In his latest blog, Governor Gabriel Makhlouf argues that economists must adapt their analytical frameworks and expand their focus beyond traditional topics to address emerging challenges—such as geopolitical upheaval and defence spending—in order to provide robust evidence-based policy advice that serves the public interest.
Central Bank of Ireland has successfully completed the sale of its Spencer Dock (East Wing) building to the Office of Public Works for €23.7m. The sale of Spencer Dock was a key element of the Central Bank’s longer term property strategy aligned to our decision to develop a single Dockland Campus through the purchase of our North Wall Quay building and subsequent purchase of our Mayor Street building. This sale of the East Wing, to Office of Public Works on 22 January 2026, follows the earlie...
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
The latest Accelerated Settlement Taskforce (AST) report updates on the significant progress made towards the move to T+1. Read the AST report.Jamie Bell, head of capital markets at the FCA, said:'T+1 marks a major milestone in our drive to support growth and innovation. Faster settlement cycles will reduce risk, free up capital for faster reinvestment and align with other major markets.'We are delighted to see the great progress made last year highlighted in the AST’s report. By the end of t...
FINRA issued an Information Notice on January 3, 2025, modifying the Contrary Exercise Advice (CEA) cut-off time for options expiring on January 9, 2025, from the standard 5:30 p.m. ET to 10:00 a.m. ET due to the National Day of Mourning. This time-sensitive directive required immediate operational adjustments for all broker-dealers and clearing members handling options exercise instructions on that specific date.
What Changed
The primary regulatory modification addresses a single-day exception to standard options exercise procedures:
CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025.
Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date.
OCC Processing Unchanged: The Options Clearing Corporation's proc
What You Need To Do
*Update Internal Procedures
*System Configuration
*Staff Communication
*Customer Notification
*Submission Coordination
Key Dates
January 9, 2025 - 10:00 a.m. ETFinal deadline for option holders to make exercise/non-exercise decisions and for members to accept exercise instructions (accelerated from standard 5:30 p.m. ET)DEADLINE
January 9, 2025 - 10:00 a.m. ETFinal deadline for members to submit Contrary Exercise Advice to exchanges or OCC (accelerated from standard 5:30 p.m. ET or 7:30 p.m. ET depending on account type and submission method)DEADLINE
January 9, 2025National Day of Mourning; national options exchanges closed; exercises in specified option classes prohibited
Compliance Impact
Urgency: HIGH (for January 9, 2025 operations; now historical)
FINRA's Information Notice dated October 21, 2025, reminds member firms of NSCC's amendment to Rule 50, effective October 17, 2025, which removes the "Settle Prep Day" from the ACATS process, shortening full customer account transfers to 3-4 business days. This matters because it aligns with FINRA Rule 11870's requirements to expedite transfers, enhances operational efficiency, reduces risk, and improves client experience amid broader industry shifts like T+1 settlement.[original notice]
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What Changed
Removal of Settle Prep Day: NSCC Rule 50 amended to eliminate the settlement preparation stage from ACATS, effective October 17, 2025, streamlining the process for all securities transfers.[original notice]
Mutual Fund/Options Synchronization: Eliminates the extra day for processing mutual funds and options via Fund/SERV, aligning their settlement with other assets; also removes the second day of Fund/SERV pending acknowledgment.[original notice]
Overall Timeline Reduction: Full ACATS transfers
September 10, 2025- Federal Register publication of SEC approval (90 FR 43709).[original notice]
October 17, 2025- Effective date: Removal of Settle Prep Day and Fund/SERV changes; firms must support next-day settling assets.[original notice]DEADLINE
October 2026- Planned modernization of ACATS client interfaces (decommission of legacy formats; migration to JSON/MQ for enhanced messaging).
Compliance Impact
Urgency: Medium - Effective over three months ago (as of January 2026), with industry-wide accommodation confirmed; no new mandates but requires ongoing operational alignment to avoid Rule 11870 violations (e.g., delays in validation or exceptions). Matters for reducing transfer failures, enhancing
CSSF Circular 26/906, published on 20 January 2026, establishes detailed requirements for central administration, internal governance, and risk management for payment institutions (PIs) and electronic money institutions (EMIs) in Luxembourg, repealing prior circulars IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155. It clarifies application of the amended Law of 10 November 2009 on payment services, emphasizing robust governance amid sector growth to ensure safety, efficiency, and trust. This matters for compliance as it mandates comprehensive reviews and updates to governance frameworks by mid-2026, addressing rising transaction volumes.
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What Changed
The circular consolidates and updates governance rules, focusing on:
Management bodies: Responsibilities, composition, qualifications, organization, and functioning, including CSSF authorization of members based on professional experience, standing (e.g., police records), and irreproachable conduct.
Internal control functions: Responsibilities, characteristics, organization, and execution of work for compliance officers and internal auditors, with notifications to CSSF including detailed persona
What You Need To Do
Gap analysis
Updates and notifications
Implementation
Documentation
Key Dates
20 January 2026- Publication date of Circular CSSF 26/906.
30 June 2026- Compliance deadline: Institutions must assess/review central administration, internal governance, and risk management frameworks to ensure full compliance.DEADLINE
Compliance Impact
Urgency: High - With ~5 months from publication (20 Jan 2026) to compliance (30 Jun 2026), firms face tight timelines for assessments, policy overhauls, and CSSF notifications, especially given repealed circulars and sector growth pressures. Non-compliance risks supervisory actions, as this fosters
Central administration, internal governance and risk management
AI Analysis
Circular CSSF 26/906, published on 20 January 2026, consolidates and clarifies Luxembourg's rules on central administration, internal governance, and risk management specifically for payment institutions, electronic money institutions, and account information service providers. It repeals prior circulars (IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155) to address growth in transaction volumes by mandating robust governance, control functions, and risk processes, enhancing safety, efficiency, and trust in these services. This matters for compliance professionals as it strengthens defenses against financial crime, operational risks, and supervisory scrutiny in a high-growth sector.
