authorized in the relevant jurisdiction.
*Competence and Care Standa
What You Need To Do
*Immediate Compliance Review
*Governance and Documentation
*Training and Culture
*Regulatory Engagement
Key Dates
19 December 2023- AMF Enforcement Committee decision against Séquence 13 and Jean-Louis Lehmann (€15,000 fines each; 5-year ban)
11 April 2022- AMF Enforcement Committee decision against DCT and Didier Maurin (€150,000 and €200,000 fines; 5-year ban)
9 September 2024- Conseil d'Etat judgment dismissing appeal by DCT and Didier Maurin
24 October 2022- AMF Enforcement Committee decision against Salzillo Finance and Jean Salzillo (€20,000 and €80,000 fines; 3-year ban)
2 July 2019- AMF Enforcement Committee decision against Invest Securities and financial advisors (€90,000 to €60,000 fines)
Sustainable Finance Governance Financing the economy Other professionals Journalists Investment management companies Listed companies and issuers The AMF and the ACPR have published their report on the monitoring and assessment of the climate...
Annual report Savings protection Marketing Retail investors Journalists The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment has published its 2023 Annual Report
Warning Savings protection Crypto-assets Warning Cryptoassets: the Autorité des Marchés Financiers warns the public about the activities of several fraudulent market participants and publishes a new ‘blacklist’
Asset management MMF AMF complies with ESMA guidelines on updating the stress scenario parameters provided for in Article 28 of the Money Market Funds Regulation for 2024
Appointment AMF activity Retail investors Journalists France Mayer appointed Retail Investor Relations and Protection Director at the Autorité des Marchés Financiers
Financial disclosures & corporate financing Equity Journalists Listed companies and issuers Amendment to the AMF General Regulation makes "retail" tranche optional for initial public offerings
Professional certification AMF activity Journalists The Autorité des Marchés Financiers announces the new composition of the Financial Skills Certification Board
Warning Savings protection Forex and binary options Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Warning Miscellaneous assets The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Appointment Sanctions & settlements Journalists Valérie Michel-Amsellem becomes Chair of the AMF Enforcement Committee
AI Analysis
This AMF publication announces the appointment of Valérie Michel-Amsellem as the new Chair of the AMF Enforcement Committee, the independent body responsible for imposing sanctions in financial market violations. It matters for compliance professionals because leadership changes in enforcement can signal shifts in sanctioning priorities, rigor, or focus areas, potentially influencing how firms approach risk management and remediation. While no immediate policy changes are introduced, monitoring the new Chair's tenure is essential given the Committee's role in upholding market integrity.
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What Changed
There are no substantive regulatory changes, new requirements, or amendments to the AMF General Regulation outlined in this announcement. The publication solely details an internal governance appointment within the AMF's structure, where the Enforcement Committee maintains its established autonomy for sanction decisions, separate from the AMF Board. This aligns with prior affirmations of the Committee's independence, as upheld in ECHR rulings on its impartiality.
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What You Need To Do
Review backgrounds of key AMF personnel, including Valérie Michel-Amsellem, for insights into enforcement trends (e
Enhance internal monitoring of AMF sanction releases (https://www
Conduct gap analyses on compliance programs for high-risk areas like market abuse, given the Committee's sanction powers up to €100 million or 10x profits
Key Dates
Immediate- Appointment takes effect upon announcement, with no disclosed transition period.
2026, Enforcement Committee sanction against an asset management company, indicating ongoing enforcement operations.
Compliance Impact
Urgency: Low - This personnel change does not impose new obligations or alter existing rules, posing minimal immediate risk. It matters indirectly for long-term strategy, as the Chair could steer enforcement toward stricter penalties or novel interpretations of obligations (e.g., as analyzed in hist
Asset management Anti-money Laundering Combatting money laundering and terrorist financing: AMF applies two sets of European Banking Authority guidelines
Innovation Savings protection AMF activity Open Data: publication on data.gouv.fr of the list of Asset Management Companies (AMCs) authorized by the AMF, of the white lists of Digital Asset Service Providers (DASPs) and offers of investments in miscellaneous assets
Supervision Marketing MIFID Journalists Investment services providers Investment management companies AMF calls on investment services providers to take account of the specific nature of temporary ownership dismemberment when marketing SCPI units
Appointment Sanctions & settlements Journalists Appointements to the AMF Enforcement Committee
AI Analysis
This AMF publication announces the partial renewal of the Enforcement Committee, including four new appointments, two reappointments, and the subsequent election of Valérie Michel-Amsellem as Chair on 28 February 2024. It matters for compliance professionals as changes in committee composition can influence enforcement priorities, sanction severity, and interpretations of financial regulations under AMF jurisdiction.
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What Changed
There are no new regulatory requirements or substantive changes to laws; this is an administrative renewal of the Enforcement Committee's membership. Key developments include: new members Jean-Claude Hassan (Vice-President of the Council of State appointee, also chairs second section), Xavier Samuel (Court of Cassation appointee), Sophie Langlois and Aurélien Soustre (Ministerial appointees); reappointments of Anne Le Lorier and Ute Meyenberg. The committee maintains its structure of 12 independ
Key Dates
13 February 2024- Ministerial order appointing new and reappointed members.
20 February 2024- Publication of the ministerial order.
27 February 2024- Composition published in the Official Journal.
28 February 2024- First meeting; election of Valérie Michel-Amsellem as Chair and Jean-Claude Hassan as second section Chair.
