Senior Managers / Governance

Insurance & Pensions Consumer Credit

🇬🇧 FCA News

May 27th 2026

Vacancies open for FCA Smaller Business Practitioner Panel

We’re inviting applications from senior practitioners at smaller regulated firms in the general insurance and consumer credit sectors to join the panel. The Smaller Business Practitioner Panel provides independent advice and challenge from the perspective of smaller firms, helping to shape our work at a time of significant change in UK financial services regulation.Its key remit is to provide input to the FCA from the industry to help us meet our strategic and operational objectives from a sm...

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance

InsuranceAll Firms

Banking & Credit Investment Management Capital Markets & Trading

🇬🇧 PRA Policy high

May 27th 2026

PS14/26 – CRR Definitions: restatement in PRA Rulebook

Policy statement 14/26

AI Analysis

PRA Policy Statement PS14/26 finalises the restatement of CRR definitions into the PRA Rulebook Glossary, with consequential amendments across other Rulebook Parts and updates to SS15/13 on groups. For compliance teams, the key issue is transition planning: the remaining CRR definitions are being moved out of the CRR framework, and firms must ensure their policies, capital documentation, systems, and references align with the PRA Rulebook versions before the repeal of CRR Articles 4–5 takes effect on 1 January 2027.

What Changed

- The PRA has finalised new and restated PRA Rulebook Glossary definitions that replace the CRR definitions previously found in Articles 4, 4A, 4B and 5 for PRA Rulebook purposes.
The PRA has made consequential amendments across other Parts of the PRA Rulebook to align internal cross-references and terminology with the new glossary structure.
The PRA has updated Supervisory Statement SS15/13 – Groups to reflect the transfer of CRR definitions into the PRA Rulebook framework.
The PRA has stated that the vast majority of definitions are restated without substantive policy change, but some definitions were clarified for drafting consistency and readability.
HM Treasury has set the legislative timetable so that the relevant CRR Articles 4–5 will be revoked from 1 January 2027, while the statutory restatement of selected definitions was made in April 2026.

Suggested Considerations

Review all internal policies, manuals, and regulatory interpretation documents that currently cite CRR Articles 4, 4A, 4B, or 5 and replace those references with the corresponding PRA Rulebook Glossary definitions.
Update capital adequacy, prudential reporting, and risk management systems to use the new PRA Rulebook terminology where definitions have moved from the CRR text.
Reconcile group supervision materials, governance papers, and consolidation analyses against the revised SS15/13 wording to ensure group structures are assessed using the updated definitions.
Map every affected business line and legal entity to determine which Rulebook Parts and counterparties rely on the transferred CRR definitions.
Test template agreements, customer disclosures, and internal controls for terminology drift where contractual drafting depends on CRR-defined concepts.

Key Dates

July 2025

- HM Treasury published its Policy Update on applying the FSMA model of regulation to the UK CRR and proposed revoking the remaining CRR provisions while restating only necessary definitions

July 2025

- PRA published CP19/25 proposing the transfer of CRR definitions into the PRA Rulebook Glossary and consequential amendments across the Rulebook

January 2026

- PRA published earlier final policy work on CRR restatement and related implementation measures, indicating the wider restatement programme was already underway

February 2026

- HM Treasury published a policy update confirming it would proceed largely as consulted on, with a change to the statutory definition of “securitisation” for consistency with PRA Basel 3.1 rules

February 2026

- The commencement statutory instrument revoking CRR Articles 4–5 was made, with effect from 1 January 2027

Compliance Impact

The compliance impact is moderate to high because this is a definitional restatement rather than a wholesale policy rewrite, but it affects the legal basis of many prudential references and could create misstatement risk if firms continue to rely on revoked CRR text after 1 January 2027. Non-compliance may lead to inaccurate capital, governance, or perimeter analysis, and could trigger supervisory findings where firms have not updated systems, documentation, or controls to the new Rulebook structure.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankAsset ManagerBroker Dealer

🇱🇺 CSSF Guidance medium

May 22nd 2026

Circular CSSF 26/912

Repeal of Circular IML 91/75 related to the revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment (“UCI”) are subject

AI Analysis

The CSSF has issued Circular CSSF 26/912, formally repealing Circular IML 91/75 (and its amendments) governing Luxembourg UCIs under the (now repealed) Law of 30 March 1988 on undertakings for collective investment. This is a technical clean‑up measure that removes an obsolete circular from the rulebook and confirms that the 1991 governance, organisational and investment rules under IML 91/75 no longer apply.