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What Changed
Consolidation and repeal: Replaces outdated circulars with unified requirements under the amended Law of 10 November 2009 on payment services, covering central administration (decision-making must be in Luxembourg), management body responsibilities, internal control functions (compliance, risk management, internal audit as independent second/third lines), conflicts of interest management, new product approval processes, and client funds safeguarding (e.g., segregation, daily/weekly reconciliatio
What You Need To Do
Assess and update governance frameworks
Confirm control functions
Implement operational safeguards
Document proportionality
Retain records and report
Key Dates
20 January 2026 - Publication date of Circular CSSF 26/906.
30 June 2026 - Compliance deadlineInstitutions must assess, review, and ensure their central administration, internal governance, and risk management frameworks fully comply with the circular.DEADLINE
Compliance Impact
Urgency: High – With a 30 June 2026 deadline (five months from publication), firms face immediate pressure to review and remediate governance gaps amid sector growth and heightened AML/CFT scrutiny; non-compliance risks supervisory actions, fines, or license issues, especially as it closes criminal
Supervision Compliance Journalists Investment services providers The AMF publishes the findings of its inspections on the role and involvement of the compliance function at investment services providers
The Prudential Regulation Authority (PRA) has today published its supervisory priorities for 2026, outlining in a letter its sector-specific priorities for the coming year to all banks, building societies, insurers and other PRA-regulated firms.
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
Introduction Good morning and thank you to Michael for inviting me to speak at the Compliance Institute’s Annual General Meeting. It is always a real pleasure to engage with compliance professionals. At the Central Bank, we recognise the essential role played by the compliance community in ensuring that financial firms are well-run and contributing to a financial system that is trusted and resilient. We also recognise the important role played by the compliance institute, equipping those work...
AI Analysis
This speech by Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (CBI), outlines key supervisory priorities including securing customers' interests via the revised Consumer Protection Code, Individual Accountability Framework (IAF) implementation, regulatory simplification, resilience, technology leverage, and an evolving outcomes-focused supervision approach. It matters because it signals CBI's expectations for compliance professionals to drive these outcomes in firms, emphasizing proportionality and ongoing engagement amid regulatory evolution. Compliance teams must integrate these themes to align with CBI's shift toward less process-driven, more effective oversight.
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What Changed
Revised Consumer Protection Code: Introduces new Standards for Business, building on the Code reviewed with industry input; focuses on delivering good outcomes for consumers and the economy.
Individual Accountability Framework (IAF): Implemented 18 months prior (circa mid-2024); enhances clarity on responsibilities, supports governance, and aligns with outcomes-focused regulation rather than enforcement-heavy approaches.
Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcom
What You Need To Do
Implement Revised Consumer Protection Code
Adopt Outcomes-Focused Practices
Engage with CBI
Leverage Technology
Key Dates
24 March 2026- Revised Consumer Protection Code comes into force; firms must ensure full readiness and ongoing embedding of provisions, including new Standards for Business.DEADLINE
January 2026speech).
Compliance Impact
Urgency: Medium. This speech reinforces imminent obligations like the 24 March 2026 Consumer Protection Code effective date (less than 2 months from speech/publication), requiring immediate readiness checks, but lacks new rules or critical enforcement threats. It matters for long-term alignment with
The European Supervisory Authorities and UK financial regulators sign Memorandum of Understanding on oversight of critical ICT third-party service providers under DORA 14 January 2026 Digital Finance and Innovation International cooperation The European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) have today signed a Memorandum of Understanding (MoU) with the Bank of England (BoE), the Prudential Regulation Authority (PRA), and the Financial Conduct Authority (FCA). This agreement...
The FCA, Bank of England and Prudential Regulation Authority have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.The MoU establishes a framework for coordinating and sharing information on the oversight of CTPs under the UK regime and critical third party providers (CTPPs) under the EU’s Digital Operational Resilience Act (DORA), including du...
AI Analysis
The FCA, Bank of England (BoE), and Prudential Regulation Authority (PRA) have signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities (ESAs) to coordinate oversight of critical third parties (CTPs) under the UK's CTP regime and critical third party providers (CTPPs) under the EU's Digital Operational Resilience Act (DORA). This matters because it enhances cross-border information sharing and cooperation during incidents like cyber-attacks, reducing regulatory duplication while bolstering financial stability and operational resilience for firms reliant on these providers.
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What Changed
Establishes a framework for timely information sharing, coordination of oversight activities, and joint responses to incidents affecting CTPs/CTPPs, including power outages or cyber-attacks.
Defines principles for cooperation on mutually designated CTPs/CTPPs, including notifications of investigations and best endeavors to share material information where legally and operationally feasible.
Complements the UK's CTP regime (effective 1 January 2025), which requires designated CTPs to provide regu
What You Need To Do
For CTPs/CTPPs
For financial firms/FMIs
Regulators' internal actions
Firms should review contracts with third parties for compliance alignment and conduct gap analyses against CTP requirements
Key Dates
1 January 2025UK CTP rules came into effect, applying to CTPs designated by HMT.
Ongoing (process begun pre-2025)HMT designation process for CTPs, with regulators recommending based on concentration and materiality criteria; no fixed end date specified.
