BPS Financial to pay $14 million in penalties over crypto Qoin Wallet
Crypto ExchangeFintechPayment Provider
Weโre working closely with the Office of Financial Sanctions Implementation (OFSI), UK law enforcement, and our regulatory partners to tackle the abuse of cryptoassets and associated moneyโlaundering activities. Read the full blog on the OFSIโs website.
Crypto ExchangeFintechPayment Provider On 21 January 2026, Guavapay Limited entered compulsory liquidation. The Official Receiver, an officer of the Insolvency Service, is its liquidator. Guavapay is authorised by the FCA to issue E-money and provide payment services to its customers.On 17 September 2025, Guavapay agreed to a voluntary requirement with the FCA, restricting the activities it can undertake. See details on the Financial Services Register.As liquidator, The Official Receiver is responsible for:Managing customer claims...
Payment Provider
FINRA publishes Notices to provide firms with timely information on a variety of issues.ย To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerFintechAll Firms
Good and poor practice
The FCA's guidance outlines good and poor practices in communicating costs for international money remittance and cross-border payments involving currency conversion, emphasizing transparency under the Consumer Duty to enable informed consumer decisions. It matters because non-compliance risks supervisory action, as the FCA plans future reviews to assess improvements, raising the bar on pricing clarity amid ongoing Duty enforcement.
#
What Changed
This is not new rulemaking but illustrative guidance applying existing Consumer Duty rules from FG 22/5 and PRIN 2A.5.3R, which mandate communications that are clear, fair, not misleading, meet retail customers' information needs, are understandable, and support effective decisions. Key emphases include pre-transaction disclosure of: amount remitted (GBP), applied exchange rate (explaining markups as consumer costs), recipient amount (local currency), variable/fixed fees, total fees, and interme
What You Need To Do
- Review and update pre-transaction communications (e
- Ensure markups are framed as consumer costs, not obscured (e
- Monitor communication effectiveness regularly under Consumer Duty to confirm good outcomes, enabling cost comparisons and informed choices
- Apply principles to all channels; proactively disclose fee variability and third-party impacts
Key Dates
31 July 2023 - Consumer Duty effective date for new and existing products/services.
1 May 2025 - FCA publication date of this good/poor practice guidance.
Compliance Impact
Urgency: High โ Consumer Duty is live since 2023, but this 2025 guidance signals intensified FCA scrutiny on payments transparency, with planned follow-up work and engagement to enforce improvements. Firms risk remediation demands or enforcement if disclosures remain inadequate, especially as it tar
Payment ProviderBankFintech
Consultation papers
FCA PS25/19 finalizes rules to streamline complaints reporting by replacing multiple existing returns with a single consolidated return, enhancing data quality, consistency, and vulnerability identification while reducing burdens. This matters for compliance teams as it mandates system and process updates to improve regulatory oversight and consumer protection, with implementation required within 12 months.
#
What Changed
Consolidated complaints return: Replaces five existing returns (DISP 1 Annex 1, Consumer Credit Return (CCR), Funeral Plans (FP), Claims Management Companies (CMCs), and Electronic Money and Payment Services Return (PSR)) with one unified return to reduce duplication and improve comparability.
Permission-based reporting: Firms report only sections relevant to their regulated permissions, targeting reporting to specific activities.
Simplified nil returns: Proportionate approach allows upfront sel
What You Need To Do
- Review and update internal complaints recording, categorization, and reporting systems to align with new consolidated return, taxonomy, permission-based sections, and vulnerability data points
- Eliminate group-level aggregation; implement entity-level reporting
- Integrate FCA Vulnerability Guidance into complaints processes for identification and reporting
- Test and prepare for fixed 6-monthly submissions via FCA systems; complete nil return simplifications where applicable
- For Retail Banking, Insurance, Payment Services, and CMCs: Retain and adapt contextualised data capture
Key Dates
2025 Consultation opened.[User Query]
2025 Consultation closed.[User Query]
2025 Policy Statement PS25/19 published, with 12-month implementation period starting.
2026 Feedback deadline on Chapter 4 questions (email to FCA). DEADLINE
2027 30/06/2027 - First reporting period under new process.
Compliance Impact
Urgency: High โ With publication on 3 Dec 2025 and a 12-month implementation window (to ~Dec 2026), firms must prioritize system changes now, as the first period starts 1 Jan 2027; non-compliance risks enforcement, especially on vulnerability reporting and transparency, amid FCA's focus on consumer
BankInsurancePayment Provider Consultation papers
CP25/15 proposes prudential rules and guidance for UK firms issuing **qualifying stablecoins** and safeguarding **qualifying cryptoassets**, aiming to foster a safe, competitive crypto sector while prioritizing consumer protection and market integrity. This matters for compliance professionals as it introduces tailored prudential sourcebooks (COREPRU and CRYPTOPRU) to mitigate firm failure risks, aligning with the FCA's crypto roadmap and Treasury's statutory plans.
#
What Changed
Prudential Sourcebooks: Introduces COREPRU (core requirements across sectors) and CRYPTOPRU (crypto-specific calibrations) for "CRYPTOPRU firms" handling regulated crypto activities, covering own funds adequacy, capital resources, and stress-adjusted internal capital assessments.
Own Funds and Capital Rules: Firms must hold financial resources adequate in amount and quality, including adjustments for valuation uncertainty, stress realizable values, and interim profits in CET1 capital; supplement
What You Need To Do
- Respond to Consultation
- Assess Applicability
- Prepare Prudential Frameworks
- Engage on Related CPs
- Data and Reporting Readiness
Key Dates
28/05/2025 - Consultation opens and CP first published.
31/07/2025 - Consultation closes; submit feedback via online form, email ([emailย protected]), or post.
Post-31/07/2025 - FCA considers feedback and publishes final rules (no specific date given).
Q3 2025 - Upcoming Conduct and Firm Standards CP affecting all cryptoasset firms, including QS issuers and custodians.
Future (CP2 per Roadmap) - Consultation on remaining prudential sourcebook requirements.
Compliance Impact
Urgency: High โ As of January 2026, the consultation closed over five months ago, signaling imminent final rules that could reshape prudential requirements for crypto firms; non-compliance risks authorization barriers, enforcement, or market exclusion in a regime prioritizing stability amid global c
FintechCrypto ExchangePayment Provider
SAMA Licenses โTabby financeโ Company to Engage in BNPL Activity
FintechPayment Provider
SAMA Licenses โDarb Pay for Information Technologyโ to Provide Payment Services
Payment Provider
SAMA Seeks Public Consultation on the Draft Update to the โOversight Framework for Payment Systems and Their Operatorsโ
Payment Provider
SAMA Revokes the License of โFas Finance Companyโ
BankFintech
SAMA Hosts BIS Innovation Summit
BankFintechCrypto Exchange
ASIC sues former Electro Optic Systems Holdings director and CEO Ben Greene for breach of directorโs duties
Broker DealerFintech
Defence systems manufacturer Electro Optic Systems Holdings admits to breaching continuous disclosure requirements
All Firms
No description available.