Compliance Impact
Urgency: low - This personnel change poses minimal immediate risk but signals potential evolution in enforcement tone under new leadership experienced in sanctions and regulation (e.g., Michel-Amsellem's appellate background). It matters longer-term for firms in protracted AMF proceedings, as commit
Warning Savings protection Financial Scams Warning The AMF warns the public about fraudulent press advertisements proposing investments in car parks with electric charging points
Asset management Entry into force of the revised European Long-Term Investment Fund Regulation (ELTIF 2) - AMF clarifies fund authorisation requirements
Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
AI Analysis
The AMF Enforcement Committee imposed sanctions on SPI (a financial investment advisor) and its director Vincent Rhodes on 9 January 2024 for breaching professional obligations. This case demonstrates the AMF's enforcement priorities regarding advisor conduct standards and establishes precedent for disciplinary action against both firms and individual managers who fail to meet regulatory requirements.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement of existing professional obligations for financial investment advisors. The case reinforces that advisors must:
Comply with all applicable laws and regulations governing financial investment advisory activities
Maintain professional standards in their dealings with clients and regulators
Ensure their directors and managers operate within regulatory boundaries
The enforcement action reflects the AMF's i
What You Need To Do
*For Financial Investment Advisors
*Review compliance frameworks - Audit existing policies and procedures against the professional obligations that triggered this enforcement action
*Enhance governance controls - Implement systems to ensure directors and senior management comply with regulatory requirements
*Document compliance - Maintain records demonstrating adherence to professional conduct standards
*Staff training - Ensure all personnel understand the scope of professional obligations and consequences of breach
Key Dates
9 January 2024- AMF Enforcement Committee decision imposing sanctions on SPI and Vincent Rhodes
Immediate effect- 2-year temporary ban on both respondents from exercising financial investment advisor activities commenced following the decision
Warning Savings protection Forex and binary options Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Sanctions & settlements professional obligations Investment advice Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations
AI Analysis
The AMF Enforcement Committee imposed a five-year ban on financial investment advisor DCT (formerly Didier Maurin Finance) and its director Didier Maurin from practicing, plus fines of €150,000 on the firm and €200,000 on the director, for recommending unauthorized Samoan AIF investments to 64 clients, failing to manage conflicts of interest (e.g., no conflicts register), and breaching duties of competence, care, and diligence in clients' best interests. This matters as it reinforces AMF's strict enforcement on CIFs (Conseillers en Investissements Financiers) for product authorization checks, conflicts management, and client-centric obligations under MiFID II transposition in France, signaling heightened scrutiny on advisory integrity amid rising sanctions. The Conseil d'Etat upheld the decision on 9 September 2024, dismissing appeals and confirming sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing requirements for CIFs:
Product marketing authorization: CIFs must verify that recommended investments (e.g., AIFs) are authorized for sale in France before advising clients; recommending unauthorized products breaches professional obligations regardless of client outcomes.
Conflicts of interest management: CIFs must maintain an effective conflicts register, identify risks (e.g., personal benefits), an
What You Need To Do
Immediate audit
Conflicts policy enhancement
Training and documentation
Director accountability
Key Dates
11 April 2022- AMF Enforcement Committee decision imposing bans and fines.
9 September 2024- Conseil d'Etat judgment (no. 464877) dismissing appeals, upholding sanctions, and ordering €1,500 costs each to AMF.
Compliance Impact
Urgency: High - This upheld decision (post-2024 appeal) exemplifies AMF's pattern of escalating fines/bans on CIFs for conduct failures (e.g., €2.5M on Carat GP in 2025; €120K-€150K on Capexis upheld 2025), amid 2024-2025 enforcement wave on professional obligations. Matters for CIFs as it heightens
Asset management UCIT Collective investments The AMF updates its policy on disclosures by collective investment schemes incorporating non-financial methods
Sanctions & settlements Journalists The AMF Enforcement Committee fines a French tied agent of a Cypriot investment services provider and its manager for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined France Safe Media (FSM), a French tied agent of Cypriot provider VPR Safe Financial Group Limited (Alvexo platform), €300,000 and imposed a 10-year ban from tied agent activities and reception/transmission of orders (RTO) services, while its manager Lior Mattouk received a €100,000 fine and similar 10-year ban, for breaches occurring January 2019–September 2021. This decision, dated 10 November 2023 and upheld by Conseil d'Etat on 16 June 2025, underscores AMF's strict enforcement of professional obligations for tied agents marketing high-risk CFDs, emphasizing staff qualifications, client assessments, risk warnings, disclosures, and diligence. It matters for cross-border intermediaries as it highlights personal liability for managers and the finality of sanctions post-appeal, signaling heightened scrutiny on CFD promotion and tied agent compliance in France.
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What Changed
This is an enforcement action, not a new regulation, but it clarifies and reinforces existing requirements under French rules implementing MiFID II for tied agents:
Staff qualifications: Tied agents must verify sales staff have minimum qualifications and knowledge; post-hoc inadequate tests do not suffice.
Client knowledge/experience assessment: Questionnaires must be robust, with appropriate scoring; account managers cannot interfere (e.g., by prompting answer changes).
Promotional communicatio
What You Need To Do
Conduct gap analysis
Enhance manager oversight
Audit CFD marketing
Training programs
Cross-border review
Key Dates
10 November 2023- AMF Enforcement Committee decision SAN-2023-15 imposing fines and bans.
14 November 2023- French version of press release published.
16 June 2025- Conseil d'Etat judgment (n° 490826) dismissing appeals by FSM and Mattouk, confirming sanctions and ordering €4,000 costs to AMF.
Compliance Impact
Urgency: High – Though dated (2019–2021 breaches), the 2025 appeal dismissal makes sanctions final, serving as a binding precedent for tied agents amid AMF's ongoing CFD enforcement wave (e.g., parallel fines on providers like CIC banks). It elevates personal risk for managers and signals intensifie
Long term investment Equity Journalists Investment services providers Investment management companies Listed companies and issuers An OECD study for the AMF profiles new French retail investors
Cooperation Fintech Market Infrastructures Post-trade Infrastructures Professional investors Journalists Investment services providers Investment management companies Listed companies and issuers The AMF and the US...
Fees Savings protection Other professionals Retail investors Journalists Investment services providers The AMF ensures that retail investors are properly informed on fees of financial products
Warning Warning Savings protection Miscellaneous assets The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Warning Warning Savings protection Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Innovation Markets Decentralised Finance (DeFi): IOSCO publishes its consultation report
AI Analysis
The AMF publication announces IOSCO's consultation report on Decentralised Finance (DeFi), highlighting ongoing global efforts to regulate DeFi activities under IOSCO's 2023 policy recommendations. This matters for compliance professionals as it signals intensifying scrutiny on DeFi platforms for investor protection, market integrity, and financial stability risks, potentially leading to harmonized rules that bridge traditional finance and crypto assets. Firms involved in DeFi must monitor this to align with emerging "same risk, same rule" standards across jurisdictions.