What Changed

- Circular IML 91/75, including its amendments by Circulars CSSF 05/177, 18/697, 21/790, 22/811 and 25/901, is formally repealed by Circular CSSF 26/912.
The rules on “revision and remodelling of the rules to which Luxembourg undertakings governed by the Law of 30 March 1988 on undertakings for collective investment are subject” no longer form part of...
Supervisory expectations for Luxembourg UCIs are now to be derived exclusively from the current UCI regime (notably the Law of 17 December 2010 relating to undertakings for collective investment and...
Any internal compliance mappings, policy references, or control frameworks that still cite Circular IML 91/75 or its amending circulars must be treated as referencing repealed guidance and should be...

Suggested Considerations

Update your regulatory inventory and obligation registers to reflect that Circular IML 91/75 and its amending circulars (CSSF 05/177, 18/697, 21/790, 22/811 and 25/901) have been repealed by Circular CSSF 26/912 as of 22 May 2026.
Verify that your compliance monitoring programmes and internal audit test plans do not rely on requirements sourced from Circular IML 91/75, and re-align any such tests to the currently applicable legal and regulatory standards.
Communicate the repeal of Circular IML 91/75 internally to legal, compliance, risk, product, and fund administration teams to prevent continued reliance on obsolete rules in ongoing or future projects.
For any ongoing remediation, authorisation or approval processes that previously cited IML 91/75 as justification for a control design, reassess and document those controls against the current CSSF requirements that have effectively replaced or superseded the 1991 framework.
Maintain an audit trail evidencing the update of documentation and registers in response to Circular CSSF 26/912, including board or senior management notification where your governance framework requires it for changes in regulatory obligations.

Key Dates

21 January 1991

- Original Circular IML 91/75 on revision and remodelling of rules applicable to UCIs under the Law of 30 March 1988 is issued (subsequently amended by later circulars)

22 May 2026

- Circular CSSF 26/912 is published and Circular IML 91/75 (as amended by Circulars CSSF 05/177, 18/697, 21/790, 22/811 and 25/901) is repealed and archived

Compliance Impact

The immediate compliance risk is low, as the circular repeals an already outdated framework; however, continuing to reference or rely on Circular IML 91/75 could create documentation inconsistencies, misalignment with current CSSF expectations and weaknesses in regulatory audits or inspections.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Reporting & Disclosure Senior Managers / Governance

Topics:

Asset ManagerHedge FundBank

Banking & Credit Crypto & Digital Assets Capital Markets & Trading

🇭🇰 SFC Enforcement high

May 22nd 2026

Movie producer Wong Pak Ming convicted of insider dealing in SFC’s prosecution

No description available.

AI Analysis

The Eastern Magistrates’ Court has convicted movie producer and former Pegasus Entertainment Holdings Limited chairman Wong Pak Ming of criminal insider dealing for directing his sister to buy Pegasus shares in 2017 while in possession of undisclosed price‑sensitive information about the sale of his controlling stake. The case underscores that the Securities and Futures Commission (SFC) will actively prosecute “tipping” and trading via connected persons, and that listed-company insiders must treat funding and advising relatives as insider dealing risk events.

What Changed

- The conviction reinforces the SFC’s enforcement position that “counselling or procuring” another person to trade, including a close family member, while in possession of inside information...
The case highlights that use of personal communication channels (e.g., WhatsApp) to direct trading can be decisive evidence in insider dealing prosecutions, increasing expectations that firms monitor...
The conviction confirms that controlling shareholders and chairpersons of Hong Kong–listed companies are expected to treat negotiations for disposal of control stakes, memoranda of understanding...
The SFC has publicly quantified the estimated illicit profits (over HK$1 million) earned via the relative’s trading, signalling a continued focus on disgorgement and benefit analysis in enforcement...
The case continues the SFC’s trend of using criminal prosecution, rather than solely civil Market Misconduct Tribunal proceedings, for insider dealing involving abuse of senior positions and close...

Suggested Considerations

Review and update insider dealing and market misconduct policies to explicitly cover “counselling or procuring” trading by family members, nominees, and other connected persons, in line with Part XIII and Part XIV of the Securities and Futures Ordinance (Cap. 571).
Update staff and director training materials to include concrete examples of prohibited conduct, including funding relatives’ accounts and giving trading instructions via messaging apps while in possession of inside information about control transactions, MOUs, or earnest money arrangements.
Strengthen personal account dealing policies to require pre‑clearance and enhanced scrutiny for trades in securities of issuers where the employee, director, or major shareholder is directly or indirectly involved in control stake negotiations or other price‑sensitive corporate events.
Implement or enhance procedures to identify and log potential inside information events (such as MOUs for stake sales, receipt of earnest money, or other significant transaction milestones) and to trigger trading blackouts for relevant insiders and their close associates.
Conduct targeted thematic reviews of recent and ongoing corporate finance mandates and control stake transactions handled by the firm to identify any gaps in information barriers, wall‑crossing procedures, or monitoring of insiders’ and their relatives’ trading activities.

