Consumer Protection / Conduct

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - ESMA reports that NCAs have strengthened authorisation assessments by placing greater emphasis on firms’ cross-border business plans and intentions before granting or maintaining permissions.
• NCAs are increasingly using data-driven and risk-based supervision to monitor cross-border activity and calibrate supervisory attention to the scale, nature, and complexity of the activity.
• NCAs have expanded cooperation and enforcement, including more targeted supervisory actions and reporting of enforcement cases where relevant.
• ESMA expects NCAs with significant outbound cross-border activity to ensure that their supervisory and enforcement approaches are proportionate to the level of risk and business volume.
• The report reinforces that cross-border activity should be treated as a distinct supervisory risk area, not merely as an incidental extension of domestic supervision.

Suggested Considerations

• Review cross-border business plans for all passported investment services and ensure they are supported by clear governance, staffing, systems, and client-service arrangements.
• Map all outbound cross-border activities by jurisdiction, client type, product type, and distribution channel so that compliance can identify where supervisory risk is highest.
• Strengthen controls over retail cross-border activity, including marketing, suitability/appropriateness, complaints handling, and local conduct requirements in each host market.
• Prepare to provide supervisors with more granular evidence of how cross-border risks are identified, monitored, escalated, and mitigated.
• Ensure internal reporting can distinguish cross-border revenue, complaints, incidents, and enforcement exposure from domestic business lines.

Key Dates

References

• [1] esma.europa.eu/sites/default/files/2026-07/ESMA42-2004696...
• [2] esma.europa.eu/press-news/esma-news/esma-finds-shortcomin...
• [3] esma.europa.eu/sites/default/files/2025-10/ESMA22-5075148...
• [4] esma.europa.eu/sites/default/files/2025-12/ESMA35-3354356...
• [5] esma.europa.eu/sites/default/files/2026-06/ESMA22-5075148...
• [6] schoenherr.eu/content/to-the-point-financial-regulation-1...
• [7] esma.europa.eu/press-news/esma-news/esma-publishes-report...
• [8] esma.europa.eu/sites/default/files/library/esma42-111-553...

What Changed

• - The CBI has formally listed Aoncfd (CLONE) as an unauthorised investment firm / investment business firm that is not permitted to provide investment services or operate as an investment firm in...
• The CBI has publicly identified Aoncfd (CLONE)’s websites, email address, and purported Dublin address to support monitoring and blocking efforts by firms and market infrastructures.
• The CBI has clarified that Aoncfd (CLONE) is a clone entity that has copied the name, address and foreign registration details (CONSOB Registration 5141) of Aon Solutions Ireland Limited, and that...
• The publication reiterates that the CBI will use its section 53 naming power under the Central Bank (Supervision and Enforcement) Act 2013 to publicly warn about unauthorised firms.
• The notice reinforces existing expectations that firms, consumers, and intermediaries should use the CBI’s authorisations register and list of unauthorised firms as part of fraud and clone‑risk...

Suggested Considerations

• Firms should immediately screen client referral sources, onboarding records, and any existing or prospective relationships against the identifiers published for Aoncfd (CLONE) (names, URLs, email, and purported address) and block or terminate any exposure.
• Compliance teams should update internal fraud and financial crime watchlists and sanctions‑style screening tools to include Aoncfd (CLONE) and the specific URLs, email address and address cited in the warning.
• Authorised firms, particularly Aon Solutions Ireland Limited, should conduct brand‑misuse and impersonation checks (including web‑scraping, social media monitoring and domain surveillance) to identify further clone activity and prepare incident‑response plans.
• Client‑facing staff should be briefed via targeted compliance communications to warn clients about clone firms and to ensure they direct clients to the CBI’s register and unauthorised firms list when verifying any investment provider claiming an Irish authorisation.
• Firms should review and, where necessary, enhance KYC and onboarding controls to include explicit verification of a counterparty’s regulatory authorisation in Ireland (or relevant jurisdiction) and checks for inconsistencies between provided details and registry information.