Financial disclosures & corporate financing Periodic & ongoing disclosures Reporting ESEF Closing of the 2025 accounts: the AMF flags up points for vigilance and issues recommendations
BankBroker DealerAsset Manager No description available.
BankWealth ManagerPayment Provider
We have issued a joint statement with the Payment Systems Regulator (PSR) giving clarity on open banking pricing models. We and the PSR have issued the following statement (PDF).This confirms we will not, at this stage, prioritise a Competition Act 1998 (CA98) investigation into the centralised โaccess feeโ pricing model being developed by the UK Payments Initiative (UKPI) for commercial Variable Recurring Payments (cVRPs). cVRPs are an emerging open banking technology that allow consumers to...
The FCA and PSR have jointly confirmed they will not prioritize a Competition Act 1998 investigation into the UK Payments Initiative's (UKPI) centralized access fee pricing model for commercial Variable Recurring Payments (cVRPs), with the CMA's concurrent agreement. This regulatory clarity provides temporary certainty for cVRP development ahead of anticipated legislation by end-2026, creating a critical window for firms to develop compliant commercial models in this emerging open banking technology.
What Changed
The regulatory statement establishes the following key positions:
Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase 1/Wave 1 cVRPs (limited to "lower risk" use cases).
Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services
What You Need To Do
- *For UKPI and participating firms
- *Governance documentation
- *Pricing methodology transparency
- *Phase 1/Wave 1 compliance
- *Market engagement
Key Dates
15 January 2026 - FCA and PSR wrote to CMA setting out their non-prioritization position
16 January 2026 - CMA confirmed alignment with FCA/PSR position on CA98 prioritization
20 January 2026 - Joint FCA/PSR statement issued on open banking pricing models
Q1 2026 - Expected first live UKPI cVRP payments
End of 2026 - Government anticipated to introduce legislative framework granting FCA new open banking powers
Compliance Impact
Urgency: HIGH
The FCA and PSR have issued a joint statement providing clarity on open banking pricing models, specifically regarding the centralised 'access fee' pricing model for commercial Variable Recurring Payments (cVRPs). This statement confirms that they will not prioritize a Competition Act 1998 investigation into this model at this stage. The goal is to support the development of cVRPs, giving consumers more control over their payments and lowering processing fees for businesses.
What Changed
The FCA and PSR have clarified their enforcement position on the UKPI's proposal for a commercial model for cVRPs, indicating they will not prioritize a Competition Act 1998 investigation at this stage.
What You Need To Do
- Monitor market developments and updates on the legislative framework for open banking
- Review and understand the implications of the centralised 'access fee' pricing model for cVRPs on your business operations
- Ensure compliance with existing competition laws and regulations
Key Dates
31 Dec 2026 Expected implementation of the government's legislative framework for open banking DEADLINE
1 Jul 2027 End of the temporary measure if the legislative framework is not implemented DEADLINE
Non-Compliance Risk
Enforcement action, fines, or other regulatory penalties for non-compliance with competition laws and regulations
Related Regulations
Competition Act 1998Payment Services Directive (PSD2)
Confidence: high
BankFintechPayment Provider No description available.
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.
#
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
Payment ProviderFintech
Central administration, internal governance and risk management
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.
#
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 deadline Institutions must assess, review, and ensure their central administration, internal governance, and risk management frameworks fully comply with the circular. DEADLINE
Compliance Impact
Urgency: High โ 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
Payment Provider
SAMA Updates Implementing Regulation of Finance Companies Control Law
BankFintechPayment Provider
SAMA Issues Fees Guide for Financial Institutionsโ Services
BankPayment Provider
SAMA Introduces Electronic Check Clearing System (ECCS) Service on its Website
BankFintechPayment Provider
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address bancosantander.es-kundenservice[at]outlook.com. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from Banco Santander S.A. This is a case of identity theft.
BankFintechPayment Provider
Central Bank of Ireland and Banca dโItalia are launching the Innovation Data Challenge 2026, a joint initiative designed to foster cutting-edge research and innovation in the retail payments sector. The Challenge reflects the shared commitment of the two Institutions to promoting applied research, international collaboration, and the responsible use of data and technology to shape the future of payments. The initiative brings together leading Irish and Italian universities, including Universi...
FintechPayment Provider
On 07 November 2025, the Federal Office of Justice (Bundesamt fรผr Justiz - BfJ) imposed a disciplinary fine amounting to 50.000 euros on pferdewetten.de AG.
The Federal Office of Justice (BfJ) imposed a โฌ50,000 disciplinary fine on pferdewetten.de AG on November 7, 2025, for violations related to the publication of financial reports under German securities law (WpHG - Wertpapierhandelsgesetz). This enforcement action underscores regulatory expectations for timely and accurate financial disclosure compliance, particularly for publicly traded or regulated entities in the gaming/betting sector.
#
What Changed
Based on the enforcement context, the regulatory requirements at issue involve:
Financial Reporting Obligations: Entities subject to WpHG must publish financial reports in accordance with statutory deadlines and content requirements
Disclosure Standards: Reports must meet quality and completeness standards established under German securities law
Enforcement Mechanism: The BfJ has authority to impose disciplinary fines for non-compliance with publication requirements
No Safe Harbor: Delayed or d
What You Need To Do
- *Audit Current Compliance
- *Strengthen Internal Controls
- *Document Procedures
- *Monitor Deadlines
- *Legal Review
Key Dates
November 7, 2025 - BfJ imposed โฌ50,000 disciplinary fine on pferdewetten.de AG
January 15, 2026 - BaFin published enforcement action notice
Ongoing - WpHG financial reporting obligations remain in effect with no stated grace period modifications
Compliance Impact
Urgency Rating: HIGH
All Firms
According to information available to the Federal Financial Supervisory Authority (BaFin), unknown persons are using WhatsApp groups and chats to contact German investors. The initiators of these WhatsApp groups purport to be the US company โPayden & Rygelโ. This is a case of identity theft misusing the names of real employees.
BankFintechPayment Provider
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 UKโs 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 EUโs Digital Operational Resilience Act (DORA), including du...
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.
#
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 2025 UK 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 โ 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
BankPayment ProviderAll Firms
Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung WBF hat รnderungen der Verordnung vom 4. Mรคrz 2022 รผber Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
The Swiss Federal Department for Economic Affairs, Education and Research (WBF) has published updates to the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions with ongoing international restrictions targeting Russia. This matters for Swiss financial institutions as it reinforces asset freezing and economic resource restrictions, heightening compliance risks amid prolonged geopolitical tensions, with the ordinance valid until at least November 2026.
#
What Changed
The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibit
What You Need To Do
- Block prohibited activities in energy sector, financial services (e
- Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11)
- Monitor FINMA's sanctions page for full ordinance text and related guidance
Key Dates
January 13, 2026 - Publication of amendments by WBF, triggering immediate review obligations.