Key Dates

31 October 2012

– Pegasus Entertainment Holdings Limited is listed on the Growth Enterprise Market of the Stock Exchange of Hong Kong

09 January 2015

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

Bank

🇪🇺 ESMA News

May 20th 2026

ESMA publishes shortlist of candidates for position of Chair

ESMA publishes shortlist of candidates for position of Chair 20 May 2026 About ESMA Board of Supervisors Press Releases The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published the shortlist of candidates for the position of Chair, which it has sent to the Council of the European Union (Council) and the European Parliament (Parliament). The Council will appoint the Chair following confirmation by the Parliament. The Board of Supe...

Sectors:

Authorisation & Licensing Senior Managers / Governance

Topics:

All Firms

Capital Markets & Trading Investment Management Crypto & Digital Assets

🇺🇸 CFTC Enforcement high

May 19th 2026

CFTC Staff Issues Advisory on Cooperation in Enforcement Matters

No description available.

AI Analysis

On 19 May 2026, the CFTC Division of Enforcement issued a new cooperation advisory that supersedes all prior CFTC cooperation and self‑reporting advisories and policies. For compliance teams, this resets the playbook for how voluntary self‑reporting, cooperation, remediation, and restitution/disgorgement are assessed for mitigation credit, including a clarified path to potential declinations where specific conditions are met.

What Changed

- The CFTC Division of Enforcement has adopted a new, unified cooperation policy that expressly supersedes all prior Division cooperation and self‑reporting advisories (including the 2017 corporate...
The new advisory establishes a clear “declination pathway” under which, absent aggravating circumstances, a respondent that voluntarily self‑reports, fully cooperates, timely and appropriately...
The advisory formalizes that voluntary self‑reporting is a central prerequisite for the highest level of credit, distinguishing between cases with self‑reports (potential declination or high...
The policy confirms that “full cooperation” will be a necessary condition for a declination, which in practice will require proactive, resource‑intensive engagement with Enforcement beyond mere...
The advisory codifies that timely and appropriate remediation is a separate and indispensable requirement for top‑tier outcomes, emphasizing that firms must implement corrective measures before...

Suggested Considerations

Identify and catalogue all existing internal policies, playbooks, and checklists relating to CFTC investigations, dawn raids, inquiries, self‑reporting, and cooperation, and amend them to reflect the new advisory’s superseding status.
Update the firm’s enforcement‑response framework to explicitly incorporate the new declination pathway, including clear decision criteria for when and how to voluntarily self‑report potential CFTC violations.
Establish or refine escalation triggers for potential insider trading, fraud, manipulation, and market abuse in CFTC‑regulated markets to ensure that issues can be investigated and elevated quickly enough to support “prompt” and “voluntary” self‑reporting.
Design and document a structured internal investigation protocol that can generate the level of factual development, analysis, and documentation needed to demonstrate “full cooperation,” including protocols for sharing findings, data, and analytics with the CFTC where appropriate.
Implement procedures to rapidly secure, preserve, and collect relevant trading records, communications (including messaging apps), surveillance alerts, and algorithmic trading data so that the firm can cooperate effectively and avoid any appearance of obstruction or delay.

Key Dates

19 May 2026

- CFTC Division of Enforcement issues the new cooperation advisory, which supersedes all prior cooperation and self‑reporting advisories and becomes the operative policy for ongoing and future enforcement matters

Compliance Impact

The impact is high: the advisory reshapes incentives around self‑reporting and cooperation and directly affects whether firms can obtain declinations or material penalty reductions in CFTC enforcement actions. Failure to align investigation, remediation, and reporting practices with the new framework may result in higher civil monetary penalties, loss of declination eligibility, and more intrusive enforcement scrutiny.

References

AI-generated analysis. May contain errors or omissions — verify with the original CFTC source before acting. Full disclaimer.

Sectors:

Topics:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset ManagerHedge Fund

Senior Managers / Governance

🇺🇸 SEC Enforcement high

May 18th 2026

SEC Rescinds Policy Regarding Denials of Settlements in Enforcement Actions

The Securities and Exchange Commission today rescinded a policy, codified in Rule 202.5(e) of its informal rules of procedures, stating that when it chooses to settle an enforcement action in which a sanction is imposed, it will not settle unless the…

AI Analysis

The SEC has rescinded its long‑standing “no‑deny” settlement policy, previously codified in Rule 202.5(e) of the Commission’s Rules of Practice, which had prohibited settling respondents from publicly denying the Commission’s allegations in cases resolved on a “neither admit nor deny” basis. This materially alters how firms can speak about resolved SEC enforcement matters and will directly affect settlement negotiations, collateral consequences analysis, and post‑settlement communications and disclosure strategies.