DORA effective date (prior context)EU CTPPs oversight under DORA aligns with UK regime; MoU signed to ensure compatibility (exact DORA timeline not in publication but supports post-2024 implementation).
Compliance Impact
Urgency: High – The MoU operationalizes the live UK CTP regime (effective January 2025), with designations underway, amplifying risks of non-compliance for firms using critical ICT providers amid rising cyber and resilience threats. It matters for cross-border firms as it enables regulator-to-regula
The Financial Conduct Authority, Bank of England and Prudential Regulation Authority (UK regulators) have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.
ESMA’s Digital and Data strategies support supervision of EU financial markets 13 January 2026 About ESMA Market data Press Releases The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has adopted a new Digital Strategy and updated its Data Strategy . They reflect ESMA’s commitment to smarter regulatory reporting and technology-driven supervision, promote synergies and innovation while reducing unnecessary complexity. The digital strategy...
In new guidance, the Swiss Financial Market Supervisory Authority FINMA explains how it assesses the risks associated with the custody of cryptobased assets. The guidance sets out the rules that institutions must abide by in order to keep cryptobased assets safe.
Principles for risk-based supervision: a critical pillar for ESMA’s simplification and burden reduction efforts 09 January 2026 Supervision The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, published today its principles for risk-based supervision . These principles support a common and effective EU-wide supervisory culture and strengthen the EU single market. The principles on risk-based supervision outline key concepts and foundationa...
On 12 November the PRA hosted a roundtable meeting with Chief Financial Officers (CFOs) of systemically important firms operating in the UK, to discuss Future Banking Data (FBD).
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
The 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
ESMA publishes latest Spotlight on Markets newsletter featuring updates on market integration and transparency 23 December 2025 ESMA newsletter The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has today published the latest edition of its Spotlight on Markets newsletter. This edition opens with ESMA welcoming the European Commission’s ambitious proposal on market integration, underlining the importance of deeper, more integrated and ef...
AI Analysis
ESMA's latest *Spotlight on Markets* newsletter (November/December 2025 issue, published 23 December 2025) summarizes key regulatory updates on EU market integration, transparency enhancements, and supervisory actions, including welcoming the European Commission's market integration proposal and announcing an equity consolidated tape provider (CTP) selection. This matters for compliance professionals as it signals accelerating EU efforts to deepen capital markets integration, improve data transparency, and strengthen oversight under MiFID II and DORA, potentially requiring firms to adapt governance, reporting, and conflict management practices.
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What Changed
ESMA welcomes the European Commission's 4 December 2025 legislative package on market integration, emphasizing robust governance and market infrastructure for deeper EU capital markets.
Announcement of selected applicant for the equity consolidated tape provider (CTP), advancing MiFIR transparency for equity markets by improving post-trade data consolidation and access.
Publication of ESMA's final report on Regulatory Technical Standards (RTS) for non-equity transparency, clarifying pre- and pos
What You Need To Do
Review the final non-equity transparency RTS and assess impacts on trading and reporting systems for compliance by any upcoming application dates (not specified)
Evaluate MiFID II conflicts of interest policies in preparation for the CSA; conduct internal audits and enhance training/staff attestations on identification and mitigation
Monitor equity CTP rollout for changes to post-trade data access and costs; update vendor contracts if applicable
For DORA-impacted firms, map exposures to designated critical ICT providers and strengthen due diligence, contractual clauses, and exit strategies
Asset managers
Key Dates
4 December 2025- European Commission publishes market integration legislative package; legislative process expected to take at least one year.
23 December 2025- Newsletter publication date.
Compliance Impact
Urgency: Medium - The newsletter highlights finalized standards (e.g., RTS, CTP) and imminent actions (e.g., CSA, DORA designations) that require proactive preparation, but lacks hard deadlines or immediate mandates. It matters because it previews intensified supervision on transparency, conflicts,
The Bank's Court of Directors acts as a unitary board, setting the organisation's strategy and budget and taking key decisions on resourcing and appointments. Required to meet a minimum seven times per year, it has five executive members from the Bank and up to nine non-executive members.
Update of Circular CSSF 24/850 on the practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS, as well as the engagement of the réviseurs d’entreprises agréés (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
AI Analysis
Circular CSSF 25/903 updates Circular CSSF 24/850, refining practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg regarding their annual descriptive report, self-assessment questionnaire, and the roles of approved statutory auditors (réviseurs d’entreprises agréés). It specifies requirements for auditors' engagement, management letters, and separate annual reports. This matters for support PFS as it enhances supervisory oversight, ensures consistent reporting quality, and strengthens internal controls, directly impacting compliance and audit processes amid CSSF's focus on robust PFS supervision.
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What Changed
Updates to Descriptive Report and Self-Assessment Questionnaire: Refines content, format, and submission requirements for support PFS's annual submissions, emphasizing more detailed disclosures on operations, risks, and controls (building on CSSF 24/850).
Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for reviewing support PFS reports.