Various historical dates (e.g., March 25, 2022 at 23:00; January 25, 2023 at 18:00) - Prior amendment effective dates, illustrating pattern of rapid implementation.
November 22, 2026 - Current expiry of ordinance (subject to extension).
Compliance Impact
Urgency: High - Ongoing amendments to this long-standing ordinance (active since 2022) demand immediate screening and blocking to avoid FINMA enforcement, fines, or reputational damage, especially with crypto and energy sector expansions capturing evolving risks. Non-compliance risks asset release v
BankPayment ProviderCrypto Exchange No description available.
This CSSF publication, dated January 12, 2026, identifies the specific population (likely a firm or individual) subject to an enforcement action, such as an administrative sanction, as part of the CSSF's transparency in supervisory measures. It matters because it signals CSSF's active enforcement priorities, potentially in areas like AML or reporting failures, enabling firms to assess similar risks in their operations and strengthen compliance to avoid parallel actions. Published amid rising focus on financial crime typologies like sexual extortion, it underscores the regulator's commitment to public accountability.
#
What Changed
No new regulatory changes or requirements are introduced in this publication, as it is an enforcement notice rather than a circular or guideline. It serves as a disclosure of an ongoing or concluded enforcement case, aligning with CSSF's practice of publishing sanction details to deter non-compliance and inform the market, without altering existing rules.
#
What You Need To Do
- For the named population
- For all supervised firms
- Update internal policies, train staff on enforcement precedents, and ensure robust reporting under Circular CSSF 19/726 or Transparency Law obligations
Compliance Impact
Urgency: High โ Immediate relevance for the named party facing direct consequences; medium-to-high for peers due to CSSF's pattern of public enforcements signaling heightened scrutiny on financial crime, especially amid rising OCSE/FSEC cases noted in recent CSSF guidance. It matters as it could pre
BankPayment ProviderAll Firms
The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address wise[at]wisefestgeldkonto(.)com. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from Wise Europe SA. This is a case of identity theft.
BankFintechPayment Provider
Survey on the amount of covered deposits held on 31 December 2025
Circular CSSF-CPDI 25/49 is a **mandatory quarterly reporting requirement** for Luxembourg credit institutions and postal financial service providers to submit data on covered deposits as of December 31, 2025. This survey directly feeds into the Single Resolution Fund's annual target level calculation and the Luxembourg deposit guarantee scheme's contribution assessments, making it essential for regulatory compliance and fund management.
What Changed
The circular explicitly states that no substantive changes have been made to the survey process compared to previous quarters. The only modifications are administrative: the reference date (December 31, 2025) and the submission deadline (January 30, 2026). The specifications for data collection, definitions of covered and eligible deposits, and reporting methodologies remain unchanged from prior circulars, particularly Circular CSSF-CPDI 16/02 as amended by Circular CSSF-CPDI 23/35.
What You Need To Do
- *Calculate covered deposits as defined in Article 163 of the 2015 law, including balance and accrued interest (even if not yet due)
- *Report eligible deposits after applying exclusions under Article 172 of the 2015 law, including exclusions for financial institutions and life insurance products
- *Distinguish deposit types by reporting
- Total eligible deposits (field 201)
- Eligible deposits in omnibus accounts, fiduciary accounts, trusts, sub-accounts, and segregated accounts (field 0226)
Key Dates
January 30, 2026 - Deadline for transmitting average covered deposits data to the Single Resolution Board DEADLINE
December 31, 2025 - Reference date for the survey
December 24, 2025 - Circular publication date
Compliance Impact
Urgency: HIGH
BankPayment Provider
No description available.
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.
#
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 โ 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
Crypto ExchangeBroker DealerBank People could find it easier to pay using contactless, thanks to greater flexibility and the removal of red tape by the FCA. Banks and payment providers with strong fraud controls will be able to set their own limit for contactless payments, allowing them to better respond to changing consumer demands, inflation and new technology. They are also being encouraged to let customers set their own limit, or turn contactless off altogether, as many high street banks already do. People are using cont...
BankPayment Provider
Open banking in the UK is growing rapidly. Latest industry figures show there are more than 16 million users now benefiting from the service. The number of open banking payments has soared by 53% year on year, reflecting a significant shift in how consumers and businesses manage their finances.See the API performance statsA key driver of this transformation is the rise of variable recurring payments (VRPs), which now account for 16% of all open banking transactions. VRPs allow consumers and b...
BankFintechPayment Provider
Der Bundesrat hat am 12. Dezember 2025 beschlossen, die Iran-Sanktionen dem Stand von vor dem Abschluss des Wiener Abkommens รผber das iranische Atomprogramm anzupassen. Dazu hat er die Verordnung รผber Massnahmen gegenรผber der Islamischen Republik Iran einer Totalrevision unterzogen. Die neue Verordnung (SR 946.231.143.6) trat am 12. Dezember 2025 in Kraft.
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)
Compliance Impact
Urgency: CRITICAL
BankPayment ProviderAll Firms
Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 รผber Massnahmen gegenรผber Sudan (SR 946.231.18) geรคndert.
On December 9, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 2 of the Sudan Sanctions Ordinance (SR 946.231.18), requiring Swiss financial intermediaries to implement changes to their sanctions screening and compliance procedures. This update reflects ongoing international coordination on Sudan sanctions enforcement and requires immediate implementation by all Swiss-regulated financial institutions.
What Changed
The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries.
The timing of this update aligns with broader international sanctions activity on Sudan. In July 2025,
What You Need To Do
- *Sanctions List Update
- *System Screening
- *Transaction Review
- *Blocked Assets
- *Staff Training
Key Dates
December 9, 2025, 23:00 UTC - Effective date of the urgent amendment to Annex 2 of SR 946.231.18; SECO updated the SESAM database on this date
Immediate - Financial intermediaries required to implement changes according to SR 946.231.18 regulations DEADLINE
Compliance Impact
Urgency: CRITICAL
BankPayment ProviderWealth Manager
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.
BankBroker DealerPayment Provider
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. 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), 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.
BankBroker DealerPayment Provider
In this blog, Governor Gabriel Makhlouf writes about the development of the Digital Euro and how central banks foster trust and safety in the financial system and in the implementation of projects like the Digital Euro.
BankFintechCrypto Exchange
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: โAmid 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. Todayโs consultation is an important step towards the implementation of the Central Bankโs new responsibilities under the Access to Cash leg...
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 โ 4 March 2026 โ Public consultation period for local deficiency guidelines and ATM service standards
30 June 2025 โ Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced
Early 2026 โ First publication of quarterly cash infrastructure data expected
30 June 2026 โ Central Bank to publish local deficiency guidelines
2026 โ Central Bank to publish final ATM service standards regulations
Compliance Impact
Urgency: HIGH
BankPayment Provider
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.