What Changed

- The SEC has rescinded the policy in Rule 202.5(e) of its informal Rules of Practice that conditioned settlements involving sanctions on the respondent’s agreement not to publicly deny the...
Settling parties in SEC enforcement actions may now have greater scope to make public statements that deny or contest aspects of the SEC’s allegations, subject to the specific language of each...
The traditional “neither admit nor deny” construct will no longer automatically include a built‑in prohibition on denials, which means the SEC staff will need to negotiate any desired limitations on...
Communications and disclosure provisions in SEC settlement papers (including “undertakings” and clauses governing press releases and investor communications) are likely to become more tailored and...
The rescission increases the importance of alignment between legal, compliance, and communications teams when crafting public statements following an SEC settlement, because statements that deny...

Suggested Considerations

Review existing internal playbooks for handling SEC investigations and settlements and update them to reflect the rescission of Rule 202.5(e), including how settlement language on admissions, denials, and public statements is negotiated.
For matters currently under SEC investigation or in active settlement negotiations, direct outside and in‑house counsel to reassess settlement strategy, including whether to seek greater flexibility for post‑settlement denials or clarifications in the consent language and undertakings.
Conduct an inventory of significant historical SEC settlements that included “no‑deny” provisions and identify where ongoing communications plans, disclosure narratives, or litigation strategies may be constrained by legacy language.
For high‑impact historical orders with restrictive “no‑deny” clauses, obtain legal advice on whether and how to approach the SEC about potential modification or clarification of those provisions in light of the Commission’s changed policy.
Train senior management, board members, and spokespersons on the revised SEC posture, emphasising that while denials may now be more permissible, inaccurate or overly aggressive denials could adversely affect ongoing private litigation, insurance recoveries, or relationships with other regulators.

Key Dates

All Firms

Technology & Cyber Authorisation & Licensing Senior Managers / Governance

🇪🇺 ESMA Consultation low

May 12th 2026

European Commission launches call for candidates for the ESAs’ Board of Appeal

European Commission launches call for candidates for the ESAs’ Board of Appeal 12 May 2026 Board of Appeal The European Commission has launched a call for expression of interest for the appointment of members to the Board of Appeal of the three European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs). This call aims to establish a reserve list of qualified candidates to fill vacancies that may arise within the Board of Appeal. The reserve list will remain valid for a period of five y...

Sectors:

General

Topics:

All Firms

Banking & Credit Investment Management Capital Markets & Trading

🇱🇺 CSSF Enforcement low

May 12th 2026

Law of 5 May 2026 (only in French)

1° amending:(a) the Law of 5 April 1993 on the financial sector, as amended;(b) the Law of 17 December 2010 relating to undertakings for collective investment, as amended;(c) the Law of 18 December 2015 on the failure of credit institutions and certain investment firms, as amended;(d) the Law of 15 March 2016 on OTC derivatives, central counterparties and trade repositories and amending different laws relating to financial services, as amended;2° transposing:(a) Directive (EU) 2024/1619 of th...

Sectors:

Topics:

AML / Financial Crime ESG Technology & Cyber

Bank

Technology & Cyber Senior Managers / Governance

🇸🇬 MAS News

May 12th 2026

Changes to MAS Board of Directors

MAS today announced the the appointment of Mr Ong Pang Thye to its Board of Directors. MAS also announced the re-appointment of four existing Directors, including its Chairman, Mr Gan Kim Yong and its Managing Director, Mr Chia Der Jiun.

Sectors:

General

Topics:

All Firms

🇪🇺 ESMA Enforcement high

May 11th 2026

ESMA identifies areas for further supervisory convergence on compliance and internal audit in the funds sector

ESMA identifies areas for further supervisory convergence on compliance and internal audit in the funds sector 11 May 2026 Audit Fund Management The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published the results of its 2025 Common Supervisory Action (CSA) on the compliance and internal audit functions of fund managers , carried out in with the participation of all EU and EEA national supervisors. The EU-wide review found that m...

Sectors:

Consumer Protection / Conduct Technology & Cyber Market Abuse / Surveillance

Topics:

Asset Manager

🇬🇧 FCA Speech

May 11th 2026

Laying the foundation for confidence

Speech by Sarah Pritchard, deputy chief executive, at the Investment Association's Private Markets Summit 2026. Headlines are always a tough read when funds run into difficulty.And lately, the language has been stark.Some have even asked if private credit has a canary in the coal mine.That’ll make you sit up a bit straighter, won’t it?But in this moment, it’s important to remember that stress in markets is normal – and okay, as long as the system stays resilient.Private markets, done well, ca...

Sectors:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

Topics:

All Firms

🇬🇧 FCA News

May 11th 2026

Restrictions imposed on Kingscrown Finance Limited

Kingscrown Finance Limited (Kingscrown) has stopped onboarding new customers or undertaking new business with existing customers – including extending existing credit. Kingscrown, which was incorporated in 2014, provides lending for business and investment purposes, including property investment, buy-to-let and house in multiple occupation (HMO) finance.The voluntary restrictions on Kingscrown’s business came into effect on 21 April 2026. Kingscrown has never been authorised by or registered ...