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What Changed
No immediate binding regulatory changes are introduced, as this is a consultation report tied to IOSCO's 2023 DeFi Recommendations and a 2025 Thematic Review assessing implementation progress. Key focuses include enhanced regulatory cooperation (Recommendation 11), addressing gaps in enforcement for Crypto Asset Service Providers (CASPs), and applying CDA Policy Recommendations to DeFi for risks like financial stability, investor protection, and market integrity. Progress is noted in legal frame
What You Need To Do
Review and comment
Gap analysis
Enhance compliance
Monitor cross-border
Pilot participation
Key Dates
31 July 2025- Cut-off date for assessing Participating Jurisdictions' regulatory frameworks in IOSCO's Thematic Review.
October 16, 2025- Publication date of FSB and IOSCO reports assessing crypto-asset and stablecoin implementation, including DeFi elements.
2 February 2026- IOSCO consultation comment deadline on related reports (e.g., FMIs’ management of general business risks).DEADLINE
6 February 2026- CPMI-IOSCO consultation comment deadline on FMIs’ general business risks guidance, relevant to DeFi infrastructure.DEADLINE
starting 2026.
Compliance Impact
Urgency: High – While not yet binding, the report underscores incomplete global implementation (e.g., enforcement gaps, regulatory arbitrage risks), with IOSCO/FSB calling for swift action amid 2025-2026 reviews. This matters as DeFi's growth amplifies systemic risks, prompting "same risk, same rule
Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny.
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What Changed
This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activ
What You Need To Do
Immediate gap analysis
Enhance AML/CFT
Conflicts framework
Senior manager attestation
Marketing/retrocessions
Key Dates
31 December 2025- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors.
August 2019 - December 2023- Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures.
08 January 2026- Public press release date.
Compliance Impact
Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplify
Sanctions & settlements professional obligations Journalists The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined the Association Nationale des Conseillers Financiers-CIF (ANACOFI-CIF), a professional association approved for investment advisors (CIFs), €250,000 with a warning, and its former president €20,000 with a warning, for breaching professional obligations in membership vetting, controls, archiving, and conflicts of interest management. This decision, dated September 5, 2023, underscores AMF's scrutiny of professional associations' gatekeeping and oversight roles in ensuring CIF compliance. It matters as it signals heightened enforcement against associations failing to uphold regulatory standards, potentially impacting CIF ecosystem integrity and prompting reviews of similar bodies.
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What Changed
This is an enforcement action, not a new regulation, but it reinforces existing obligations under French Monetary and Financial Code (CMF) for approved professional associations like ANACOFI-CIF. Key breaches highlighted include:
Failure to verify quality of CIF membership application dossiers and non-compliance with internal adhesion procedures.
Non-respect of procedures for member controls, sanctions, and proper archiving of control dossiers.
Violation of internal rules on conflicts of interes
What You Need To Do
Review and strengthen internal procedures for CIF membership vetting, ensuring dossier quality checks align with approved protocols
Implement robust systems for member controls, sanctions processes, and secure archiving of all dossiers per CMF L
Update conflicts of interest policies and registers to fully comply with internal rules and CMF obligations, documenting all identifications
Conduct gap analyses on governance, documentation, and AML/KYC for CIF activities, training staff on operationalizing procedures
For CIF members
Key Dates
September 5, 2023- AMF Sanctions Commission decision issued, imposing fines and warnings on ANACOFI-CIF (€250,000) and M. Patrick Galtier (€20,000).
Post-September 5, 2023- Decision subject to potential recourse (appeal period not specified in public summaries, typically 1 month under AMF procedures).
June 2, 2023- AMF Sanctions Commission hearing where €500,000 sanction was initially sought (reduced in final decision).
Compliance Impact
Urgency: Medium - This 2023 decision is not imminent but remains highly relevant given ongoing AMF focus on CIF compliance (e.g., 2025 sanctions for similar breaches like archiving and AML failures). It matters for preventing fines, bans, or reputational damage, as AMF targets systemic weaknesses in
Savings protection Cooperation Crypto-assets Retail investors Fintech Journalists The AMF and the ARPP launch the Responsible Influence Certificate in Finance
MiCA Crypto-assets Regulatory developments Digital assets: the AMF amends its General Regulation and its policy on DASP in light of enhanced registration and the MiCA Regulation
Asset management The Autorité des Marchés Financiers (AMF) announces withdrawal of the authorisation of the portfolio asset management company Quantology Capital Management as of 30 June 2023
Collective investments Asset management The AMF updates its policy on the information to be provided by collective investment schemes incorporating non-financial approaches
Crypto-assets Innovation Market infrastructures Post-trading infrastructures Market infrastuctures on blockchain technology: adaptation of the French securities laws
Warning Warning Savings protection Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Warning Savings protection Miscellaneous assets The AMF warns the public against companies proposing atypical investments without being authorised to do so
Annual report Savings protection Marketing Financial products Retail investors Journalists The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment publishes its 2022 annual report
Warning Warning Savings protection Forex and binary options Crypto-assets The AMF warns the public about the fraudulent investment offers in Forex and crypto-assets by Immediate Connect
Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)
AI Analysis
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.
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What Changed
This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source cod
What You Need To Do
Submit feedback (past deadline)
Monitor developments
Conduct internal assessments
Enhance compliance programs
Engage stakeholders
Key Dates
June 19, 2023- AMF publishes initial discussion paper on DeFi regulatory issues.
September 30, 2023- Deadline for stakeholder contributions to the discussion paper.DEADLINE
July 10, 2024- AMF publishes summary of responses to the discussion paper.