BankBroker DealerPayment Provider
Consultation paper 23/25
This joint PRA-FCA consultation (CP23/25 from PRA and Chapter 4 of FCA's CP25/33) proposes policy updates to regulatory fees, levies, and invoice processes for 2026/27, including new fee blocks for emerging activities like PISCES operators and targeted support, alongside adjustments to FOS/FSCS levies and payment timelines. It matters for compliance teams as it directly impacts budgeting, fee calculations, and cash flow management for fee-payers, with potential cost increases and procedural changes effective from April 2026.
#
What Changed
New fee structures: Introduction of a periodic fee block for PISCES operators based on regulated income (baseline ยฃ2,200 annual fee, variable above ยฃ500,000 threshold); extension of fee-block A.13 to include "targeted support" activities (Category 2 variation fee for existing firms, Category 4 for new entrants); registration fees for Deferred Payment Credit (DPC/buy-now-pay-later) activities aligned with Temporary Permissions Regime, added to FOS consumer credit fee-block but excluded from FSCS.
What You Need To Do
- Review current fee/levy exposure and model impacts of new blocks (e
- Assess invoice processes if paying ยฃ50,000+ in FCA/PRA fees; prepare for aligned due dates
- Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026
- Budget for potential fee increases; monitor Spring 2026 fee-rates CP
- For applicants
Key Dates
9 January 2026 - Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7). DEADLINE
16 January 2026 - Consultation close for all other proposals, including PRA-FCA joint changes; responses to cp25-33@fca.org.uk.
February 2026 - FCA publishes feedback and rules on targeted support in Handbook Notice.
March 2026 - FCA publishes feedback and rules on all other proposals (including Chapter 4) in Handbook Notice; Spring fee-rates consultation.
April 2026 - PRA publishes feedback and rules on Chapter 4; changes effective for 2026/27 fee year (April-March).
Compliance Impact
Urgency: High โ Firms must act imminently on consultation responses (deadlines passed as of today, but feedback analysis pending March/April 2026 rules) to influence outcomes; changes affect 2026/27 budgets starting April, with cash flow risks from invoice timing and new fees for emerging activities
BankFintechPayment Provider No description available.
BankFintechCrypto Exchange
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 Englandโs Monetary Policy Committee.
BankBroker DealerPayment Provider
Meeting of the CBDC Engagement Forum
BankFintechCrypto Exchange
Policy statement 22/25
The PRA's PS22/25 finalizes an increase in the retail deposits threshold for the leverage ratio requirement from ยฃ50 billion to ยฃ75 billion, introducing a three-year averaging mechanism for calculations, effective 1 January 2026. This adjustment reflects nominal UK GDP growth since 2016 to maintain the Financial Policy Committee's original risk appetite while smoothing cliff-edge effects for firms like building societies. It matters for major UK banks and similar firms as it alters capital planning and leverage ratio applicability, potentially reducing immediate compliance burdens for those nearing the old threshold.
#
What Changed
Retail deposits threshold raised from ยฃ50 billion to ยฃ75 billion, adjusted upward from the CP2/25 proposal of ยฃ70 billion to account for further GDP growth to Q2 2025 (rounded to nearest ยฃ5 billion).
Introduction of a three-year moving average for calculating retail deposits metric, replacing point-in-time values to mitigate volatility and aid capital planning, particularly for building societies.
Non-UK assets threshold remains unchanged at ยฃ10 billion.
Modifications by consent disapplying leve
What You Need To Do
- Review and update internal retail deposits calculations to incorporate three-year moving average methodology starting 1 January 2026
- Assess current and projected retail deposits against ยฃ75 billion threshold (and ยฃ10 billion non-UK assets) to determine leverage ratio applicability and adjust capital planning accordingly
- Prepare to meet 3
- For firms with modifications by consent
- Update governance, risk models, and board reporting to reflect changes; conduct gap analysis against PRA Rulebook appendices in PS22/25
Key Dates
5 March 2025 - PRA publishes Consultation Paper CP2/25 proposing ยฃ70 billion threshold.
5 June 2025 - Consultation response deadline. DEADLINE
12 November 2025 - PRA issues PS22/25 with final policy.
1 January 2026 - Final policy takes effect, applying new ยฃ75 billion threshold and three-year averaging.
30 June 2026 - Cessation of modifications by consent disapplying leverage ratio rules.
Compliance Impact
Urgency: High โ With effectiveness just after today (1 January 2026), firms near ยฃ50-75 billion in retail deposits face immediate recalibration of leverage exposures and capital buffers to avoid breaches, amplified by the shift to averaging which requires historical data reconstruction. Non-complian
BankPayment ProviderAll Firms
The Bank of England (the Bank) has today published a consultation paper (CP) setting out its proposed regulatory regime for sterling-denominated systemic stablecoins.
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
Compliance Impact
Urgency: HIGH
BankFintechPayment Provider
The Central Bank of Ireland has fined Coinbase Europe Limited โฌ21,464,734 for breaching its anti-money laundering and counter terrorist financing transaction monitoring obligations between 2021 and 2025. The Central Bank of Ireland (the Central Bank) has fined Coinbase Europe Limited (Coinbase Europe) โฌ21,464,734 for breaching its anti-money laundering (AML) and combatting terrorist financing (CFT) obligations with respect to transaction monitoring as required by the Criminal Justice (Money L...
The Central Bank of Ireland (CBI) fined Coinbase Europe Limited โฌ21,464,734 for AML/CFT transaction monitoring failures under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), involving over 30 million unmonitored transactions worth โฌ176 billion from April 2021 to March 2025. This marks CBI's first enforcement against a crypto firm, highlighting regulators' focus on robust real-time monitoring and timely Suspicious Transaction Reporting (STR) for virtual asset service providers (VASPs). It matters as it sets a precedent for EU crypto compliance amid MiCA and AMLA implementation, signaling increased scrutiny and potential multimillion-euro penalties for similar lapses.
#
What Changed
This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime. Key breaches included: misconfigured monitoring systems missing 30,442,437 transactions (31% of activity over 12 months); delayed r
What You Need To Do
- Conduct Gap Analysis
- Enhance Controls
- Accelerate STR Processes
- Board/Compliance Reporting
- Third-Party Review
Key Dates
23 April 2021 - 19 March 2025 Period of breaches, including 12-month window of unmonitored โฌ176 billion transactions.
5 November 2025 Settlement reached between CBI and Coinbase Europe.
6 November 2025 CBI public announcement and Settlement Notice published.
12 January 2026 High Court confirmed sanctions, making them final and effective.
CJA 2010 obligations remain perpetual.
Compliance Impact
Urgency: High โ This establishes a โฌ21.5m benchmark for VASP monitoring failures in the EU, with risks amplified by MiCA (effective 2024) and AMLA (2025 onward), where national regulators like CBI will enforce harmonized rules. Firms risk similar fines (30% settlement discount possible), reputationa
Crypto ExchangeFintechPayment Provider
Meeting of the CBDC Engagement Forum
BankFintechCrypto Exchange
Die Schweiz schliesst sich den weiteren Massnahmen des 18. Sanktionspakets der Europรคischen Union (EU) gegenรผber Russland sowie den zusรคtzlich zum 18. Sanktionspaket erlassenen Massnahmen gegenรผber Belarus an. Dies hat der Bundesrat am 29. Oktober 2025 beschlossen. Im Fokus stehen Massnahmen im Gรผter-, Finanz und Energiebereich. Der Bundesrat hat dafรผr die Verordnung รผber Massnahmen gegenรผber Belarus (SR 946.231.116.9) geรคndert.