Sectors:

AML / Financial Crime Technology & Cyber Authorisation & Licensing

Topics:

All Firms

🇬🇧 BoE News

May 7th 2026

Minutes of the Meeting of the Court of Directors held on 12 February 2026

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.

Sectors:

Technology & Cyber Senior Managers / Governance

Topics:

Bank

Technology & Cyber Senior Managers / Governance

🇭🇰 SFC News

May 7th 2026

SFC obtains disqualification orders against former directors of China Candy Holdings Limited

No description available.

Sectors:

General

Topics:

All Firms

🇪🇺 ESMA Enforcement high

May 6th 2026

ESMA promotes proportionate supervision of MiFID II sustainability requirements

ESMA promotes proportionate supervision of MiFID II sustainability requirements 06 May 2026 Investor protection The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has issued a statement presenting the results of its Common Supervisory Action (CSA) on how sustainability is integrated into firms’ suitability assessment as well as into processes and procedures for product governance. The statement highlights key themes emerging from the sup...

Sectors:

Consumer Protection / Conduct ESG Technology & Cyber

Topics:

All Firms

Banking & Credit Investment Management Payments & E-Money

🇸🇬 MAS News

May 6th 2026

No description available.

AI Analysis

The CSSF publication highlights AMLA's public consultation on draft Regulatory Technical Standards (RTS) under Articles 16(4) and 17(3) of Regulation (EU) 2024/1624, specifying minimum group-wide AML/CFT requirements and additional measures for subsidiaries and branches in third countries. This matters because it aims to harmonize cross-border AML frameworks, ensuring groups maintain consolidated ML/TF risk views and robust controls, particularly in high-risk third-country operations, impacting EU financial groups' compliance structures. Private sector input is encouraged to align standards with practical operations.[https://www.cssf.lu/en/Document/public-consultation-by-amla-on-the-draft-rts-on-group-wide-minimum-requirements-and-additional-measures-for-subsidiaries-and-branches-in-third-countries/][https://www.amla.europa.eu/amla-consults-group-wide-requirements-and-business-wide-risk-assessment_en]

What Changed

- Group-wide AML/CFT frameworks: Establishes minimum standards for design and implementation across groups, including cross-border structures and third-country operations, to enable consolidated...
Third-country subsidiaries and branches: Introduces additional measures for entities in non-EU countries, extending requirements beyond traditional groups to other...
Information sharing and parent identification: Defines provisions for intra-group data sharing and criteria to identify the EU parent undertaking when multiple entities report to a third-country head...
Interlinked mandates: Cross-references obligations between Articles 16(4) and 17(3) for complementary requirements on organizational...

Suggested Considerations

Register for 20 May 2026 public hearing to engage directly on practical application across group structures.[https://www.amla.europa.eu/events/public-hearing-draft-rts-group-wide-minimum-requirements-and-additional-measures-subsidiaries-and-2026-05-20_en]
Assess current group-wide AML/CFT frameworks against proposed minimums, identifying gaps in third-country controls, risk consolidation, and data sharing protocols.

Compliance Impact

Urgency: High – Firms with third-country exposure must act now on consultation (closes 15 July 2026) to influence final RTS, as these will mandate binding minimums for group-wide AML/CFT, potentially requiring significant framework overhauls for risk consolidation and controls. Non-engagement risks misaligned systems post-adoption, increasing supervisory scrutiny under harmonized EU standards; early assessment prevents rushed...

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Senior Managers / Governance

BankAsset ManagerPayment Provider

Banking & Credit Investment Management Payments & E-Money

🇱🇺 CSSF Consultation high

April 17th 2026

Public consultation by AMLA on the draft Guidelines on business-wide risk assessment

No description available.

AI Analysis

AMLA has launched a public consultation on draft Guidelines for business-wide risk assessments (BWRA) under the new Anti-Money Laundering Regulation (EU 2024/1624), with submissions open until 15 July 2026. These guidelines establish minimum requirements for all obliged entities across financial and non-financial sectors to systematically identify and manage money laundering and terrorist financing risks inherent to their operations.

What Changed

The draft Guidelines introduce four minimum requirements for conducting adequate business-wide risk assessments applicable to all obliged entities. The framework mandates that entities:
Identify risk exposure across their business model, customers, products, services, transactions, delivery channels, and geographical exposure
Maintain consolidated risk views across group structures, eliminating silos between branches and subsidiaries
Utilize internal and external data sources to build comprehensive risk landscapes, including monitoring customer behavior changes and tracking international typologies
Apply proportionality based on entity size, business model, and risk profile, while ensuring consistent application of policies across the organization The guidelines specifically address evaluation...