Management Letter
What You Need To Do
*Review and Update Processes
*Engage/Confirm Auditors
*Implement Templates and Testing
*Training and Governance
*Submit on Time
Key Dates
1 January 2026 - Effective DateApplies to annual reporting cycles starting for financial year 2025 onwards.
30 April (annually) - Submission DeadlineSupport PFS must submit descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF by 30 April following the financial year-end (first applicable: 30 April 2026 for FY 2025).DEADLINE
31 December 2025 - Preparation MilestoneAuditors must be engaged and initial scoping completed by year-end 2025 for FY 2025 compliance.DEADLINE
Compliance Impact
Urgency: High. This is high urgency for support PFS due to the impending 30 April 2026 deadline for FY 2025 submissions, with non-compliance risking supervisory fines, license reviews, or reputational damage under CSSF's PFS enforcement regime. It matters as it tightens audit accountability, potenti
Practical rules concerning the descriptive report and the self-assessment questionnaire to be submitted on an annual basis by support PFS.Engagement of the réviseurs d’entreprises agréés (approved statutory auditors) of support PFS and practical rules concerning the management letter and the separate report to be drawn up on an annual basis.
AI Analysis
Circular CSSF 24/850, as amended by Circular CSSF 25/903, establishes practical rules for support Professional of the Financial Sector (support PFS) in Luxembourg to submit annual descriptive reports and self-assessment questionnaires, while also defining the roles of approved statutory auditors (réviseurs d’entreprises agréés) in issuing management letters and separate reports. This guidance standardizes supervisory reporting and audit processes to enhance oversight of support PFS, which provide essential back-office services to authorized PFS. It matters because non-compliance risks supervisory sanctions, reputational damage, and operational disruptions for entities reliant on support PFS structures.
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What Changed
Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management, internal controls, and operational metrics specific to support PFS activities (e.g., IT services, administrative support, custody).
Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separa
What You Need To Do
Annual Reporting Cycle
February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report
Governance Updates
Auditor Coordination
Record-Keeping
Key Dates
31 March annually- Deadline for submission of descriptive report, self-assessment questionnaire, management letter, and separate auditor report to CSSF (first applicable for FY 2024 reporting due 31 March 2025).DEADLINE
1 January 2025- Effective date of original Circular CSSF 24/850.
15 December 2025- Effective date of amendments in Circular CSSF 25/903, applicable to 2025 reporting cycle onwards.
End of February annually- Support PFS must engage auditors and provide necessary data to enable timely report preparation.DEADLINE
Compliance Impact
Urgency: High – This is a recurring annual obligation with a firm 31 March deadline, where delays trigger automatic CSSF notifications and potential fines (up to €250,000 per Law 1993). It matters for support PFS as it intensifies scrutiny on operational resilience in a post-SFI (2021) landscape, wh
MDD is projected to grow by just below 4 per cent in 2025. From 2026 to 2028, MDD is forecast to grow at an annual average rate of 2.9 per cent per annum. More positive momentum in MNE investment amid lower uncertainty contrasts with slower pace of growth in domestic sectors and cooling of the labour market as drag from capacity constraints becomes evident. Outlook for slightly higher overall inflation, as underlying services price growth more persistent at a higher rate than pre-pandemic. Th...
The CFTC approved a final rule on December 18, 2025, that codifies existing staff no-action positions and eliminates duplicative business conduct and documentation requirements for swap dealers and major swap participants. This rule resolves over a decade of regulatory uncertainty, reduces operational costs, and harmonizes CFTC requirements with SEC and Municipal Securities Rulemaking Board standards.
What Changed
The final rule introduces the following substantive amendments:
*Exceptions for Swaps Intended to be Cleared (ITBC Swaps)**
Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution. Such swaps are deemed void if rejected from clearing.
*Prime Broker Arrangement Exemptions**
Swaps executed purs
What You Need To Do
*Immediate Actions (Pre-Implementation)
*Implementation Actions (Upon Effective Date)
trade disclosure systems to remove PTMMM generation and delivery requirements
based operations, review implications of superseded Staff Letter No
*Ongoing Compliance
Key Dates
April 4, 2025- CFTC Staff Letter 25-09 issued, establishing no-action position on PTMMM requirement
September 12, 2025- CFTC issued further amended exemptive order permitting JSCC to clear interest rate swaps
September 24, 2025- CFTC issued Notice of Proposed Rulemaking (comment period opened)
October 24, 2025- Comment period deadline (ISDA and SIFMA submitted comments on this date)DEADLINE
December 18, 2025- CFTC approved final rule (subject to pre-publication technical corrections)
The Artificial Intelligence Consortium (AIC) aims to provide a platform for public-private engagement to further dialogue on the capabilities, development, deployment, use, and potential risks of artificial intelligence (AI) in UK financial services.
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
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
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 am 12. Dezember 2025 beschlossen, die Iran-Sanktionen dem Stand von vor dem Abschluss des Wiener Abkommens über das iranische Atomprogramm anzupassen. Dazu hat er die Verordnung über Massnahmen gegenüber der Islamischen Republik Iran einer Totalrevision unterzogen. Die neue Verordnung (SR 946.231.143.6) trat am 12. Dezember 2025 in Kraft.
AI Analysis
Switzerland has completely revised its Iran sanctions regulations effective December 12, 2025, restoring sanctions to pre-2015 levels following the automatic reinstatement of UN Security Council resolutions on September 28, 2025. This comprehensive overhaul requires Swiss financial institutions and businesses to immediately implement expanded asset freezes, trade restrictions, and sectoral prohibitions affecting Iran-related transactions and designated persons.
What Changed
The total revision introduces several critical regulatory shifts:
*Scope Expansion**: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803, 1835, 1929, and 2224) and aligns Swiss sanctions with EU measures reactivated on September 29, 2025.