Compliance Impact
Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity
Financial services providers Asset management Marketing European Crowdfunding Services Providers: the AMF publishes a position on marketing communications
Supervision Asset management Sustainable Finance Journalists Investment management companies The AMF publishes a summary on the internal processes that aim to ensure compliance with non-financial contractual commitments by asset management companies of ESG/SRI funds
Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000, and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025, for multiple breaches spanning August 2019 to December 2023, including unauthorized placement of financial instruments as a tied agent, non-operational investment allocation processes, inadequate compliance with investment procedures, deficient conflicts of interest management, and non-operational AML/CFT systems. This decision underscores AMF's strict enforcement of operational compliance and scope limitations for asset managers, serving as a critical reminder for firms to ensure robust, traceable systems and director accountability. It matters because it highlights personal liability for managers and recurring AMF focus on AML/CFT and procedural deficiencies, potentially signaling increased scrutiny in 2026.
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What Changed
This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset management companies (AMCs), particularly:
Strict limits on services: AMCs cannot provide placement of financial instruments without a firm commitment basis, even as tied agents; doing so circumvents authorized investment services.
Operational investment systems: Processes for allocating investments betwe
What You Need To Do
Audit dual roles
Enhance investment processes
Strengthen controls
Director oversight
Documentation
Key Dates
31 December 2025- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023- Period of breaches investigated.
Compliance Impact
Urgency: High - This recent (Dec 2025) decision aligns with a pattern of AMF fines on AMCs for AML/CFT, procedural, and operational failures (e.g., €200k on Eres Gestion in 2023 for rebates/investments; warnings/fines on Inter Gestion REIM in 2024 for AML). It matters due to director liability, esca
Sanctions & settlements Asset management Compliance Anti-money Laundering Executive & other private individuals Investment management companies The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their...
AI Analysis
The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000 and its managers Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for multiple breaches of professional obligations from August 2019 to December 2023, including unauthorized investment services as a tied agent, non-operational investment allocation processes, deficient conflict-of-interest management, and inadequate AML/CFT systems. This decision underscores AMF's strict enforcement against operational failures in asset management, particularly for firms balancing portfolio management with tied agent roles, emphasizing personal accountability for managers. Compliance teams must review this for gaps in procedures, as it highlights how imprecise processes and poor traceability lead to substantial sanctions.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociétés de gestion) are restricted to specific investment services; providing placement of financial instruments without firm commitment (as a tied agent) circumvents these limits and is prohibited.
Investment systems must be operational with precise allocation rules between funds;
What You Need To Do
Audit investment services scope to ensure no unauthorized placement activities, especially if acting as tied agents; cease and remediate any circumventions
Enhance investment allocation processes with precise rules, full traceability of verifications, and demonstrable operationality
Strengthen conflict-of-interest frameworks with identification, prevention, and management protocols, including documentation
Overhaul AML/CFT systems for effective due diligence on clients, assets, and risks; conduct staff training and test operationality
Review manager accountability
Key Dates
31 December 2025- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier.
August 2019 - December 2023- Period of breaches investigated, covering unauthorized services, investment process failures, conflicts, and AML/CFT deficiencies.
31 December 2025(exact deadline unspecified; standard AMF appeals must be lodged promptly, typically within 1 month).DEADLINE
Savings protection Equity Savings Plan Shares Long term investment Retail investors Journalists Investment services providers Listed companies and issuers Equity savings plans : the AMF working group proposes avenues for...
Supervision MIFID Financial services providers Other professionals Journalists Investment services providers Provision of market data: the AMF conducts a series of SPOT inspections and identifies shortcomings in compliance with requirements
Asset management The Autorité des Marchés Financiers (AMF) has withdrawn the authorisation of the portfolio asset management company Quantology Capital Management
Financial disclosures & corporate financing The AMF makes available to listed companies the English version of its recommendations and the results of its examination work of the financial statements
Warning Warning Savings protection Forex and binary options The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Sustainable Finance Asset management Sustainable Finance Disclosure Regulation: the AMF publishes a study on classifications and fossil fuel exposure in the French funds universe
MIFID Supervision Retail investors Journalists Mystery shopping campaign to bank branches: progress made in the questioning to client, improvements needed in the information provided
Innovation Market infrastructures Post-trading infrastructures Market infrastructures on blockchain: Application of the EU DLT Pilot Regime from March 23rd
Asset management Anti-money Laundering Anti-money laundering and combating the financing of terrorism: the AMF applies the guidelines of the European Banking Authority
Sanctions & settlements professional obligations Investment advice Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined financial investment advisor Capexis €120,000 on 15 February 2023 for breaches including receiving prohibited payments from client loan repayments and failing to disclose commissions from SCPI usufruct subscriptions, with the Conseil d'Etat later increasing the fine to €150,000 on 3 March 2025. This enforcement action underscores AMF's strict oversight of **financial investment advisors (Conseillers en Investissements Financiers - CIFs)** on professional obligations like payment restrictions and transparency. It matters for compliance as it highlights personal liability risks and the educational role of such decisions in clarifying regulations.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces existing requirements under French financial regulations for CIFs:
Prohibition on non-remunerative payments: CIFs cannot receive payments beyond fees for advisory services, such as loan repayments from clients.
Commission disclosure: CIFs must inform clients of the nature, amount, or calculation method of any commissions received in connection with investment advice, e.g., from SCPI usufruct arrangements.
No aggravating fac
What You Need To Do
Review payment structures
Enhance disclosure policies
Conduct gap analysis
Training and monitoring
Prepare for inspections
Key Dates
15 February 2023- AMF Enforcement Committee decision imposing €120,000 fine on Capexis.
3 March 2025- Conseil d'Etat judgment increasing fine to €150,000, overturning some findings, and ordering publication on AMF website.
Compliance Impact
Urgency: High - This matters due to escalating fines (e.g., €120k to €150k on appeal), permanent/temporary bans in parallel cases, and director liability up to €2m. Recent 2024-2025 enforcements signal AMF's intensified focus on CIF misconduct amid fund scandals, risking reputational damage and oper
Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Warning Savings protection Forex and binary options Crypto-assets Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Innovation The AMF publishes its proposals for an open finance framework
AI Analysis
The Autorité des Marchés Financiers (AMF), France's financial markets authority, has published proposals for an **open finance framework** via a public consultation, extending open banking principles to broader financial data sharing for enhanced innovation and competition. This matters for compliance professionals as it signals upcoming regulatory requirements for secure data access, APIs, and customer consent mechanisms, aligning with EU trends toward open finance while prioritizing consumer protection and market resilience. Firms must engage early to shape the final rules and prepare systems for compliance.