Suggested Considerations

*Immediate (by 15 July 2026):
Review draft Guidelines and assess alignment with current BWRA practices
Identify gaps between existing risk assessment frameworks and proposed minimum requirements
Prepare formal consultation responses, particularly if your organization operates in non-financial sectors
Register for relevant public hearings (28 May for BWRA Guidelines; 20 May for group-wide RTS) to engage directly with AMLA

Key Dates

Later in 2026

- Final adoption of guidelines and technical standards

16 April 2026

- Consultation launched

20 May 2026, 10:00–12:00 CET

- Public hearing on draft RTS on group-wide requirements

28 May 2026, 10:00–12:00 CET

- Public hearing on draft Guidelines on business-wide risk assessment

15 July 2026 DEADLINE

- Consultation deadline for submissions

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Operational Resilience / Outsourcing Senior Managers / Governance

All Firms

Investment Management Wealth & Private Banking Capital Markets & Trading

🇮🇪 CBI Enforcement high

April 17th 2026

Central Bank statement on High Court judgment

Today, the High Court published its written judgment in the matter of the Central Bank’s application under the Fitness & Probity Regime to confirm the one-year prohibition issued to a senior executive on 02 February 2022 concerning his role in a regulated firm in the investment fund and asset management sector. The decision of the High Court was to refuse the application. The Central Bank acknowledges the importance of the Court’s findings and the clarity that the judgment provides in this ca...

AI Analysis

The Central Bank of Ireland (CBI) issued a statement on 17 April 2026 acknowledging a High Court judgment refusing to confirm a one-year prohibition on a senior executive in the investment fund and asset management sector due to inadequate fair procedures during the CBI's Fitness & Probity (F&P) investigation. This matters for compliance professionals as it underscores the critical need for robust fair procedures in F&P processes and highlights recent legislative and guidance enhancements under the Individual Accountability Framework (IAF) Act 2023 to address such shortcomings. Firms must prioritize these updates to mitigate enforcement risks.

What Changed

- Legislative enhancements via IAF Act 2023: Introduced changes to strengthen CBI's investigation and prohibition powers under the F&P Regime, including additional safeguards for fair procedures in...
Updated Regulations and Guidance (April 2023): CBI published revisions reflecting IAF Act changes, focusing on improved investigation and decision-making processes...
CP-150 Consultation (2025): Led to updated Guidance on consolidated Fitness and Probity Standards, separate from F&P investigations...
CP-166 Consultation on Supplemental Guidance: Public consultation on prohibitions closed 25 March 2026; final guidance expected summer 2026...

Suggested Considerations

Review and implement April 2023 updated F&P Regulations and Guidance to ensure investigations and prohibitions incorporate IAF Act fair procedure safeguards (https://www.centralbank.ie/news/article/press-release-central-bank-statement-on-high-court-judgment-17-april-2026).
Conduct internal audits of F&P processes, focusing on fair procedures (e.g., notice, representation rights) for senior executives in CF/PCF roles.
Monitor and prepare for summer 2026 final guidance from CP-166 on prohibitions; submit any late feedback if applicable.
Train compliance and HR teams on heightened procedural standards, referencing High Court emphasis on fair procedures.
For firms in investment funds/asset management: Assess PCF suitability assessments against consolidated F&P Standards from CP-150.

Compliance Impact

Urgency: High – The High Court ruling directly critiques CBI's past F&P procedures, signaling elevated scrutiny on fair process compliance; failure risks court refusals of prohibitions, reputational damage, and escalated enforcement. With final CP-166 guidance imminent (summer 2026), firms face immediate pressure to align processes, especially post-IAF Act, to avoid similar outcomes in ongoing or future investigations.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Authorisation & Licensing

Asset ManagerWealth ManagerHedge Fund

Banking & Credit Capital Markets & Trading Investment Management

🇪🇺 ESMA Consultation medium

April 16th 2026

ESMA launches a call for evidence on restricted subscription and private credit ratings

ESMA launches a call for evidence on restricted subscription and private credit ratings 16 April 2026 Credit Rating Agencies The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, today launched a call for evidence to gather stakeholder views on the purposes, market practices, needs and risks associated with restricted subscription and private credit ratings. ESMA is encouraging all interested stakeholders to share views, data and analysis i...

AI Analysis

ESMA has launched a call for evidence on restricted subscription and private credit ratings to gather stakeholder input on their market practices, uses, risks, and potential regulatory gaps under the CRA Regulation. This matters because rising use of these non-public ratings could prompt future clarifications or adjustments to ensure consistent standards with public ratings, impacting credit rating agencies (CRAs) and users reliant on them for regulatory or investment purposes.

What Changed

There are no immediate regulatory changes; this is a fact-finding call for evidence to assess whether adjustments to the CRA Regulation are needed. ESMA seeks views on definitions (e.g., restricted subscription ratings as selectively distributed to limited subscribers with economic interest; private ratings excluded from CRA scope if not distributed to >150 persons), production processes, governance comparability to public ratings, distribution risks, and market needs. Potential future outcomes include enhanced clarity on CRA Regulation application, but none are confirmed yet.