Switzerland has aligned with additional EU measures from the 18th sanctions package against Russia and specific Belarus measures, amending the Ordinance on Measures against Belarus (SR 946.231.116.9) to focus on goods, financial, and energy sectors. This strengthens the sanctions regime against Belarus to mirror Russia's more closely, aiming to enhance effectiveness and prevent circumvention. Compliance teams must prioritize asset freezes, transaction prohibitions, and reporting to avoid enforcement risks from FINMA and SECO.
#
What Changed
Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine.
Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening), financial services (e.g., transaction bans on additional banks), and energy sectors.
Requirements for financial intermediaries to
What You Need To Do
- Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists)
- Freeze assets of newly sanctioned persons/entities and prohibit dealings (e
- Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist
- Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e
- Review third-party exposures (e
Key Dates
18 July 2025 - EU adopts 18th sanctions package against Russia and additional Belarus measures.
29 October 2025 - Swiss Federal Council decides to align and amends SR 946.231.116.9.
30 October 2025 - New provisions enter into force.
13 December 2025 - Related expansion of Russia/Belarus lists (22 persons, 42 entities, 116 ships, 45 trade firms) takes effect, relevant for harmonization context.
Compliance Impact
Urgency: High - Effective 30 October 2025, these changes demand immediate portfolio screening and reporting, with non-compliance risking FINMA enforcement, asset seizure, or criminal penalties under sanctions laws. Matters due to rapid alignment with evolving EU packages, increasing circumvention ri
BankPayment ProviderAll Firms
Die Schweiz schliesst sich den weiteren Massnahmen des 18. Sanktionspakets der Europรคischen Union (EU) gegenรผber Russland sowie den zusรคtzlich zum 18. Sanktionspaket erlassenen Massnahmen gegenรผber Belarus an. Dies hat der Bundesrat am 29. Oktober 2025 beschlossen. Im Fokus stehen Massnahmen im Gรผter-, Finanz und Energiebereich. Der Bundesrat hat dafรผr die Verordnung รผber Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) geรคndert.
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 SECOโthis 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
Compliance Impact
Urgency: CRITICAL
BankPayment ProviderAll Firms
Policy Statement 20/25
**PS20/25** represents the second and final phase of the PRA's "Strong and Simple Framework," establishing a significantly simplified capital regime for Small Domestic Deposit Takers (SDDTs) while maintaining their resilience. This near-final policy statement, published on 28 October 2025, fundamentally restructures capital requirements, liquidity rules, and operational frameworks for SDDTsโa critical development for smaller deposit-taking institutions seeking regulatory relief from disproportionate compliance burdens.
What Changed
The simplified capital regime introduces structural changes across all three pillars of capital requirements:
*Pillar 1 (Risk-Weighted Assets)
SDDTs must apply Basel 3.1 standardised approaches for credit risk and operational risk, with specific simplifications.
Due diligence requirements in the standardised approach to credit risk are disapplied for SDDTs.
Counterparty credit risk (CCR) for derivatives and credit valuation adjustment (CVA) risk are disapplied (with minor exceptions).
Market ri
What You Need To Do
- *For SDDTs Currently Operating or Considering Entry:
- *Notification Decision โ Determine whether to enter the SDDT regime and submit notification to the PRA by 31 March 2026 if seeking to benefit from simplified rules
- *Policy Review โ Conduct comprehensive review of PS20/25, related policy statements (PS18/25, PS19/25, PS8/25, PS14/25), and supporting methodologies (SoP5/25, SS4/25, amendments to SoP2/23)
- *Capital Calculation Transition โ Prepare systems and processes to transition from current capital calculation methodologies to Basel 3
- Removal of CCR and CVA calculations for derivatives
Key Dates
31 March 2026 โ Deadline for firms wishing to enter the SDDT regime to notify the PRA and benefit from the simplified framework at implementation. DEADLINE
1 January 2027 โ Implementation date for the simplified capital regime for SDDTs; the Interim Capital Regime will no longer apply.
2026 (specific date TBD) โ PRA to make final rules and policy covering the entire Basel 3.1 package once HM Treasury makes commencement regulations to revoke relevant CRR provisions.
2027 (specific date TBD) โ PRA to implement restatement of CRR requirements (PS19/25).
Compliance Impact
Urgency Rating: HIGH
Bank
Am 20. Oktober 2025 hat das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung WBF die Liste der in diesem Kontext sanktionierten Personen, Unternehmen und Organisationen geรคndert. Das WBF hat die fรผr die Schweiz massgebliche Sanktionsdatenbank SESAM (SECO Sanctions Management) angepasst und die Anpassung auf seiner Internetseite dringlich verรถffentlicht. Die รnderung tritt am 21. Oktober 2025 23:00 Uhr in Kraft. Die Finanzintermediรคre werden gemรคss den Vorschriften der Verordnu...
This FINMA publication notifies Swiss financial intermediaries of updates to the Swiss sanctions list against the Islamic Republic of Iran, as amended by the Federal Department of Economic Affairs, Education and Research (WBF) on October 20, 2025, via the SESAM sanctions database. It matters because financial firms must immediately screen clients, freeze assets, and report matches to comply with Swiss sanction ordinances, amid escalating global Iran sanctions following UN snapback mechanisms. Failure to act risks enforcement by FINMA or SECO.
#
What Changed
The core change is the WBF's amendment to the SESAM (SECO Sanctions Management) database, updating the list of sanctioned persons, companies, and organizations related to Iran sanctions. This aligns with the Swiss Iran Ordinance and reflects broader international reimposition of UN sanctions via the JCPOA snapback mechanism triggered in late September 2025. No new Swiss-specific requirements are introduced beyond standard implementation of the updated list, but it emphasizes urgent publication a
What You Need To Do
- Immediate screening
- Asset freeze
- Transaction blocks and reporting
- Due diligence enhancement
- Internal controls
Key Dates
20 October 2025 - WBF amends SESAM database and publishes urgent update on its website.
21 October 2025, 23:00 Uhr - Changes enter into force, binding on all Swiss financial intermediaries.
29 September 2025 - Triggering UN snapback sanctions on Iran reinstated (contextual lead-in). https://www.mrllp.com/news-item/monthly-sanctions-update-october-2025/
12 December 2025 - Swiss Federal Council expands Iran Ordinance, adding humanitarian exceptions and authorization grounds. https://sanctionsnews.bakermckenzie.com/swiss-government-significantly-expands-sanctions-against-iran/
Compliance Impact
Urgency: High - Effective immediately (post-21 Oct 2025), with today's date (Jan 2026) indicating firms had ~3 months to implement but must verify ongoing compliance amid further expansions (e.g., Dec 2025). Matters due to FINMA's strict enforcement history on sanctions (e.g., independent freezing m
BankAll Firms
Given at the Bank of England and Bank for International Settlements Innovation Hubโs DLT Innovation Challenge Showcase
BankFintechCrypto Exchange Publication from the Bank, PRA and FCA to firms and financial market infrastructures highlighting observed effective practices of cyber response and recovery capabilities.