Key Dates

References

• [1] centralbank.ie/news/article/fti-finance-limited-(clone)--...
• [2] fi.ee/sites/default/files/2023-02/CENTRA~2.PDF
• [3] finanstilsynet.no/contentassets/4bd8bb48debc4989af4e599b1...

What Changed

• - The CBI has formally listed “Codeve Insurance Co DAC (CLONE)” as an unauthorised insurance/reinsurance firm and insurance intermediary/distributor for Ireland.
• The CBI confirms that this entity is not authorised in Ireland to provide insurance, reinsurance or insurance distribution/intermediary services.
• The warning identifies specific contact points used by the clone: website `https://www.codeveinsurance.com` and email addresses `contact@codeveinsurance.com`, `legal@codeve.com` and...
• The CBI confirms that the unauthorised firm has cloned the name and details of the authorised firm CODEVE Insurance Company dac to pass itself off as that legitimate entity and deceive consumers.
• The CBI explicitly states there is no connection between the authorised CODEVE Insurance Company dac and the unauthorised clone, clarifying that the authorised firm is a victim of impersonation.

Suggested Considerations

• Update internal unauthorised/blacklist tables and watchlists to include “Codeve Insurance Co DAC (CLONE)”, the website `https://www.codeveinsurance.com`, and the email addresses `contact@codeveinsurance.com`, `legal@codeve.com`, and `Investorrelations@bournrockinvest.com`.
• Configure onboarding, third‑party due diligence and supplier management systems so that any counterparty or proposal referencing these identifiers or closely similar names triggers escalation and enhanced verification.
• Conduct an immediate screening of existing distribution, outsourcing, binder, reinsurance and fronting arrangements to confirm that no current relationships involve the clone entity or its contact details.
• Implement or reinforce a formal “clone‑firm check” in client and counterparty KYC/KYB procedures, requiring staff to verify authorisation status directly against the CBI’s registers and unauthorised firm list before entering into insurance or reinsurance arrangements linked to Ireland.
• Issue an internal compliance and financial‑crime alert to underwriting, sales, distribution, treasury and investment teams highlighting the Codeve clone, the specific identifiers, and the need to report any contact or proposals linked to this entity.

Key Dates

References

• [1] centralbank.ie/news/article/central-bank-of-ireland-issue...
• [2] centralbank.ie/docs/default-source/regulation/industry-ma...
• [3] fi.ee/sites/default/files/2026-01/Standard%20Life%20Irela...
• [4] williamfry.com/knowledge/cbi-publishes-consultation-paper...

What Changed

• - The decision clarifies that EBA’s decision whether or not to initiate an investigation into a possible breach or non‑application of Union law under Article 17 of Regulation (EU) No 1093/2010 is a...
• The Board of Appeal confirms that a decision not to open a Union law breach investigation does not constitute a reviewable “decision” for the purposes of Article 60(1)–(2) of the ESA Regulations and...
• The Board of Appeal confirms that individual complaints about account closures and associated supervisory handling remain primarily within the remit of national competent authorities and national...
• The decision reiterates that only certain categories of ESA acts that produce binding legal effects (for example, decisions adopted under Articles 17, 18 or 19 of the ESA Regulations, and acts within...
• The outcome aligns with prior Board of Appeal and EU court case law confirming that persons outside the specific categories listed in Article 17(2) of the ESA Regulations have no right of appeal to...

Suggested Considerations

• Review internal complaints‑handling and escalation procedures to ensure that disputes over account closures and related supervisory decisions are managed through national complaint bodies and courts, rather than assuming EBA or Board of Appeal review will be available.
• Update legal and compliance guidance notes to reflect that EBA’s decision whether to initiate a breach‑of‑Union‑law investigation is discretionary and generally not subject to appeal before the Board of Appeal, limiting external escalation avenues.
• Train front‑office, customer‑service and complaints staff to provide accurate information to customers about available redress routes, emphasising national ombudsman, national competent authority and judicial mechanisms rather than ESMA/EBA appeals.
• For groups operating across the EU, map national complaint and judicial mechanisms for account closures in each jurisdiction and integrate them into group‑wide conduct risk frameworks and customer communication templates.
• Monitor further ESA and EU court case law on which ESA acts are susceptible to appeal before the Board of Appeal, and adjust litigation and escalation strategies accordingly.