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What Changed
The publication outlines AMF's proposals for an open finance framework, building on open banking (e.g., PSD2) to include investments, insurance, and asset management data. Key elements include:
Mandatory API-based data sharing for account information and payment initiation, extended to non-banking products like securities and insurance.
Enhanced customer consent and control mechanisms, with granular permissions, revocation rights, and strong authentication.
Security and liability standards align
What You Need To Do
Review and respond to consultation
Conduct gap analysis
Update policies
Engage stakeholders
Test systems
Key Dates
January 14, 2026- AMF publishes 2026 priorities, including open finance as part of innovation framework.
TBD (consultation period)- Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication).DEADLINE
June 30, 2026- End of MiCA transitional period, relevant for crypto/open finance intersections.
2026 (H2)- Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs.
likely 2027implementation phased over 12-24 months.
Compliance Impact
Urgency: High – As a consultation, immediate engagement is critical to shape rules, but full implementation may not hit until 2027+. It matters due to alignment with AMF's 2026 priorities on innovation (AI, tokenization, MiCA) and resilience (DORA, cybersecurity), risking fines or supervisory action
Long term investment Shares Collective investments Retail investors Journalists The AMF’s latest savings barometer finds that the French are a little less inclined to invest in the stock market
Markets Financial disclosures & corporate financing The Autorité des marchés financiers (AMF) has requested the resumption of listing of ORPEA’s securities today
Supervision UCIT Asset management Journalists Investment management companies The AMF calls on investment fund depositaries to strengthen their arrangements for the onboarding and monitoring of asset management companies
Warning Miscellaneous assets Savings protection Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
AMF activity AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani
AI Analysis
This AMF publication announces a proposal to appoint Marie-Anne Barbat-Layani as Chair of the AMF, France's financial markets authority responsible for investor protection, market supervision, and regulatory enforcement. It matters for compliance professionals because leadership changes at key regulators like the AMF can signal shifts in enforcement priorities, supervisory focus, or policy directions affecting investment firms, asset managers, and market participants across the EU. While not imposing immediate rules, it warrants monitoring for potential impacts on ongoing consultations and governance expectations.
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What Changed
No specific regulatory changes or new requirements are outlined in this publication, as it solely concerns a leadership appointment proposal rather than substantive rule amendments. The AMF's standard process for such proposals involves board review and government ratification, but no alterations to the General Regulation, policies, or compliance obligations are proposed here.
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What You Need To Do
binding appointment proposal without compliance obligations
Monitor AMF website (https
Review existing AMF relationships and prepare for potential shifts in supervisory engagement
Urgency: Low – This is a procedural leadership announcement with no immediate regulatory or operational impacts. It matters for long-term strategic planning, as the new Chair could influence AMF's approach to MiFID II implementation, sustainability integration, or enforcement, but firms face no urge
Warning Savings protection Forex and binary options Crypto-assets Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Crypto-assets Anti-money Laundering Supervision Journalists Investment services providers AMF and ACPR announce the withdrawal of BYKEPS SAS’s registration as a DASP
Equity Savings Plan Long term investment Savings protection Retail investors Journalists The AMF creates a working group on equity savings plans (PEAs)
Supervision Journalists Investment services providers The AMF publishes a summary of its SPOT inspections on simple, transparent and standardised securitisation
MIFID Sustainable Finance Asset management Sustainability requirements in the distribution of financial instruments: update on upcoming legislation and its implementation dates
Investment services Savings protection Europe & international Retail investors Investment services providers The AMF informs the public of the partial suspension by the CySEC of VPR Safe Financial Group Limited’s authorisation to operate in France
AI Analysis
The AMF publication notifies the public of CySEC's August 3, 2022, decision to partially suspend VPR Safe Financial Group Limited's (operating as Alvexo) authorization to provide investment services in France, prompted by AMF findings of regulatory violations including misleading marketing, inadequate client suitability assessments, and poor tied agent oversight. This cross-border enforcement highlights escalating EU supervisory cooperation under MiFID II, serving as a warning for firms using tied agents in France. It matters for compliance as it underscores risks of AMF referrals leading to home-state suspensions, with subsequent developments including suspension revocation and full license withdrawal by September 2025.
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What Changed
This is an enforcement action rather than new rules, imposing specific prohibitions on VPR Safe Financial Group Limited in France:
Ban on accepting new French clients or entering business relationships with them.
Prohibition on advertising or marketing investment services to current or potential French clients, directly or via tied agent France Safe Media.
Restriction on receiving new deposits from existing French clients, except to cover initial margins for open positions upon explicit client r
What You Need To Do
For VPR/Alvexo (during suspension)
Ongoing for similar firms
Client protection
Key Dates
August 3, 2022- CySEC issues partial suspension decision based on AMF findings, effective immediately for French operations.
~October 4, 2022- Two-month deadline for VPR to remediate compliance issues (from suspension date).DEADLINE
Post-August 22, 2022 (exact date unspecified)- CySEC revokes partial suspension after demonstrated compliance.DEADLINE
September 29, 2025- CySEC fully withdraws VPR's CIF authorization pursuant to the firm's renunciation.
October 13, 2025- CySEC publicly announces license withdrawal.
Compliance Impact
Urgency: Low (as of January 2026). The 2022 suspension is historical, resolved via revocation and superseded by full license withdrawal in 2025, posing no ongoing restrictions. It matters as a precedent for AMF-CySEC coordination on retail misconduct (e.g., CFD marketing, tied agents), urging firms
Market infrastructures Post-trading infrastructures EMIR Common procedures and methodologies on supervisory review and evaluation process of CCPs under Article 21 of EMIR: the AMF complies with ESMA guidelines
Asset management Savings protection Journalists The AMF is conducting a consultation on the end of life of private equity funds intended for retail investors
AI Analysis
The AMF is conducting a consultation on regulatory reforms governing the end-of-life management of retail private equity funds (FCPRs, FCPIs, and FIPs), with the objective of improving compliance with liquidation deadlines and enhancing investor protection through better information disclosure and operational safeguards. This initiative addresses systemic issues where fund managers have historically failed to respect contractual lifespan commitments, creating liquidity risks and investor communication failures.