BankFintechPayment Provider 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.
BankBroker DealerPayment Provider
The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. 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.
BankBroker DealerPayment Provider
Meeting of the CBDC Academic Advisory Group
BankFintechCrypto Exchange
Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung WBF hat รnderungen des Anhangs 8 der Verordnung vom 4. Mรคrz 2022 รผber Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.
The publication announces updates by the Swiss Federal Department for Economic Affairs, Education and Research (WBF) to Annex 8 of the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions against Russia with ongoing international restrictions. This matters for Swiss financial intermediaries as it imposes immediate obligations to block assets, report relationships, and conduct AML checks, amid escalating sanctions that heighten compliance risks and enforcement scrutiny from FINMA.
#
What Changed
Amendments to Annexes 8, 14, 15b, and 33 of the Ordinance, though specific details on new listings or prohibitions are not detailed in the announcement.
Continuation of standard requirements: Implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
These updates follow a pattern of prior changes, such as expanded export bans on dual-use goods (e.g., chrome ore, chemicals), transaction bans on additio
What You Need To Do
- Screen and freeze assets
- Report to SECO
- Conduct AML due diligence
- Review transactions
- Document compliance
Compliance Impact
Urgency: Critical โ Effective immediately at 23:00 on January 13, 2026, with no grace period, this demands urgent system updates, screenings, and reporting to avoid FINMA enforcement (e.g., fines, licenses at risk). It amplifies AML / Financial Crime risks in a high-scrutiny environment, as FINMA's
BankPayment ProviderAll Firms
MiCA Other professionals Fintech Journalists Listed companies and issuers The French, Austrian and Italian markets authorities call for a stronger European framework for crypto-asset markets
Crypto ExchangeFintechBank
Given at the Bank of England and Warwick Business School Innovation in Money and Payments Conference
BankFintechCrypto Exchange
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 Zรผrcher 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.
Bank
Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung WBF hat eine รnderung des Anhangs 7 der Verordnung vom 11. November 2015 รผber Massnahmen gegenรผber der Islamischen Republik Iran (SR 946.231.143.6) publiziert.
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
Compliance Impact
Urgency: CRITICAL
BankAsset ManagerPayment Provider Das Staatssekretariat fรผr Wirtschaft (SECO) hat eine รnderung der Liste der sanktionierten natรผrlichen Personen, Unternehmen und Organisationen der Verordnung vom 30. Mรคrz 2011 รผber Massnahmen gegenรผber Libyen (SR 946.231.149.82) publiziert.
This FINMA publication announces an update by Switzerland's State Secretariat for Economic Affairs (SECO) to the sanctions list under the Ordinance of 30 March 2011 on Measures against Libya (SR 946.231.149.82), aligning Swiss sanctions with changes in the UN Libya sanctions regime. It matters for Swiss financial institutions as it triggers immediate screening and compliance obligations to avoid violations of asset freeze and related restrictions on designated persons, entities, or organizations. Failure to act promptly risks enforcement by FINMA.
#
What Changed
The core change is an amendment to the list of sanctioned natural persons, companies, and organizations in SR 946.231.149.82, as published by SECO. This reflects broader UN Security Council updates via Resolution 2769 (2025), which introduced new designation criteria for individuals/entities supporting armed groups or criminal networks through illicit exploitation/export of crude oil or refined petroleum from Libya, alongside exemptions for certain arms embargo activities, allowances for Libyan
What You Need To Do
- Screen immediately
- Freeze assets
- Cease dealings
- Update systems
- Monitor related flows
Key Dates
Immediate upon publication (19 August 2025) - Swiss firms must implement updated sanctions list screening and freeze applicable assets/transactions per FINMA/SECO requirements (https://www.finma.ch/en/news/2025/08/20250819-sr-946-231-149-82/). DEADLINE
1 May 2026 - Expiration of UN authorizations/measures on illicit petroleum exports from Libya (Resolution 2769).
15 May 2026 - End of UN Panel of Experts mandate monitoring Libya sanctions.
Compliance Impact
Urgency: High - Immediate action required due to asset freeze obligations; non-compliance risks FINMA fines, reputational damage, or criminal liability under Swiss AML/sanctions laws. This matters amid evolving geopolitical risks (e.g., petroleum smuggling destabilizing Libya), as flagged in FINMA's
BankWealth ManagerPayment Provider Adoption of the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures (sanctions)
Circular CSSF 25/896 adopts the EBA Guidelines EBA/GL/2024/14 and EBA/GL/2024/15, mandating Luxembourg financial institutions to establish robust internal policies, procedures, and controls for complying with EU and national restrictive measures (sanctions). This matters because it sets binding EU-wide standards to prevent sanctions violations and circumvention, with absolute obligations for immediate asset freezing and reporting, amid escalating geopolitical tensions.
#
What Changed
Institutions must develop, implement, and maintain up-to-date policies, procedures, and controls for identifying, investigating, and applying restrictive measures without delay, including risk management for violations and circumvention.
Management body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and report deficiencies.
Screening and monitoring requirements: Maint
What You Need To Do
- Conduct annual exposure assessments to sanctions risks and circumvention; update policies accordingly
- Appoint senior management/board-level responsibility for approving and overseeing sanctions strategy, including annual reviews and deficiency reporting
- Implement reliable screening systems for customers, transactions, and lists; define screenable datasets; test systems regularly for effectiveness (e
- Provide documented training to relevant staff on sanctions, institutional exposure, and internal processes
- Establish processes for immediate action on matches: suspend transfers, freeze assets, report to Ministry of Finance/CSSF/FIU without delay; maintain whitelists only under strict conditions
Compliance Impact
Urgency: High โ With less than 12 months until the 30 December 2025 deadline (as of January 2026), firms face binding requirements for absolute compliance, including personal accountability for management bodies; non-compliance risks enforcement by CSSF, reputational damage, and fines amid frequent
BankPayment ProviderCrypto Exchange
Das Staatssekretariat fรผr Wirtschaft (SECO) hat eine รnderung des Anhangs der Verordnung vom 7. August 1990 รผber Wirtschaftsmassnahmen gegenรผber der Republik Irak (SR 946.206) publiziert.