Suggested Considerations

Review the full Call for Evidence document and annexes for specific questions on restricted subscription (Annex I) and private credit ratings (Annex II).
Prepare and submit evidence-based responses addressing key areas: use cases/benefits vs. public ratings, contracting/distribution parties, analytical/governance comparability, transparency impacts, risks/mitigations, and multi-CRA practices.
Provide quantitative data, concrete examples, and rationale; indicate specific questions and alternatives considered.
Submit online by 31 May 2026 using the docx reply form; note responses may be published unless confidentiality requested.

Key Dates

Q2 2026

- ESMA reviews responses to assess potential regulatory adjustments under CRA Regulation

31 May 2026 DEADLINE

- Deadline for submitting evidence-based responses, including quantitative data and market examples, via ESMA's online consultation form in docx format

Compliance Impact

Urgency: Medium - This is not mandatory rulemaking but a critical opportunity to influence potential CRA Regulation clarifications amid growing private rating use, which could standardize governance/internal controls or expand scope. Firms using or issuing these ratings should engage to mitigate risks of future unaddressed practices leading to enforcement or restrictions; inaction may expose gaps if ESMA identifies inconsistencies with public rating standards.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Asset ManagerBankAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE Speech

April 14th 2026

Central Bank Independence – in need of further thinking - Speech by Andrew Bailey

Given at Columbia University, New York

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankAsset ManagerWealth Manager

🇭🇰 SFC Speech

April 13th 2026

New speech by Kelvin Wong: Remarks at HKIFA’s 40th Anniversary Cocktail Reception

No description available.

Sectors:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Topics:

Asset ManagerWealth ManagerAll Firms

Banking & Credit Payments & E-Money

🇬🇧 BoE Guidance high

April 13th 2026

Bank of England enhances resolution readiness with updated operational guides

The Bank of England has today published new and updated guidance on how the Bank might implement the UK’s resolution regime in the event of a bank failure.

AI Analysis

The Bank of England (BoE) has published updated operational guides on implementing the UK's resolution regime for failing banks, including new details on transfer resolutions and an alternate bail-in approach using non-transferable contingent beneficial interests, informed by recent failures like Silicon Valley Bank and Credit Suisse. This matters for compliance professionals as it enhances transparency on BoE execution strategies, strengthens cross-border resolvability (e.g., via a US SEC No-Action Letter), and requires firms to align recovery/resolution plans with these operational clarifications to ensure feasibility and credibility under the Resolvability Assessment Framework (RAF).[BoE News Release](https://www.bankofengland.co.uk/news/2026/april/boe-enhances-resolution-readiness-with-updated-operational-guides)

What Changed

- New Operational Guide to Transfer Resolution: Details BoE's execution of transfers to private sector purchasers or temporary bridge banks, including recapitalisation payments and use of resolution...
Updates to Operational Guide to Bail-in Resolution: Introduces an alternate approach where affected creditors receive non-transferable contingent beneficial interests (simplifying bail-in by...
US SEC No-Action Letter: Confirms non-transferable contingent beneficial interests for US investors need no SEC registration, aiding cross-border bail-in operability.[BoE News...

Suggested Considerations

Assess resolvability: Major firms perform and disclose self-assessments under RAF; address identified barriers or face BoE powers to mandate fixes.
Enhance capabilities: Implement MREL, operational continuity in resolution (OCIR), and Single Customer View for deposits; prepare for recapitalisation or non-transferable interests in bail-in.
Cross-border coordination: US-exposed firms leverage SEC No-Action Letter for bail-in planning; engage BoE on international strategies.[BoE News Release](https://www.bankofengland.co.uk/news/2026/april/boe-enhances-resolution-readiness-with-updated-operational-guides)
Monitor thresholds: Notify BoE/PRA if approaching £25bn assets or account thresholds.

Key Dates

Ongoing DEADLINE

- Firms must maintain resolution packs and MREL compliance; bail-in firms have at least **6 years** (plus up to 2-year extension) to meet end-state MREL, and **minimum 18 months** for additional resolvability requirements

Advance notification DEADLINE

- Modified insolvency firms forecasting £25bn assets or transactional account thresholds within 3 years must inform BoE/PRA

Compliance Impact

Urgency: High - This is guidance, not new rules, but directly impacts resolution plan credibility and RAF assessments, with potential supervisory/enforcement actions for non-alignment (e.g., MREL shortfalls or unresolved barriers). Firms must act proactively to avoid heightened BoE scrutiny, especially post-SVB/Credit Suisse lessons emphasizing bail-in effectiveness and no public fund reliance.