*Sectoral Restrictions**: New measures in the raw materials sector have been introduced, complementing existing prohibitions on:
Sale or supply of key energy sector equipment
Gold, precious metals
What You Need To Do
*Immediate (Completed by December 12, 2025)
related transactions and accounts for compliance with expanded prohibitions
*Short-term (By January 1, 2026)
September 30, 2025 contracts under legacy exemption provisions
related transactions
Key Dates
September 28, 2025- UN Security Council resolutions automatically reinstated (snapback mechanism triggered)
September 29, 2025- EU reactivated suspended sanctions on Iran's proliferation activities
October 20, 2025- Swiss State Secretariat for Economic Affairs (SECO) updated SESAM sanctions database with reinstated listings
October 21, 2025- Updated sanctions list effective (23:00 UTC)
December 12, 2025- Complete revision of Iran sanctions ordinance (SR 946.231.143.6) entered into force (23:00 UTC)
Good evening. Thank you for the invitation to join you today. This evening I want to talk about economic resilience, what it is and whether we have enough of it. I spoke about economic resilience in my first speech as Governor – 6 years ago – and wrote to the Minister for Finance about it in early February this year. After everything that’s happened since February, it feels timely to take stock of where we are. My conclusion is that we need to give it greater focus. Let me start by setting ou...
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 Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Operations Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
In line with the Bank's transition to a repo-led, demand-driven operational framework for providing reserves, the Bank is today announcing a reduction in the spread to Bank Rate of the Operational Standing Facility (OSF). This Market Notice confirms the new, recalibrated spread of the OSF at Bank Rate +15bps for the lending facility and Bank Rate -15bps for the deposit facility. As with all SMF facilities, the OSFs are 'open for business' and should be used by SMF participants for the purpose...
Good morning and welcome everyone. I am delighted to address the eighth meeting of this Forum. When the Forum was established three years ago, the goal was to bring together participants from across Ireland to build a shared approach to understanding and managing the systemic risks that climate change poses, while supporting the orderly transition of households and businesses to the net zero objective that we’re all familiar with. The Forum has come a long way in those three years. We have es...
The Central Bank of Ireland has today (5 December) launched a public consultation on the implementation of our new Access to Cash responsibilities. Deputy Governor Vasileios Madouros said: “Amid a rapidly evolving payments landscape, the Central Bank of Ireland is committed to making sure that cash continues to be readily available as a means of payment. Today’s consultation is an important step towards the implementation of the Central Bank’s new responsibilities under the Access to Cash leg...
AI Analysis
The Central Bank of Ireland has launched a public consultation on implementing new **Access to Cash** responsibilities under the Finance (Provision of Access to Cash Infrastructure) Act 2025, which commenced on 30 June 2025. This consultation addresses two critical areas: identifying local deficiencies in cash infrastructure and establishing minimum ATM service standards. The initiative reflects regulatory commitment to ensuring cash remains readily available as payment preferences shift toward digital channels.
What Changed
The consultation covers two primary regulatory components:
*1. Local Deficiency Guidelines**
The Central Bank will establish procedures for identifying geographical areas where individuals and SMEs face particular difficulties accessing cash, even where overall access-to-cash criteria are met. The guidelines will specify how the Central Bank receives notifications, undertakes assessments, and makes determinations regarding local deficiencies.
*2. ATM Service Standards and Operator Requirements
What You Need To Do
*For designated credit institutions
Monitor consultation developments and prepare for compliance with minimum cash infrastructure maintenance levels once regulations are finalized
Prepare to provide quarterly data on ATM numbers, locations, and availability hours
*For ATM operators
Engage with the consultation process to provide feedback on proposed service standards
Key Dates
5 December 2025 – 4 March 2026– Public consultation period for local deficiency guidelines and ATM service standards
30 June 2025– Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced
Early 2026– First publication of quarterly cash infrastructure data expected
30 June 2026– Central Bank to publish local deficiency guidelines
2026– Central Bank to publish final ATM service standards regulations
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.
The Bank of England (the Bank) has today launched its second system-wide exploratory scenario (SWES) exercise. This will focus on how the private markets ecosystem operates under stress and the potential implications for UK financial stability and the UK real economy.
CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.
What Changed
The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas:
*Reporting Framework Modifications
Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims.
Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency.
RBNS claims de
What You Need To Do
*Immediate Actions (January-February 2026)
*Review consultation paper
*Assess applicability
*Identify gaps
*Engage supervisory contacts
Key Dates
4 December 2025- PRA published CP22/25 consultation paper
31 December 2025- Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date
31 December 2025- Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date
55 business days after quarter-end- Deadline for quarterly QMC.01 submission (internal model firms)DEADLINE
100 business days after financial year-end- Deadline for annual AoC.01 submission (internal model firms and groups)DEADLINE
Our Financial Policy Committee (FPC) meets to identify risks to financial stability and agree policy actions aimed at safeguarding the resilience of the UK financial system.
Statistical Notices update the definitions and guidance contained in the Banking Statistics Yellow Folder
AI Analysis
The Bank of England's Statistical Notice 2025/05 requires all reporting institutions to confirm their confidentiality permissions for publishing aggregate statistical data during the 2026 reporting year. This mandatory review streamlines data publication processes by seeking prior consent for aggregate data where firms are among fewer than three contributors, reducing administrative burden while maintaining data integrity.