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)
Compliance Impact
Urgency: CRITICAL
BankPayment ProviderAll Firms
Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung WBF hat eine รnderung der Anhรคnge 5, 13, 14 und 15 der Verordnung รผber Massnahmen gegenรผber Belarus (SR 946.231.116.9) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published updates to Annexes 5, 13, 14, and 15 of the Ordinance on Measures against Belarus (SR 946.231.116.9), aligning Switzerland with additional EU sanctions imposed on July 18, 2025, in response to Belarus's involvement in Russia's war against Ukraine. This matters for Swiss financial institutions as it expands asset freezes, reporting obligations, and prohibitions, strengthening sanctions parity with Russia to prevent circumvention and enhance enforcement effectiveness.
#
What Changed
The updates amend Annexes 5, 13, 14, and 15 of SR 946.231.116.9, incorporating EU measures beyond the 18th Russia sanctions package, focusing on goods, financial, and energy sectors. Specific enhancements include expanded lists of sanctioned goods for military/technological strengthening (Annex 3 updated 29.10.2025), high-priority goods (Annex 11a), and industrial strengthening goods (Annex 19). Financial sanctions reinforce asset freezes, prohibitions on providing funds/services to listed parti
What You Need To Do
- Screen clients, assets, and transactions against updated Annexes 5, 13-15, and related lists (e
- Conduct GwG Art
- Cease prohibited activities
- Update internal screening tools, policies, and training; monitor SECO/FINMA websites for ongoing Anhรคnge updates
- For trade/energy firms
Key Dates
30 October 2025 - New provisions from Bundesrat decision on 29 October 2025 enter into force, requiring immediate implementation of updated Belarus measures.
13 December 2025 - Expansions to sanctions lists for Russia/Belarus (including 22 persons, 42 entities, 116 ships, 45 trade firms, 5 banks) take effect.
15 September 2025 - Harmonization of financial sanctions across multiple regimes (including Belarus) enters into force, clarifying fund crediting on blocked accounts and reporting.
12 December 2025 - Publication of list expansions by WBF/SECO.
Compliance Impact
Urgency: High - Immediate effect from 30 October 2025 demands swift asset screening and reporting to avoid GwG/EmbG violations, with heightened FINMA scrutiny amid Russia-Belarus alignment and recent list expansions (e.g., December 2025). Non-compliance risks enforcement, reputational damage, and sa
BankWealth ManagerPayment Provider Das Departement fรผr Wirtschaft, Bildung und Forschung (WBF) hat die Erweiterung der Sanktionslisten betreffend Russland publiziert. Die Schweiz hat damit diverse รnderungen รผbernommen, welche die EU im Rahmen ihres 18. Sanktionspakets beschlossen hatte.
This FINMA publication announces Switzerland's adoption of the EU's 18th sanctions package against Russia, expanding the sanctions lists with new designations and restrictions via the Swiss State Secretariat for Economic Affairs (SECO/WBF). It matters because Swiss financial institutions must immediately screen and freeze assets of newly listed parties, aligning with heightened FINMA enforcement on Russia sanctions risks amid ongoing geopolitical tensions. Compliance teams face elevated legal, reputational, and secondary sanctions exposure from US/EU measures.
#
What Changed
The core update involves Switzerland incorporating EU Council decisions from the 18th sanctions package, which typically include:
Additions to asset freeze lists targeting Russian individuals, entities, and sectors like energy, finance, and dual-use goods.
Expanded prohibitions on making funds or economic resources available to designated parties.
Alignment with EU sectoral restrictions on Russia's financial messaging services (e.g., SPFS), oil trade, and shadow fleet activities, now binding in
What You Need To Do
- Screen sanctions lists immediately
- Enhance customer due diligence (CDD)
- Report to FINMA/SECO
- Update policies
- Train staff
Key Dates
Immediate upon publication (August 13, 2025) - Swiss sanctions lists updated; asset freezes and prohibitions take effect instantly for newly designated parties.
15 December 2025 - Noted FINMA reference for ongoing list updates and independent freezing measures.
31 July 2026 - EU sectoral sanctions against Russia renewed until this date (adopted December 2025), influencing Swiss alignment.
Compliance Impact
Urgency: High - This directly expands enforceable prohibitions, with FINMA's targeted on-site reviews and "very high" Russia sanctions risk rating amplifying enforcement (https://www.finma.ch/en/~/media/finma/dokumente/dokumentencenter/myfinma/finma-publikationen/risikomonitor/20251117-finma-risikom
BankWealth ManagerAll Firms
Crypto-assets Innovation The ACPR and AMF publish the summary of responses to the consultation conducted by the Working Group on Smart Contract Certification
The ACPR and AMF have published a summary of responses to a public consultation on a 2024 Working Group report exploring smart contract certification in DeFi, addressing technical standards, audit practices, and potential regulatory frameworks. This matters for compliance as it signals preparatory steps toward possible EU-level DeFi regulation, emphasizing risk reduction and trust-building without immediate mandates, influencing future operational and audit strategies for crypto firms.
#
What Changed
No binding regulatory changes are introduced; this is an exploratory summary confirming industry support for proposed principles on technical standards (security, governance, compliance), audit methods (third-party, self-certification), and regulatory avenues (preference for voluntary certification over mandatory). Respondents endorsed alignment with industry best practices, risk-based approaches, and proportionality, with calls for technologically neutral standards and continuous monitoring mod
What You Need To Do
- Monitor developments
- Review internal practices
- Enhance documentation
- Engage stakeholders
Key Dates
2024 - Working Group conducts analysis and drafts report on smart contract certification.
3 February 2025 - Report published for public consultation.
14 March 2025 - Industry responses submitted (e.g., GDF, Adan).
16 July 2025 - Summary of consultation responses published by ACPR and AMF.
Compliance Impact
Urgency: Medium โ This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
Crypto ExchangeFintechAll Firms
Given at the Financial and Professional Services Dinner, Mansion House
BankPayment Provider
Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung WBF hat eine รnderung des Anhangs der Verordnung vom 16. Dezember 2022 รผber Massnahmen betreffend Haiti (SR 946.231.139.4) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Haiti (SR 946.231.139.4), dated December 16, 2022, aligning Switzerland's sanctions regime with recent UN Security Council decisions. This matters for Swiss financial institutions as it mandates immediate screening against potentially updated lists of designated persons and entities, reinforcing asset freezes, travel bans, and an expanded arms embargo to address Haiti's instability. Non-compliance risks FINMA enforcement actions under anti-money laundering and sanctions frameworks.
#
What Changed
Annex Update: The amendment modifies the annex to the Haiti Ordinance, likely incorporating additions to the UN Sanctions List, such as new designated individuals or entities involved in destabilizing activities like illicit natural resource exploitation, as seen in parallel UN actions (e.g., 2 new entries added on October 17/20, 2025).
Sanctions Renewal and Expansion: Reflects UNSC Resolution 2752 (2024, adopted October 18, 2024) and subsequent renewals (e.g., Resolution 2794 (2025)), renewing
What You Need To Do
- Screen Immediately
- Cease Prohibited Activities
- Report Findings
- Update Policies/Systems
- License Checks
Key Dates
October 18, 2024 - UNSC Resolution 2752 adoption Expands arms embargo scope, basis for national implementations.