Key Dates

References

• [1] eba.europa.eu/sites/default/files/document_library/103736...
• [2] eulawlive.com/european-banking-authoritys-decision-not-to...
• [3] cms.law/en/int/regulatory-news/eba-eiopa-esma-decision4
• [4] eufimar.jeanmonnet.unige.it/boa
• [5] esma.europa.eu/press-news/esma-news/esas-joint-board-appe...
• [6] inview.nl/document/idfc65faa7e3b34ffab5a421db4ee486d3/esa...
• [7] art.torvergata.it/retrieve/5202f4a5-3ac8-4386-b202-68b342...
• [8] inview.nl/document/idf6f86cf964ed45c8930028872e35ba78/jud...

What Changed

• - Regulation E‑Delivery would formally replace the SEC’s decades‑old, purely guidance‑based approach to electronic delivery and establish a rule‑based framework that expressly permits e‑delivery to...
• Electronic delivery would become the default method of delivery, meaning firms could deliver required regulatory information electronically without first obtaining the investor’s affirmative consent,...
• The rule would preserve investor choice by requiring that investors and other recipients be able to request paper delivery at any time and continue receiving paper format upon request.
• The proposal would set out requirements and conditions for when e‑delivery is deemed compliant, including use of electronic addresses or other electronic methods reasonably designed to ensure receipt...
• The range of deliverable documents under Regulation E‑Delivery would be broad, covering prospectuses for funds and other issuers, fund annual and semi‑annual shareholder reports, proxy statements,...

Suggested Considerations

• Conduct a comprehensive mapping of all documents currently delivered under federal securities law requirements (prospectuses, shareholder reports, proxy materials, trade confirmations, Form CRS, Form ADV brochures) and determine how each will be delivered under Regulation E‑Delivery.
• Review and update disclosure, investor communication and delivery policies to incorporate e‑delivery as the default method while clearly documenting investor rights to request and receive paper delivery at any time.
• Design and implement procedures for maintaining accurate electronic contact information for investors and clients, including periodic verification processes and remediation steps for undeliverable emails or failed electronic transmissions.
• Develop and operationalize the transition process for paper‑based recipients, including generation and mailing of the two required paper notices that explain the move to e‑delivery and the opt‑out option.
• Update client and investor onboarding materials, account agreements and preference‑capture workflows to reflect the new default e‑delivery model and how investors can elect paper delivery or change their preferences.

Key Dates

References

• [1] reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=32...
• [2] morganlewis.com/blogs/finreg/2023/04/an-end-to-the-paper-...
• [3] sec.gov/rules-regulations/2000/04/use-electronic-media
• [4] sec.gov/files/rules/proposed/2023/33-11176.pdf
• [5] sec.gov/comments/s7-09-20/s70920-8210190-227541.pdf
• [6] finra.org/media-center/blog/facilitating-e-delivery-while...
• [7] planadviser.com/white-house-to-review-sec-electronic-deli...
• [8] klgates.com/Click-Here-for-Your-Fund-Report-SEC-Endorses-...

What Changed

• - Introduction of a tailored regulatory framework for single‑parent captive insurers in the UK, distinct from the regimes applicable to traditional insurers and reinsurers.
• Creation of a streamlined dual PRA/FCA authorisation process for captives, with an explicit target decision timeline of 4–6 weeks from application.
• Exclusion of captives from Solvency UK requirements, with a move to a separate, flexible capital resources framework rather than Solvency II‑style minimum capital requirements.
• Exclusion of captives from the FCA Consumer Duty, recognising that captives primarily insure intra‑group risks and have limited direct retail customer exposure.
• Introduction of proportionately lower capital requirements for captives, reflecting their lower risk profile and group‑risk‑financing purpose.