What Changed
The notice introduces a streamlined confidentiality permission framework with four consent options for reporting institutions:
1. Blanket consent – Give prior approval for all statistical forms
2. Form-by-form consent – Approve permissions on individual forms
3. Selective consent – Approve all forms except specified data points
4. Case-by-case opt-out – Require explicit consent for each publication instance
The material change is the Bank's shift toward pre-approval for aggregate data publicat
What You Need To Do
*Log into the BEEDS portal and access the confidentiality permission survey
*Select one of four consent options (blanket, form-by-form, selective, or case-by-case)
*For multi-entity groups
*Review prepopulated firm information and make adjustments as needed
*Submit final preferences via the portal (latest submission version is treated as final)
Key Dates
19 December 2025, 5:00 PM GMT– Deadline for completing confidentiality preference survey in BEEDS portalDEADLINE
January–December 2026– Reporting reference periods covered by granted permissions
Ongoing– Consent remains valid for these periods unless explicitly withdrawn; applies to resubmissions and late submissions for 2026 reference periods
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
The Swiss Financial Market Supervisory Authority FINMA is today publishing its ex-post evaluation report on the requirements for interest rate risk management in the banking book. The evaluation has shown that the supervisory practice has essentially been successful and that the objectives have been achieved. Specific improvements will be made as part of a partial revision of Circular 2019/2, which is planned from 2026. The interest rate shock scenarios updated by the Basel Committee on Banki...
The Bank of England welcomes the Financial Conduct Authority (FCA) recognition of the 2024 versions of the FX Global Code and UK Money Markets Code under its code recognition scheme.
In its new 2025 Risk Monitor, FINMA reveals where it sees the greatest risks for the Swiss financial centre. It warns of an increase in geopolitical and technological risks and calls for more robust controls over the outsourcing of critical functions. The climate risk report is also part of the Risk Monitor for the first time.
This was the first meeting of the Market Participants Group (MPG), a senior-level forum for financial market participants to share their views on relevant themes and narratives in financial markets with members of the Bank of England’s Monetary Policy Committee.
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
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
The Securities and Exchange Commission today issued an order granting temporary exemptive relief from certain compliance dates adopted under Regulation NMS: Minimum Pricing Increments, Access Fees and Transparency of Better Priced Orders as follows:…
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
The Bank's Court of Directors acts as a unitary board, setting the organisation's strategy and budget and taking key decisions on resourcing and appointments. Required to meet a minimum seven times per year, it has five executive members from the Bank and up to nine non-executive members.
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 im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) geändert.
AI Analysis
On October 29, 2025, the Swiss Federal Council (Bundesrat) adopted comprehensive sanctions measures aligned with the EU's 18th sanctions package against Russia and additional measures against Belarus, effective October 30, 2025. This enforcement action significantly expands financial transaction prohibitions, export restrictions, and asset freezes, requiring Swiss financial intermediaries to immediately implement new compliance obligations across banking, goods trade, and energy sectors.
What Changed
*Financial Sector Restrictions**
The Bundesrat expanded transaction prohibitions on Russian banks substantially:
Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions
Introduced new transaction prohibitions for 22 additional Russian banks
Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previou
What You Need To Do
*Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
*Freeze assets of all sanctioned persons and entities immediately upon notice
*Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
*Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
*Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy
Key Dates
October 29, 2025- Federal Council decision adopted
October 30, 2025- Measures effective date
Ongoing- Financial intermediaries must implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs)DEADLINE
PS17/25 establishes the **Matching Adjustment Investment Accelerator (MAIA) framework**, enabling PRA-regulated insurers to regularize and expand their use of matching adjustment (MA) in calculating capital requirements for certain long-duration insurance liabilities. This framework is significant because it provides a structured pathway for firms to optimize capital efficiency while maintaining prudential safeguards through exposure limits, eligibility assessments, and breach remediation mechanisms.
What Changed
The MAIA framework introduces the following regulatory requirements:
*Permission and Eligibility Framework
Firms must obtain explicit MAIA permission** from the PRA to use the accelerator
Permission grants authority to regularize previously non-compliant MA assets and apply MA to new eligible assets within defined parameters
*Exposure Limits
Firms receive fixed monetary exposure limits** calibrated using the Best Estimate of Liabilities (BEL) of the MA portfolio, net of reinsurance, at the tim
What You Need To Do
*Immediate (Q4 2025 - Q1 2026)
*Assess eligibility for MAIA permission by reviewing current MA portfolio and prospective assets
Publication from the Bank, PRA and FCA to firms and financial market infrastructures highlighting observed effective practices of cyber response and recovery capabilities.
PS16/25 is the PRA's policy statement restating firm-facing organisational requirements from the MiFID Org Reg (e.g., outsourcing, record-keeping, risk management, compliance, internal audit, and governance) into the PRA Rulebook, with no material changes, to align with HMT's revocation of the EU regulation under FSMA 2023. This matters because it ensures continuity of prudential oversight for PRA-authorised firms post-revocation, preventing enforcement gaps in systems and controls while adapting provisions (e.g., supervisory function) to UK governance structures.
#
What Changed
Restatement of requirements: Provisions from MiFID Org Reg Articles on outsourcing, record-keeping, control procedures, risk management, compliance, internal audit, and governance are transferred verbatim or with minor clarifications into PRA Rulebook parts (e.g., Risk Control).
Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving board-level oversight
What You Need To Do
Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e
Confirm governing body oversight aligns with adapted Article 25 requirements; document any adjustments for UK structures
Update internal references in algorithmic trading governance documents to new rule 2
Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable
Monitor HMT commencement order; if delayed, reassess implementation plans
Key Dates
9 October 2025- PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation.
23 October 2025- New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date).
Prior to 23 October 2025- HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made.
Compliance Impact
Urgency: High – Firms must act promptly as rules take effect on 23 October 2025 (past deadline as of current date), with no transition period; non-compliance risks enforcement gaps in core systems/controls post-revocation. Impact is low for substance (restatement only) but requires documentation upd
The Swiss Financial Market Supervisory Authority FINMA today published guidance on the extension of the transitional period for exchange of collateral in certain OTC derivatives transactions. The current transitional period runs until 1 January 2026 and will be extended by a further three years.