What Changed
The AMF has amended its General Regulation and policy framework to implement several substantive requirements:
*Liquidation Compliance & Warnings**
A new Article 422-120-14-1 requires management companies to include a warning in promotional materials if, over the ten years preceding fund authorization, the company failed to respect the lifespan of at least 50% of retail or professional private equity funds under its management. This warning applies only when two materiality thresholds are met:
What You Need To Do
*For All Retail Private Equity Fund Managers
*Audit historical compliance with fund lifespan commitments over the preceding ten years to determine if warning requirements under Article 422-120-14-1 apply
*Implement bank details collection for all funds established after December 5, 2024, incorporating requirements into subscription forms per Instruction DOC-2011-22
*Establish prior notification procedures for substantial changes to fund structure, investment strategy, or operations, with one-month advance notice to the AMF
*Update Position-Recommendation DOC-2012-11 compliance to reflect the extended 15-year lock-up period for newly authorized funds
Key Dates
December 5, 2024- Effective date for new Article 422-120-16 (bank details collection requirement for newly established funds)
November 12, 2024- AMF decision approving amendments to General Regulation
December 5, 2024- Publication in Official Journal of the French Republic
June 13, 2024- Enactment of Attractiveness Law No. 2024-537 (establishing 15-year maximum lock-up period)
January 10, 2024- Revised ELTIF Regulation came into application
MiCA Crypto-assets Innovation Cooperation Europe & international Crypto-asset markets: Agreement reached on the European Crypto-Assets regulation (MiCA)
Sanctions & settlements Compliance Journalists Investment services providers The AMF Enforcement Committee fines a depositary for breaches of its professional obligations
AI Analysis
The AMF Enforcement Committee fined RBC Investor Services Bank France SA (RBC ISBF) €500,000 plus a warning on 20 July 2022 (published 08 January 2026) for breaches as a UCITS and AIF depositary, including 25 confirmed failures in tiered intervention procedures for investment ratio overruns and deficient monitoring of 14 questionable cash flows over 45 months. This decision underscores AMF's strict enforcement of depositary duties under French regulations implementing UCITS/AIFMD, emphasizing robust controls for ratio compliance, cash flow verification, and documentation. It matters for compliance teams as it provides precedent on what constitutes "irregular and deficient" oversight, potentially increasing scrutiny and fines for similar lapses in depositary functions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing depositary obligations under French UCITS/AIFMD rules (e.g., Articles L. 214-7 et seq. Monetary and Financial Code):
Ratio monitoring and intervention: Depositaries must implement tiered procedures for investment/asset composition ratio breaches (e.g., diversification limits); 25 of 28 alleged anomalies were upheld due to redundant but confirmed procedural failures.
Cash flow oversight: Must identify
What You Need To Do
Review depositary controls
Enhance cash flow monitoring
Conduct gap analysis
Update policies/procedures
Appeal if applicable
Key Dates
20 July 2022- AMF Enforcement Committee decision date imposing €500,000 fine and warning on RBC ISBF.
08 January 2026- Public news release/publication date of the decision.
Compliance Impact
Urgency: Medium – Recent publication (08 January 2026) signals ongoing AMF focus on depositary failings amid H2O-related probes, but stems from 2022 events with no immediate deadlines. Matters because it sets precedents for fine quantum (€500k) on procedural lapses, reinforces liability for cash/rat
Savings protection Cooperation Crypto-assets Fintech Journalists The AMF and the ARPP are stepping up their cooperation to promote clear and responsible advertising of financial products
Warning Savings protection Forex and binary options Crypto-assets Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Warning Savings protection Miscellaneous assets The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Institutional AMF activity Appointment Journalists Appointments to the Legal Affairs Directorate and Enforcement Assistance Directorate of the Autorité des Marchés Financiers
AI Analysis
This AMF publication announces internal appointments to its **Legal Affairs Directorate** and **Enforcement Assistance Directorate**, signaling potential enhancements in legal oversight and enforcement capabilities within France's financial markets regulator. Compliance professionals should note this as it may indicate a renewed focus on rigorous enforcement of market rules, though it imposes no direct regulatory changes on firms.
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What Changed
There are no regulatory changes, new requirements, or policy updates in this announcement. It solely details personnel appointments within AMF's internal structure, specifically leadership roles in directorates handling legal affairs (e.g., Maxence Delorme as head of Legal Affairs Directorate) and enforcement assistance (e.g., Amélie du Passage as head of Instruction and Enforcement Assistance Directorate). These directorates support AMF's core functions like investigations, inspections, and san
What You Need To Do
*No specific actions are required for regulated firms, as this does not introduce obligations
Review ongoing AMF interactions (e
Update internal AMF contact lists with confirmed governance details from https://www
Track AMF news releases for enforcement trends at https://www
Key Dates
13 February 2024- Ministerial order partially renewing AMF Enforcement Committee.
20 February 2024- Publication of Enforcement Committee appointments.
27 February 2024- Composition published in Official Journal.
16 October 2023- Appointment of Sébastien Raspiller as AMF Secretary General.
Compliance Impact
Urgency: Low. This matters peripherally for firms anticipating AMF enforcement, as new leaders in Legal Affairs and Enforcement Assistance could signal stricter scrutiny or faster processing of cases, similar to past leadership transitions (e.g., Secretary General appointment in 2023). However, abse
Annual report Savings protection Journalists Investment services providers Investment management companies Listed companies and issuers The ACPR and AMF Joint Unit for Insurance, Banking and Retail Investment publishes its 2021 annual report
Europe & international Sustainable Finance Asset management The AMF reiterates its call for a European regulation of ESG data, ratings, and related services
Sanctions & settlements Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined financial investment advisor Séquence 13 and its director Jean-Louis Lehmann €15,000 each and imposed a five-year ban from acting as financial investment advisors in its decision of 19 December 2023, due to failures in client disclosures, justifying remuneration, operating within regulatory limits, and managing conflicts of interest. This enforcement action underscores the AMF's strict enforcement of professional obligations for investment advisors, with personal liability for managers, serving as a deterrent against conduct breaches that harm client interests. Compliance teams should note this as part of a pattern of similar sanctions, emphasizing robust governance and documentation.