Suggested Considerations

• Assess whether existing or planned group risk‑financing strategies would benefit from establishing a UK single‑parent captive under the proposed regime and document the strategic rationale.
• Map current and planned intra‑group insurance and reinsurance arrangements, including any employee benefits‑related policies, to confirm which risks can be written directly and which must only be written on a reinsurance basis.
• Engage early with internal stakeholders (risk, treasury, legal, tax, and senior management) to determine preferred captive structures (standalone vs future PCC) and governance arrangements aligned with PRA expectations.
• Prepare to participate in the PRA and FCA consultations by drafting detailed, technical responses on authorisation processes, capital methodologies, reporting templates, and conduct requirements for captives.
• Review existing Solvency UK and Consumer Duty compliance frameworks and identify which elements would no longer apply to captives under the proposed regime, while ensuring that any remaining protections and safeguards are maintained where appropriate.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] assets.publishing.service.gov.uk/media/686fc3f910d550c668...
• [3] clydeco.com/en/insights/2025/07/government-plans-to-proce...
• [4] skadden.com/insights/publications/2025/07/uk-proposed-new...
• [5] tradingview.com/news/reuters.com,2025:newsml_S8N3Q9078:0-...
• [6] slaughterandmay.com/media/mzaiarh0/fr1356-18-june-2026.pdf
• [7] cms.law/en/gbr/publication/financial-services-horizon-sca...
• [8] bankofengland.co.uk/-/media/boe/files/prudential-regulati...

What Changed

• - Licensed SCF operators must implement structured due diligence checks on issuers, including clear policies on information to be obtained, risk assessment criteria and documentation standards, and...
• Lending-based SCF operators are generally prohibited from allowing a borrower to take up a new loan to repay an existing overdue loan, unless there are legitimate, documented reasons to extend a new...
• Where a lending-based SCF operator does extend a new loan to a borrower with outstanding loans, it must disclose the borrower’s total outstanding loans and the reasons for extending the new loan so...
• SCF operators must establish formal policies and procedures for issuer default management, documenting circumstances under which the operator will pursue various recovery options (e.g.
• Operators must disclose to investors the different recovery options and associated costs and must seek and obtain investors’ consent before incurring any recovery-related costs that will be borne by...

Suggested Considerations

• Review existing issuer due diligence policies and procedures and update them to align with MAS’s expectations on structured checks, documentation, and investor disclosure of due diligence scope for all SCF offers.
• Implement a formal policy prohibiting the use of new loans to repay existing overdue loans, except where legitimate reasons exist; define those reasons, approval thresholds and documentation requirements for exceptions.
• Enhance lending workflows to ensure that, when new loans are extended to borrowers with outstanding loans, the platform system automatically collates and presents total outstanding exposure and the rationale for the new loan to investors in pre-investment disclosures.
• Develop and approve a detailed issuer default management framework that defines escalation triggers, recovery options, decision criteria, investor communication templates, and record-keeping requirements.
• Update investor terms and conditions and consent mechanisms so that investors explicitly agree to any potential recovery-related costs, with clear fee schedules and scenarios disclosed before costs are incurred.

Key Dates

References

• [1] ronaldjjwong.com/2018/10/24/mas-circular-controls-disclos...
• [2] singaporefintech.org/news/controls-and-disclosures-to-be-...
• [3] nas.gov.sg/archivesonline/data/pdfdoc/20160608004/Press%2...
• [4] caas.gov.sg/docs/default-source/docs---legal/air-navigati...
• [5] bakermckenzie.com/-/media/files/insight/publications/2015...
• [6] sso.agc.gov.sg/SL/SFA2001-RG13?DocDate=20181005&ViewType=...
• [7] conventuslaw.com/report/mas-clarifies-crowdfunding-access...
• [8] mas.gov.sg/-/media/compliance-toolkit-for-approvals-notif...

What Changed

• Because the visible page content provided is limited to technical and cookie‑related information, the key points below focus on the regulatory substance of the CSSF MiFID II/MiFIR FAQ (Q&A) as the...
• The CSSF confirms the application of MiFID II investor protection rules to Luxembourg investment service providers, including obligations on inducements, suitability, product governance, and best...
• The FAQ reiterates that investment services providers must inform clients clearly whether their investment advice or services are provided on an independent or non‑independent basis, and explains the...
• The FAQ clarifies that inducements are expressly prohibited when investment advice is provided on an independent basis and for portfolio management services, requiring firms to structure their...
• The CSSF guidance reflects product governance obligations: manufacturers must define a target market for each financial instrument based on clients’ knowledge and experience, financial situation,...