AI Analysis
FINMA extended the transitional period for collateral exchange requirements in non-centrally cleared OTC derivatives from January 1, 2026 to January 1, 2029, providing Swiss market participants with three additional years of relief from mandatory collateral posting obligations on certain equity derivatives. This extension aligns Swiss regulation with the EU's indefinite exemption introduced in December 2024, preventing competitive disadvantages for Swiss derivatives traders while a permanent regulatory framework is developed.
What Changed
The primary regulatory change is the extension of the transitional period under Article 131 paragraph 5bis of the Financial Market Infrastructure Ordinance (FinMIO). Specifically:
Previous deadline: January 1, 2026
New deadline: January 1, 2029
Scope: Applies to non-centrally cleared OTC derivatives transactions involving equity options, index options, and equity basket derivatives that are not cleared through a FINMA-authorized or recognized central counterparty
Regulatory basis: FINMA Guidanc
What You Need To Do
*Acknowledge the extended timeline
*Maintain risk management controls
*Monitor FinMIA revision
*Document compliance rationale
*Assess competitive positioning
Key Dates
October 9, 2025- FINMA Guidance 04/2025 published and takes effect immediately
January 1, 2029- New expiration date for the transitional period; collateral exchange obligations become mandatory unless further extended or a permanent framework is adopted
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC), which is a forum for discussion of the wholesale foreign exchange market. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Operations Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
Our Financial Policy Committee (FPC) meets to identify risks to financial stability and agree policy actions aimed at safeguarding the resilience of the UK financial system.
Stress-testing Markets Asset management Journalists Investment services providers Investment management companies The Banque de France, the ACPR and the AMF launch a first system-wide stress test on interconnections within the financial system
The PRA Regulatory Digest is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
The Securities and Exchange Commission today issued an order granting conditional exemptive relief related to certain requirements of the National Market System Plan governing the Consolidated Audit Trail (CAT NMS Plan), Rule 613 of Regulation NMS, and…
PS15/25 introduces **new liquidity risk reporting requirements for major UK insurance firms**, closing data gaps identified during the March 2020 "dash for cash" and September 2022 LDI crisis. The policy mandates four new reporting templates for firms with significant derivatives or securities lending exposure, with implementation deferred to **30 September 2026** to allow adequate preparation time.
What Changed
The PRA's final policy establishes the following regulatory framework:
*New Reporting Templates**
Four new liquidity reporting templates have been introduced to capture previously unavailable data:
Annual committed facilities template
Monthly cash-flow mismatch template (short form)
Monthly cash-flow mismatch template for ring-fenced funds, matching adjustment portfolios, and remaining parts
Additional supervisory reporting requirements
*Scope and Thresholds
Firms are subject to liquidity repo
What You Need To Do
*Immediate Actions (by Q2 2026)
*Threshold Assessment
*RFF Mapping
*System Readiness
*Data Governance
Key Dates
30 September 2025- PRA published PS15/25 (policy statement)
31 December 2025- Original implementation deadline (now superseded)DEADLINE
30 September 2026- **Final implementation date for all liquidity reporting requirements**
First reporting reference date after 30 September 2026- Firms meeting threshold conditions must commence reportingDEADLINE
Three consecutive annual reporting reference dates- Threshold for ceasing reporting once firms fall below thresholds
The Swiss Financial Market Supervisory Authority FINMA has identified further progress in UBS’s resolvability and continues to view a resolution as feasible. However, there is a need for greater optionality, which will also require legislative changes. UBS’s emergency plan largely fulfils the current statutory requirements. However, it needs to be better integrated in the resolution plan in the future and thus cannot currently be regarded as executable. As in 2024, FINMA’s review of the recov...
The Securities and Exchange Commission today announced that Ken Johnson, who has been serving as Chief Operating Officer (COO) since December 2017, will retire from the agency in December. “Ken has been an integral leader at the SEC for more than two…
Warning Identity theft The Autorité des marchés financiers (AMF) is warning professionals about the extensive fraudulent and malicious use of its name engaging people into running a malicious computer program.
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...
The Swiss Financial Market Supervisory Authority FINMA has completed its annual assessment of the emergency and recovery plans for the domestic systemically important banks. The emergency plans for Zürcher Kantonalbank and Raiffeisen fulfil the regulatory requirements. The emergency plan for PostFinance is still not ready to implement. The recovery plans for all institutions were approved.
Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 11. November 2015 über Massnahmen gegenüber der Islamischen Republik Iran (SR 946.231.143.6) publiziert.
AI Analysis
On August 18, 2025, the Swiss State Secretariat for Economic Affairs (WBF) published an updated sanctions notification regarding Iran, specifically modifying Annex 7 of the Ordinance on Measures against the Islamic Republic of Iran (SR 946.231.143.6). This update is critical for Swiss financial institutions and businesses because it reflects the evolving sanctions landscape following the automatic reinstatement of UN Security Council resolutions on Iran's nuclear program in September 2025.
What Changed
The August 2025 notification updated the list of designated persons, entities, and organizations subject to Swiss sanctions against Iran. While the search results do not provide the specific details of individual entries added or removed from Annex 7, this type of notification typically reflects changes to the UN Security Council's consolidated sanctions list that Switzerland is obligated to implement under its Embargo Act (EmbG).