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What Changed
This is an enforcement decision, not a new regulation, but it reinforces core professional obligations under AMF rules for financial investment advisors (Conseillers en Investissements Financiers, CIFs), including:
Client information on remuneration: Advisors must disclose any remuneration received for advice and justify service improvements relative to that pay.
Regulatory scope compliance: Firms must operate strictly within authorized activities, avoiding unauthorized product recommendations.
What You Need To Do
Review and enhance policies
Training programs
Client file audits
Governance checks
Mock inspections
Key Dates
19 December 2023- AMF Enforcement Committee decision issued, imposing fines and five-year bans on Séquence 13 and Jean-Louis Lehmann.
Compliance Impact
Urgency: High - This decision highlights escalating AMF scrutiny on CIFs, with fines, bans, and personal accountability in multiple recent cases (2022-2025), signaling increased inspection risk and potential for director bans. It matters because failures in basic conduct rules lead to severe, long-t
Warning Savings protection Forex and binary options Warning The AMF and the ACPR warn the public against unauthorised Forex trading offers from Omega Pro Ltd
Sanctions & settlements Investment advice Other professionals Executive & other private individuals Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee fined a financial investment advisor (FIA) firm and its manager for multiple breaches of professional obligations, including failure to provide mandatory documents, inadequate risk disclosure, poor KYC practices, misleading information, unauthorized placing activities, and improper third-party marketing mandates. This enforcement action underscores the AMF's strict scrutiny of FIAs, emphasizing due care, conflict management, and adherence to status limits, with fines and bans serving as deterrents. Compliance teams should review it for lessons on documentation, client suitability, and outsourcing controls to avoid similar sanctions.
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What Changed
This is an enforcement decision, not a regulatory change, but it reinforces and clarifies existing FIA obligations under French regulations (e.g., AMF General Regulation). Key requirements highlighted include:
Mandatory delivery of initial contact documents, engagement letters, and written reports to clients.
Clear specification of remuneration terms and comprehensive risk information for recommended products.
Thorough KYC to ensure suitability of advice.
Prohibition on misleading information, s
What You Need To Do
Conduct Documentation Audit
Enhance KYC and Suitability Processes
Strengthen Conflicts Framework
Review Activity Scope
Training and Monitoring
Key Dates
24 January 2019AMF Enforcement Committee decision fining Novactifs Patrimoine €250,000 and CEO €100,000 for breaches from March 2014–July 2016.
11 April 2022AMF Enforcement Committee decision imposing 5-year bans and fines (€150,000 firm, €200,000 manager) on DCT/Didier Maurin Finance; appeal dismissed by Conseil d'Etat on 9 September 2024.
4 November 2024AMF fines totaling €5,670,000 on FIA Smart Tréso Conseil, asset managers, and CACEIS Bank for fund marketing/management breaches.
5 November 2025AMF Enforcement Committee decision fining Carat GP and directors €2.5 million total, with permanent/10-year bans (French release: 6 November 2025).
Compliance Impact
Urgency: Medium. This matters as part of a pattern of escalating AMF enforcement against FIAs (fines up to €2.5M, lifetime bans in recent cases), signaling heightened focus on investor protection and governance amid complex products. Firms should prioritize audits now to preempt inspections, but no
Marketing Investing wisely Retail investors Journalists The ACPR and AMF are urging professionals to improve their practices in online marketing of savings products and financial instruments
Sanctions & settlements Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations
AI Analysis
The AMF Enforcement Committee imposed significant sanctions on DCT (formerly Didier Maurin Finance) and its manager Didier Maurin for recommending unauthorized alternative investment funds to clients and obstructing regulatory investigations. This case exemplifies critical compliance failures in product authorization verification and client suitability assessment, with enforcement upheld by France's highest administrative court in September 2024.
What Changed
This enforcement action clarifies several regulatory obligations for financial investment advisors:
Product Authorization Verification: Financial advisors must verify that recommended investment products are authorized for marketing in France before advising clients, regardless of the product's legitimacy in other jurisdictions.
Client Interest Prioritization: Recommending unauthorized products is inherently contrary to client interests and constitutes a breach of the duty to act with competen
What You Need To Do
*Immediate compliance measures for financial investment advisors:
*Product Authorization Audit
*Pre-Recommendation Due Diligence
*Client Suitability Documentation
*Regulatory Cooperation Protocol
Key Dates
11 April 2022- AMF Enforcement Committee issued original decision imposing five-year ban and fines
18 July 2022- Conseil d'État suspended enforcement of fines pending appeal
9 September 2024- Conseil d'État dismissed appeal, upholding all sanctions and ordering payment of €1,500 each to AMF
Appointment Journalists Investment management companies The AMF announces the appointment of Jessica Reyes as Director of the Asset Management Regulation Division
Warning Savings protection Forex and binary options Crypto-assets Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Atypical products Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Asset management Savings protection Journalists Investment management companies The AMF announces the creation of a working group on the end-of-life of private equity funds
Sanctions & settlements Journalists The AMF to call for an amendment of the law on obstructing investigations and inspections
AI Analysis
The AMF announced its intention to propose legislative amendments to the French Monetary and Financial Code following a January 28, 2022 Constitutional Council decision that found dual prosecution for obstructing AMF investigations and inspections unconstitutional. The amendment aims to eliminate the possibility of simultaneous administrative and criminal penalties for the same obstruction conduct, while preserving the AMF's enforcement authority.
What Changed
The primary regulatory change addresses a constitutional violation regarding dual prosecution under the ne bis in idem principle:
Current problem: The Monetary and Financial Code previously allowed both administrative sanctions by the AMF Enforcement Committee and criminal prosecution for identical obstruction conduct, violating the constitutional prohibition against double jeopardy.