Suggested Considerations

• Review the latest CSSF MiFID II/MiFIR FAQ (13 July 2026 version) in full, comparing it against existing internal MiFID II/MiFIR policies, procedures, and controls to identify gaps or misalignments.
• Confirm and, where necessary, update client‑facing disclosures to clearly state whether investment services (especially advice and portfolio management) are provided on an independent or non‑independent basis, and ensure that inducement arrangements are consistent with this classification.
• Reassess inducement frameworks (commissions, fees, non‑monetary benefits) for investment advice and portfolio management to ensure that no prohibited inducements are received or retained where services are independent or involve portfolio management.
• Review and update product governance frameworks, including target market definition processes and product approval procedures, to ensure that each instrument’s intended target market is properly documented and consistently used by distributors.
• Examine best execution policies to confirm they are clear, detailed, and understandable to clients, and implement or enhance ongoing monitoring mechanisms (e.g. execution quality reports, periodic reviews) to evidence compliance with best execution obligations.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/QA-MiFIDII_MiFIR.pdf
• [2] cssf.lu/en/Document/cssf-faq-mifid-ii-mifir/
• [3] cssf.lu/en/mifid-ii-priips/
• [4] cssf.lu/fr/mifid-ii-priips/
• [5] nortonrosefulbright.com/en/knowledge/publications/494a828...
• [6] esma.europa.eu/sites/default/files/library/esma35-43-349_...

What Changed

• - The Central Bank of Ireland has formally designated “MacKay Shields UK LLP (CLONE)” as an unauthorised investment firm / investment business firm / alternative investment fund manager and published...
• The notice clarifies that MacKay Shields UK LLP (CLONE) is not authorised to provide investment services, investment business services or AIFM services in Ireland and therefore any financial services...
• The Central Bank highlights that the clone firm has been offering fake investments via the applications NYLI and NYLIPLUS, emphasising a specific scam vector via investment apps rather than...
• The warning confirms that the clone firm has cloned the name and registration details of the legitimate MacKay Shields UK LLP (Central Bank register C121665), reinforcing the pattern of...
• The firm’s name is being published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, signalling that the Central Bank considers the activity sufficiently serious to warrant...

Suggested Considerations

• Review and update client‑facing communications, website content and FAQs to warn clients about clone‑firm risks, specifically referencing messaging‑app contact details and investment apps such as NYLI and NYLIPLUS that are not associated with authorised firms.
• Implement or enhance procedures within AML / financial crime and fraud‑risk frameworks to identify and escalate interactions involving the listed email address (support@mackay-shields.email) and the specified WhatsApp and telephone numbers, treating them as indicators of potential scam activity.
• Instruct front‑office, client‑relationship and call‑centre staff to verify authorisation status using the Central Bank’s public registers before acknowledging or forwarding any investment proposals that reference “MacKay Shields UK LLP” or similar branding.
• Notify internal legal and regulatory affairs teams, and where relevant the legitimate MacKay Shields UK LLP, of the clone warning to coordinate responses, client communications and potential reporting of any attempted impersonation or fraudulent use of the authorised firm’s details.
• Review existing third‑party distribution and referral arrangements to ensure counterparties are not using or promoting NYLI, NYLIPLUS or similar unregulated applications, and add contractual provisions requiring immediate notification if cloning or impersonation is suspected.

Key Dates

References

• [1] finanstilsynet.no/contentassets/1f99db27d4004b4198e3a44d1...
• [2] centralbank.ie/news/article/larl-f.s.---larl-financial-se...
• [3] centralbank.ie/news/article/apel-investments-(clone)---ce...
• [4] centralbank.ie/news/article/fti-finance-limited-(clone)--...
• [5] fca.org.uk/news/warnings/bwb-ireland-investment-managemen...
• [6] breakingnews.ie/business/central-bank-has-issued-almost-1...
• [7] linkedin.com/posts/compliance-institute_warning-notices-t...
• [8] irishtimes.com/business/financial-services/central-bank-i...