The broader context shows that Switzerland was preparing for sig
What You Need To Do
*Immediate compliance obligations
*Sanctions List Screening
*Transaction Review
*Account Monitoring
*Policy Updates
Key Dates
August 18, 2025- WBF published updated sanctions notification for Iran (Annex 7 modifications)
August 28, 2025- Germany, France, and UK triggered UN snapback mechanism
September 15, 2025- Harmonization of sanctions ordinances entered into force (affecting financial sanctions procedures across multiple jurisdictions including Iran)
September 27, 2025- UN nuclear-related sanctions against Iran automatically reinstated
September 28, 2025- EU reactivated suspended sanctions related to Iran's proliferation activities
Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs der Verordnung vom 7. August 1990 über Wirtschaftsmassnahmen gegenüber der Republik Irak (SR 946.206) publiziert.
AI Analysis
The Swiss State Secretariat for Economic Affairs (SECO) published an updated sanctions notification on August 13, 2025, reflecting modifications to the UN sanctions list targeting Iraq under the Ordinance of August 7, 1990 (SR 946.206). This update is automatically applicable in Switzerland and requires immediate compliance by all financial institutions and regulated entities, as Switzerland implements UN Security Council sanctions lists without delay through its automatic application framework.
What Changed
The UN Sanctions Committee modified the list of sanctioned individuals, companies, and organizations subject to Iraq-related sanctions on August 5, 2025. The specific modifications to the sanctions list were incorporated into Switzerland's SESAM database (SECO Sanctions Management), which serves as the authoritative sanctions reference for Swiss compliance purposes. Under Switzerland's automatic application ordinance adopted by the Federal Council on March 4, 2016, amendments to UN Security Coun
What You Need To Do
*Update screening systems immediately - Integrate the August 5, 2025 modifications into transaction monitoring and customer due diligence systems
*Review existing customer relationships - Screen all current customers, counterparties, and beneficial owners against the updated SESAM database
*Audit transaction history - Identify any transactions processed between August 5-13, 2025 that may have involved newly sanctioned parties
*Document compliance procedures - Maintain records demonstrating implementation of updated sanctions screening
*Train compliance staff - Ensure all relevant personnel understand the updated sanctions list and screening requirements
Key Dates
August 5, 2025- UN Sanctions Committee decision modifying the Iraq sanctions list
August 13, 2025- SECO published the updated sanctions notification and SESAM database modifications
Immediate- Effective date in Switzerland (automatic application upon UN modification)
On 3 July 2025, the Swiss Financial Market Supervisory Authority FINMA launched the consultations on the new Ordinances on the Risk Diversification of Banks and Securities Firms and on the Liquidity of Banks and Securities Firms. The consultations will go on until 29 September 2025.
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
Europe & international Innovation Financial services providers Operational resilience – The AMF applies the Joint Guidelines on the oversight cooperation and information exchange under the Digital Operational Resilience Act (DORA)
Regulatory developments Post-trading infrastructures Market infrastructures Cooperation Journalists AMF and Banque de France call for a well-anticipated move to T+1 Settlement Cycle
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
Warning Identity theft Savings protection Warning The Autorité des marchés financiers (AMF) is warning professionals about the extensive fraudulent and malicious use of its name, with links to various websites that could trick people into running a malicious computer program
Supervision Asset management Journalists Investment management companies The AMF publishes summary of third thematic inspection of asset management companies' cybersecurity systems
Marketing Savings protection Retail investors Professional investors Journalists The ACPR and AMF encourage financial institutions to continue their efforts to take account of the vulnerability of ageing clients
Supervision Asset management Journalists Investment management companies The AMF examines the systems for valuation of the less liquid assets of UCITS and AIFs
Regulatory developments Post-trading infrastructures Market infrastructures Central counterparties’ recovery plan: AMF complies with ESMA guidelines on recovery plan indicators and scenarios
Savings protection Marketing Marketing of financial products to ageing populations: publication of an independent academic research report on customer relations and sales processes
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 imposed a €150,000 fine on **Inocap Gestion**, a portfolio asset management company, for multiple operational and compliance failures between 2022 and the enforcement decision date. This case demonstrates the AMF's enforcement priorities around liquidity risk management, market abuse detection systems, and anti-money laundering (AML/CFT) procedures—critical control areas that asset managers must operationalize effectively to avoid substantial penalties.
What Changed
The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations for existing obligations:
Liquidity Risk Management: Asset managers must establish procedures that are both adequate in design and operational in practice, not merely documented
Market Abuse Detection Systems: Surveillance systems must specify conditions for participation in market surveys and establish clear consequences for non-compliance
AML/CFT Procedures: Risk mapping and client onboar
What You Need To Do
assessments across these areas
*Liquidity Risk Management
*Market Abuse Detection
*AML/CFT Compliance
*Compliance Monitoring
Key Dates
21 December 2022- Enforcement Committee decision date against Inocap Gestion
No specific implementation deadline stated- The decision addresses historical breaches; however, firms should immediately remediate similar deficiencies
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
Short selling Equity Financial Crisis Executive & other private individuals Market Infrastructures Post-trade Infrastructures Professional investors Journalists French and Dutch market authorities publish a joint analysis of the...
Warning Covid-19 Savings protection Financial Scams The AMF and the ACPR warn the public of the risks of scams in the context of the coronavirus epidemic
Warning Savings protection The Autorité des Marchés Financiers (AMF) warns about persons using its name and logo and impersonating the Ombudsman and her deputy
Warning Savings protection Warning The Autorité des Marchés Financiers (AMF) warns the public about the activities of individuals claiming to work for the AMF