July 23, 2025 - UK Haiti Sanctions Amendment effective Parallel indicator of timeline for UN-aligned changes.
October 17/20, 2025 - UNSC Committee adds 2 entries to Sanctions List Triggers immediate asset freeze checks; Swiss update (SR 946.231.139.4) published in response.
October 21, 2025 - Swiss WBF/VTG announcement Confirms amended sanctioned list.
Immediate/publication date (2025/07/09 per FINMA notice) - Swiss Annex amendment effective No grace period specified; aligns with "without delay" freezing requirements.
Compliance Impact
Urgency: High โ Immediate asset freeze obligations apply "without delay" upon list updates, with FINMA's enforcement type indicating potential fines or reputational damage for lapses; matters due to Haiti's volatility driving frequent UN changes, risking secondary sanctions exposure for Swiss firms
BankPayment ProviderAll Firms
Given at the 15th annual edition of City Week
BankFintechPayment Provider
Das Eidgenรถssische Departement fรผr Wirtschaft, Bildung und Forschung WBF hat eine รnderung des Anhangs der Verordnung รผber Massnahmen betreffend Guatemala (SR 946.231.137.6) publiziert.
The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Guatemala (SR 946.231.137.6), aligning Swiss sanctions with international developments targeting threats to democracy and rule of law in Guatemala. This matters for Swiss financial institutions as it mandates immediate screening and blocking of newly designated persons/entities to prevent sanctions violations, reinforcing Switzerland's commitment to international sanctions regimes amid ongoing geopolitical tensions in Central America. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/
#
What Changed
Amendment to Annex 2 of SR 946.231.137.6, likely adding or updating designations of individuals, groups, or entities involved in undermining Guatemala's democracy, rule of law, or election integrity, consistent with parallel EU actions.
Measures include asset freezes (prohibiting Swiss persons from dealing with designated assets) and transaction prohibitions, with independent freezing by FINMA where required under Swiss law.
Updates are published in the Federal Gazette and integrated into FINMA'
What You Need To Do
- Immediate screening
- Enhanced due diligence
- System updates
Key Dates
26 June 2025 - Publication of annex amendment by WBF; immediate effectiveness for screening and blocking obligations.
Ongoing (continuous) - Annex updates published in Federal Gazette; firms must integrate changes without specified delay. DEADLINE
15 December 2025 - Reference date for related FINMA sanctions annex maintenance (not specific to this update but indicative of cycle). https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/ https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/
Compliance Impact
Urgency: High - Swiss sanctions take effect immediately upon publication, exposing non-compliant firms to FINMA enforcement (fines up to CHF 1M, reputational damage). This aligns with rising geopolitical risks flagged in FINMA Risk Monitor 2025, where sanctions evasion amid corruption flows could tr
BankWealth ManagerPayment Provider Given at UK Finance Digital Innovation Summit 2025
BankFintechCrypto Exchange
Crypto-assets Innovation The ACPR and the AMF publish the findings from the Working Group on Smart Contract Certification, and launch a Public Consultation
The ACPR and AMF have published findings from their 2024 Working Group on Smart Contract Certification in DeFi, launching a public consultation on February 3, 2025, to explore certification frameworks for smart contracts, focusing on standards, audits, and regulatory options. This matters as it signals proactive French regulatory preparation for potential EU-level DeFi rules under MiCA, aiming to enhance security, governance, and compliance without immediate mandates, while industry feedback favors voluntary schemes.
#
What Changed
No binding regulatory changes yet; this is exploratory work anticipating future regulation. The report proposes:
Standards for security, governance, and compliance across execution environments.
Audit frameworks including public authority, third-party auditors, or self-certification.
Regulatory avenues from voluntary certification to obligations, with proportionate approaches.
Consultation responses (summarized post-March 2025) confirmed support for technical standards and audits but preferred v
What You Need To Do
- Participate/Review
- Assess Smart Contracts
- Monitor Developments
- Engage Stakeholders
Key Dates
February 3, 2025 - Working Group report published and public consultation launched.
March 10, 2025 - Public consultation closed (per some reports; responses summarized afterward).
July 16, 2025 - ACPR/AMF published summary of consultation responses.
2025 (TBD) - Conclusions from consultation responses to be presented.
July 2026 - DASP regime fully phased out under MiCA transitional period.
Compliance Impact
Urgency: Medium. This is non-binding exploratory work with consultation closed, but it foreshadows potential mandatory smart contract certification in DeFi, aligning with MiCA's risk mitigation goals. Firms face low short-term risk but high long-term impact if voluntary standards evolve into obligat
Crypto ExchangeFintechBank
MiCA Crypto-assets Innovation Markets in crypto-assets: publication of the MiCA regulation
Crypto ExchangeFintechBank
Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)
The Autoritรฉ des Marchรฉs Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.
#
What Changed
This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source cod
What You Need To Do
- Submit feedback (past deadline)
- Monitor developments
- Conduct internal assessments
- Enhance compliance programs
- Engage stakeholders
Key Dates
June 19, 2023 - AMF publishes initial discussion paper on DeFi regulatory issues.
September 30, 2023 - Deadline for stakeholder contributions to the discussion paper. DEADLINE
July 10, 2024 - AMF publishes summary of responses to the discussion paper.
Compliance Impact
Urgency: Medium โ This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity
FintechCrypto ExchangeAll Firms
Innovation The AMF publishes its proposals for an open finance framework
The Autoritรฉ des Marchรฉs Financiers (AMF), France's financial markets authority, has published proposals for an **open finance framework** via a public consultation, extending open banking principles to broader financial data sharing for enhanced innovation and competition. This matters for compliance professionals as it signals upcoming regulatory requirements for secure data access, APIs, and customer consent mechanisms, aligning with EU trends toward open finance while prioritizing consumer protection and market resilience. Firms must engage early to shape the final rules and prepare systems for compliance.
#
What Changed
The publication outlines AMF's proposals for an open finance framework, building on open banking (e.g., PSD2) to include investments, insurance, and asset management data. Key elements include:
Mandatory API-based data sharing for account information and payment initiation, extended to non-banking products like securities and insurance.
Enhanced customer consent and control mechanisms, with granular permissions, revocation rights, and strong authentication.
Security and liability standards align
What You Need To Do
- Review and respond to consultation
- Conduct gap analysis
- Update policies
- Engage stakeholders
- Test systems
Key Dates
January 14, 2026 - AMF publishes 2026 priorities, including open finance as part of innovation framework.
TBD (consultation period) - Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication). DEADLINE
June 30, 2026 - End of MiCA transitional period, relevant for crypto/open finance intersections.
2026 (H2) - Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs.
likely 2027 implementation phased over 12-24 months.
Compliance Impact
Urgency: High โ As a consultation, immediate engagement is critical to shape rules, but full implementation may not hit until 2027+. It matters due to alignment with AMF's 2026 priorities on innovation (AI, tokenization, MiCA) and resilience (DORA, cybersecurity), risking fines or supervisory action
BankAsset ManagerFintech