What Changed

• - The CBI has formally designated AGF International Advisors Company Limited (CLONE) and/or Iron-Cap / IRONCAP as an unauthorised investment firm / investment business firm and has published its...
• The specific websites www.iron-cap.com and https://www.iron-cap.io (including the French-language path https://www.iron-cap.io/fr/forgot-password/) have been identified as associated with this...
• The email addresses support@iron-cap.com and Samuel.breval@iron-cap.com have been flagged as being used by the unauthorised entity in connection with the Iron-Cap / IRONCAP investment offering.
• The CBI has reiterated that the clone is not authorised to provide investment services or investment business services in Ireland and has explicitly clarified that there is no connection whatsoever...
• The warning reinforces existing CBI expectations that Irish‑authorised firms and gatekeepers must monitor and respond to clone‑firm activity, including by reporting suspected unauthorised firms...

Suggested Considerations

• Review and update client‑onboarding procedures to include specific screening for the websites www.iron-cap.com and https://www.iron-cap.io and the email domains associated with Iron-Cap / IRONCAP, flagging and escalating any matches as suspected clone‑firm exposure.
• Update sanctions, fraud, and financial crime screening tools and internal watchlists to include the unauthorised firm identifiers associated with AGF International Advisors Company Limited (CLONE) and Iron-Cap / IRONCAP, ensuring alerts are generated for relevant customer or transaction hits.
• Strengthen fraud‑awareness communications to clients and staff by referencing the CBI’s financial scam materials, emphasising the risks of dealing with unauthorised firms and clone entities, and advising clients to verify firm authorisation before investing.
• Establish or update an internal escalation protocol for suspected clone‑firm activity, ensuring that all such cases are reported promptly to the CBI via the dedicated unauthorised firms reporting channels and, where applicable, to other relevant regulators.

Key Dates

References

• [1] centralbank.ie/news/article/press-release-warning-agf-(cl...
• [2] centralbank.ie/news/article/apel-investments-(clone)---ce...
• [3] cnmv.es/webservices/verdocumento/ver?e=25B0Uu3r5m6GcxD3cP...
• [4] fca.org.uk/news/warnings/agf-europe-advisors-clone
• [5] finanstilsynet.no/contentassets/94a5c72015a5407391c9f7eee...
• [6] centralbank.ie/news-media/warning-notices/56
• [7] cnmv.es/webservices/verdocumento/ver?e=sDwq3fSYKAJr8phF8P...
• [8] fi.ee/et/print/pdf/node/48614

What Changed

• - The CBI has formally designated Arbionis as an unauthorised investment firm and published its details (name, website, phone number) as a warning notice on its website.
• The CBI has clarified that Arbionis is not authorised to provide investment services in Ireland, meaning it cannot lawfully carry out regulated investment activities in or into Ireland.
• The name Arbionis has been published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, confirming this is part of the CBI’s supervisory and enforcement toolkit against...
• The warning reiterates that market participants and the public should use the CBI’s channels (telephone line and online reporting tool) to report suspected unauthorised firms or persons.
• The CBI re‑emphasises its consumer‑protection messaging, directing individuals and firms to its dedicated financial scams information page, thereby underlining expectations that firms proactively...

Suggested Considerations

• Screen all existing and prospective counterparties, introducers, and investment product providers against the CBI unauthorised firms list, and update internal watchlists to include Arbionis and its known identifiers (name, website, phone number).
• Prohibit onboarding Arbionis as a counterparty, intermediary, or service provider and ensure no marketing, introduction, or distribution arrangements exist or are entered into with this firm.
• Conduct an immediate review of client transaction flows and communications to identify any exposure to Arbionis, including referrals, introductions, payments, or client queries referencing Arbionis or its website.
• If any exposure to Arbionis is identified, escalate to compliance and legal functions, assess potential consumer detriment, and consider notifying the Central Bank of Ireland via the dedicated phone number or online reporting channel.
• Enhance client‑facing communications and website content to warn clients about unauthorised investment firms, referencing the CBI’s financial scams guidance and explaining how clients can verify authorisation status.