Proposed solution: Legislative amendments will eliminate the possibility of dual prosecution while maintaining
What You Need To Do
*For compliance professionals and regulated entities:
*Review cooperation policies
*Assess ongoing proceedings
*Monitor legislative developments
*Counsel on cooperation
Key Dates
January 28, 2022- Constitutional Council decision declaring dual prosecution unconstitutional
No specific implementation deadline stated- AMF committed to proposing amendments "as soon as possible"
Current status (as of January 2026)- Amendments appear to be in legislative proposal stage; no effective date yet announced
Europe & international Sustainable Finance Asset management The AMF invites providers, users and rated entities to respond to ESMA's Call for evidence on the ESG rating market in Europe
AI Analysis
The AMF is urging French stakeholders—ESG rating providers, users, and rated entities—to respond to ESMA's 2022 Call for Evidence on the EU ESG rating market to inform European Commission efforts on improving transparency and reliability. This matters as it contributes to the foundational data driving the ESG Ratings Regulation (EU 2024/3005), which imposes authorization, disclosure, and conflict-of-interest rules on providers, affecting sustainable finance compliance across the EU. With the regulation applying from 2 July 2026, early engagement helps shape final rules amid ongoing ESMA consultations on technical standards.
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What Changed
This AMF notice itself introduces no new regulatory changes; it promotes responses to ESMA's 2022 Call for Evidence, which gathered market insights to support the European Commission's July 2021 sustainable finance strategy. However, it highlights the push for a European framework on ESG ratings, including transparency on methodologies, conflict-of-interest management, internal controls, and dialogue with rated companies—elements now codified in the ESG Ratings Regulation effective 2 January 202
What You Need To Do
For ESG Providers
For Users and Rated Entities
All Affected Firms
AMF Stakeholders
Compliance Impact
Urgency: High – The 2022 Call for Evidence is historical, but it feeds into the ESG Ratings Regulation now in force (since 2 January 2025), with application looming on 2 July 2026—less than 6 months away as of January 2026. Firms face authorization risks, operational overhauls for conflicts/disclosu
Financial disclosures & corporate financing Executive & other private individuals Journalists Listed companies and issuers Takeover listed companies The AMF proposes targeted measures to make financial markets more attractive for companies
Crypto-assets Innovation Market infrastructures New step forward in the adoption of the regulation on a Pilot Regime for market infrastructures based on the blockchain technology
Long term investment Retail investors Journalists More than one million new retail investors have entered equity markets in France over the last 3 years, according to the AMF's dashboard
Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorised to do so
Warning Savings protection Forex and binary options Crypto-assets Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Forex and binary options Crypto-assets Warning The AMF and the ACPR warn the public against the activities of several entities offering in France investments in Forex and in crypto-assets derivatives without being authorized to do so
Warning Savings protection Miscellaneous assets Warning The AMF is warning the public against several companies proposing atypical investments without being authorized to do so
Asset management Transposition of the directive on the cross-border distribution of collective investment undertakings: the AMF amends its General Regulation and its policy
Cooperation Derivatives or structured products Europe & international Markets Post-trading infrastructures The AMF and the ACPR sign two cooperation agreements with the SEC regarding the regime applicable to Security Based Swap Dealers (SBSD) in the U.S
Crypto-assets Savings protection AMF is warning retail investors on the importance of consulting the white list of digital asset service providers (DASPs)
Asset management The AMF has postponed the effective date of the authorisation withdrawal of the asset management company Nestadio Capital
AI Analysis
The Autorité des Marchés Financiers (AMF) postponed the effective date of the authorization withdrawal for Nestadio Capital, a portfolio asset management company, to allow time for fund transfers or liquidation following repeated non-compliance with authorization terms. This matters for compliance professionals as it illustrates AMF's enforcement approach to regulatory breaches in asset management, emphasizing orderly wind-downs to protect investors while signaling risks of judicial intervention if issues persist. The case culminated in judicial liquidation by 2022, highlighting long-term consequences for non-compliant firms.
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What Changed
Initial authorization withdrawal decided on 17 December 2019 due to Nestadio Capital's failure to comply with authorization terms, including capital requirements, with original effective date at the latest 1 July 2020 (or upon fund transfer/liquidation).
Multiple postponements: 9 June 2020 and 8 December 2020 extended to 30 June 2021; 8 June 2021 further extended to 31 December 2021 to facilitate fund sales and liquidation.
7 December 2021 postponement tied withdrawal effect to full fund liquida
What You Need To Do
For Nestadio Capital (historical)
For investors
For industry peers
AMF referrals to courts underscore need for firms to self-report issues early to avoid escalation
Key Dates
17 December 2019- AMF Board decides authorization withdrawal.
1 July 2020- Original latest effective date for withdrawal (or fund transfer/liquidation).
9 June 2020& **8 December 2020** - Postponements to **30 June 2021**.
8 June 2021- Postponement to **31 December 2021** for fund sales/liquidation.
4 October 2021- Conseil d'Etat rejects Nestadio's appeal.
Compliance Impact
Urgency: low - This is a resolved 2019-2022 enforcement case with no ongoing deadlines or new rules as of 2026; Nestadio is in judicial liquidation. It matters as a precedent for AMF's phased withdrawal process, protecting investors via extensions and liquidators, but warns asset managers of severe
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Warning Savings protection Forex and binary options Warning The Autorité des Marchés Financiers (AMF) updates the list of unauthorised websites offering binary options trading
Warning Savings protection Forex and binary options Warning The Autorité de Contrôle Prudentiel et de Résolution and the Autorité des Marchés Financiers warn the public against the activities of several websites and entities proposing Forex investments without being authorised to do so.
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Warning Savings protection Forex and binary options Warning The Autorité des Marchés Financiers (AMF) updates the list of unauthorised websites offering binary options trading
Warning Savings protection Warning The Autorité des Marchés Financiers (AMF) warns the public about the activities of individuals claiming to work for the AMF
Warning Savings protection Forex and binary options Warning The Autorité des Marchés Financiers (AMF) updates the list of unauthorised websites offering binary options trading
Warning Savings protection Forex and binary options Warning The Autorité des Marchés Financiers (AMF) updates the list of unauthorised websites offering binary options trading
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Warning Savings protection Forex and binary options Warning The Autorité des Marchés Financiers (AMF) updates the list of unauthorised websites offering binary options trading
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