Key Dates

References

• [1] centralbank.ie/news/article/alliancebernstein-limited-(cl...
• [2] rte.ie/news/business/2021/1222/1268177-central-bank-warning/
• [3] centralbank.ie/news/article/beinfinity-clone----central-b...
• [4] centralbank.ie/news/article/warning-notice-lioniseassets-...
• [5] centralbank.ie/regulation/how-we-regulate/authorisation/u...
• [6] cnmv.es/webservices/verdocumento/ver?e=x8hCs+c9Bo88couiGD...
• [7] fi.ee/sites/default/files/2024-08/Guardian%20Invest%20-%2...
• [8] irishtimes.com/business/financial-services/central-bank-i...

What Changed

• - The CBI has formally designated “LGIM Managers (Europe) Limited (CLONE)” as an unauthorised investment firm / investment business firm and published its details on the CBI unauthorised firms list...
• The CBI has explicitly stated that the clone entity is not authorised to operate as an investment firm or investment business firm in Ireland, thereby clarifying that any investment services offered...
• The warning identifies specific contact details associated with the scam, including email addresses info@lgimeu.com (now inactive) and office@bunqpartner.com, a purported address at...
• The CBI has confirmed that the clone has copied the name and registration details of the legitimate CBI‑authorised firm LGIM Managers (Europe) Limited (C173733), while emphasising that there is no...
• By publishing the firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, the CBI has activated its statutory regime for public warning notices on unauthorised firms,...

Suggested Considerations

• Update customer‑facing fraud warnings, website scam information pages, and client communications to include reference to the CBI warning on the LGIM clone and to explain how clients can verify whether a firm is authorised in Ireland.
• Enhance onboarding and periodic KYC / KYB procedures to include independent verification of counterparties’ authorisation status on the CBI register and cross‑check any claimed partnership with LGIM Managers (Europe) Limited, bunq Bank, or similar institutions.
• Implement or update internal guidance requiring staff to escalate immediately any client queries, introductions, or marketing materials referencing “LGIM Managers (Europe) Limited (CLONE)” or using the listed contact details to the compliance and financial crime teams.
• Conduct a targeted review of recent and ongoing distribution, referral, and introducer arrangements to identify any potential exposure to unauthorised clone entities or intermediaries misusing the LGIM brand or falsely claiming CBI authorisation.
• Train frontline staff, relationship managers, and call‑centre agents on the specific red flags associated with clones of authorised firms, including copied registration details, foreign addresses, and use of generic email domains, and on the process for verifying authorisation with the CBI.

Key Dates

References

• [1] centralbank.ie/news/article/warning-notice-central-bank-o...
• [2] centralbank.ie/news/article/j.p.-morgan-asset-management-...
• [3] cnmv.es/webservices/verdocumento/ver?e=25B0Uu3r5m6GcxD3cP...
• [4] fca.org.uk/consumers/warning-list-unauthorised-firms
• [5] am.landg.com/en-ie/institutional/scam-information/
• [6] finanstilsynet.no/contentassets/f9913c4f6ddc42d99873cc6d9...
• [7] fi.ee/et/print/pdf/node/51167
• [8] lexisnexis.com/en-gb/legal/news/ireland-cbi-issues-warnin...

What Changed

• - The CBI has formally identified “Inloovi Ireland Ltd. (Clone)” as an unauthorised insurance intermediary that is not authorised to provide insurance intermediary or insurance distribution services...
• The CBI has publicly associated specific digital identifiers with this fraudulent entity, including the website inloovi.com and email addresses insurance@inloovi.com, complaints@inloovi.com,...
• The CBI confirms that Inloovi Ireland Ltd. (Clone) has cloned details of a legitimate CBI‑authorised firm, A.R.B.
• The CBI clarifies that there is no connection whatsoever between the legitimate authorised entity and the clone firm, and the warning is intended to protect both consumers and the legitimate firm’s...
• The CBI reiterates that the name of the unauthorised firm is published under Section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reinforcing its supervisory and enforcement stance...

Suggested Considerations

• Review and update internal sanctions/blacklist and fraud‑risk lists to include “Inloovi Ireland Ltd. (Clone)”, the domain inloovi.com, and the listed email addresses, ensuring screening across onboarding, claims, complaints, and payment processing.
• Conduct an immediate counterparty and referral review to confirm that no current or proposed distribution, outsourcing, or referral arrangements involve Inloovi Ireland Ltd. (Clone) or entities using the inloovi.com domain.
• Enhance KYC and intermediary due‑diligence procedures to include explicit checks against the CBI’s unauthorised firms list and Section 53 Warning Notices before entering into any new intermediary, coverholder, or introducer arrangement.
• Update staff training (particularly for sales, claims, complaints, and contact‑centre teams) on recognising clone‑firm indicators (e.g., similar names, use of look‑alike domains, unofficial email addresses) and on escalation pathways to compliance and fraud teams.
• Review and, where necessary, enhance website monitoring and brand‑abuse detection (including domain monitoring, phishing detection, and use of take‑down services) to identify and address fraudulent websites or email domains purporting to represent the firm.

Key Dates

References

• [1] centralbank.ie/news/article/dev-limited-(clone)---central...
• [2] centralbank.ie/news/article/pionew-ireland-(clone)---cent...
• [3] centralbank.ie/news/article/warning-notice-central-bank-o...
• [4] centralbank.ie/news/article/fti-finance-limited-(clone)--...
• [5] centralbank.ie/news/article/warning-notice-lioniseassets-...
• [6] centralbank.ie/news/article/central-bank-of-ireland-issue...
• [7] cnmv.es/webservices/verdocumento/ver?e=25B0Uu3r5m6GcxD3cP...
• [8] centralbank.ie/regulation/how-we-regulate/authorisation/u...

What Changed

• - FCA reinforces that product design must be explicitly based on evidenced consumer needs, characteristics and behaviours, rather than generic assumptions or internal commercial priorities.
• Firms are expected to define target markets at a granular level, avoiding broad or generic categories that mask differing needs or risks (especially for vulnerable customers).
• Product governance must be embedded into business‑as‑usual decision‑making with clear ownership, challenge and accountability, not treated as a one‑off Consumer Duty implementation project.
• Manufacturers and distributors must maintain robust, ongoing monitoring of consumer outcomes using a wide range of management information, including complaints, usage patterns, early cancellations...
• There must be a clear, demonstrable link between monitoring and remedial action; collecting data without acting on emerging risks is characterised as weak practice.

Suggested Considerations

• Review and update product governance frameworks to ensure they explicitly incorporate Consumer Duty outcomes, including structured consideration of customer needs, characteristics and objectives at every stage of product design and lifecycle.
• Define and document granular target markets for each retail product and service, clearly articulating which customer segments the product is designed for, and excluding groups for whom the product could cause foreseeable harm.
• Map products and services against vulnerable‑customer characteristics and update design, features, pricing and servicing models to mitigate risks and support good outcomes for vulnerable groups.
• Implement or enhance processes to collect comprehensive management information on consumer outcomes (complaints, customer feedback, usage patterns, lapse and cancellation data, arrears and forbearance metrics) for each product.
• Establish governance mechanisms to ensure that insights from monitoring and MI lead to timely, documented actions to improve products, pricing, communications or customer journeys where emerging risks or poor outcomes are identified.

Key Dates

References

• [1] fca.org.uk/publication/finalised-guidance/fg22-5.pdf
• [2] youtube.com/watch?v=gloUN--Svqw
• [3] kpmg.com/xx/en/our-insights/regulatory-insights/what-are-...
• [4] akingump.com/en/insights/alerts/new-fca-principle-12-cons...
• [5] harperjames.co.uk/article/fcas-new-consumer-duty/
• [6] regulationhub.co.uk/fca-consumer-duty
• [7] globalfinregblog.com/2023/04/the-fcas-consumer-duty-deter...
• [8] grantthornton.co.uk/globalassets/1.-member-firms/united-k...