References

AI-generated analysis. May contain errors or omissions — verify with the original BoE source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankPayment ProviderAll Firms

Capital Markets & Trading Investment Management Banking & Credit

🇯🇵 JFSA Consultation high

April 10th 2026

Councils,Draft revisions to the Corporate Governance Code for public consultation

No description available.

AI Analysis

The Financial Services Agency (FSA) and Tokyo Stock Exchange have launched a public consultation on draft revisions to Japan's Corporate Governance Code, with comments due by May 15, 2026. This represents the first major update since 2021 and aims to redirect corporate resource allocation toward growth investments, research and development, and human capital rather than short-term shareholder returns. The revised code will become effective this summer and requires listed companies to submit governance reports by July 2027.

What Changed

The draft revisions introduce several substantive modifications to Japan's corporate governance framework:
Resource Allocation Focus: Boards must continuously examine whether management resources (cash, deposits, real estate, and other assets) are allocated appropriately, with emphasis on growth...
Principles-Based Streamlining: The code has been streamlined to adopt a more principles-based approach, moving from form to substance and reducing prescriptive requirements.
Collective Engagement Promotion: The revisions aim to promote collective and collaborative engagements among investors, strengthening dialogue between companies and investors.
Beneficial Shareholder Transparency: Enhanced transparency requirements regarding the identification of beneficial shareholders.

Suggested Considerations

*For Listed Companies:
*Immediate (by May 15, 2026): Review the draft revisions (Materials 1 and 2) and consider submitting comments during the public consultation period if your organization wishes to influence final provisions.
*Pre-Implementation (Summer 2026): Conduct a comprehensive gap analysis comparing current governance practices against the draft requirements, particularly regarding:
Board processes for examining resource allocation decisions
Documentation of investment policy rationale

Key Dates

Summer 2026

- Official adoption of the revised Corporate Governance Code

May 15, 2026 DEADLINE

- Public consultation comment submission deadline (JST)

June 1, 2026

- Anticipated effective date (based on historical pattern; confirmation pending final adoption)

July 2027 DEADLINE

- Listed companies must submit governance reports under the new code

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original JFSA source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Reporting & Disclosure ESG

Asset ManagerBankAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

April 10th 2026

ASIC permanently bans Yanhua Chen from the financial services industry

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

April 10th 2026

Shane Monte Silva banned for five years over flawed Shield and First Guardian advice

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Wealth ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

April 10th 2026

ASIC bans former financial adviser Rhys Reilly for 10 years and suspends Conexus Group’s AFS licence

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Wealth ManagerAll Firms

🇭🇰 SFC Enforcement high

April 9th 2026

SFC sanctions Impression Investment Limited and its former responsible officer over staff trading activities

No description available.

AI Analysis

The SFC reprimanded and fined Impression Investment Limited (a Type 9 licensed asset manager) HK$2 million for inadequate supervision and internal controls over staff personal trading from 2016-2021, while banning former RO Mr. Liu Shan from the industry for 8 months starting 2 April 2026. This enforcement underscores the SFC's strict enforcement of staff dealing policies and conflict management under the Fund Manager Code of Conduct, highlighting risks to investor confidence from front-running-like activities. Compliance professionals must prioritize robust monitoring to avoid similar sanctions, as policies alone are insufficient without implementation.

What Changed

This is an enforcement action, not a new rule, but it reinforces existing requirements under the Fund Manager Code of Conduct (FMCC) and paragraph 12.2 of the Code of Conduct for Persons Licensed by or Registered with the SFC, mandating licensed corporations to implement and enforce staff dealing policies, including prior approvals, monitoring of personal trades (including related accounts), and conflict mitigation.

Suggested Considerations

Conduct gap analysis: Review staff dealing policies against FMCC and Code of Conduct para. 12.2; ensure prior written approvals, 30-day holding rules, and bans on same-day/same-security trades with managed funds.
Implement/enhance controls: Deploy automated pre- and post-trade monitoring for personal/related accounts; flag same-day trades, IPO overlaps, and price discrepancies.
Senior management accountability: ROs/manager-in-charge must actively supervise; document training on conflicts and policy enforcement.
Audit and remediate: Perform immediate staff account disclosures; test for undisclosed beneficial interests; retain records for SFC inspections.
Training: Mandatory annual sessions on FMCC compliance, with attestations of no external accounts or conflicts.

Key Dates

January 2016

March 2021; Period of staff personal trading breaches investigated by SFC

Prior to 2021

Impression's staff dealing policies not implemented/enforced

Since 2021

Impression implemented remedial post-trade monitoring

2 April 2026

1 December 2026; Mr. Liu Shan's 8-month industry ban (ends ~8 months later)

8 April 2026

SFC public announcement of sanctions (today's date marks proximity to ban start)

Compliance Impact

Urgency: High – This action signals SFC's 2026 focus on staff trading oversight gaps, with fines up to HK$2m and bans for ROs, directly eroding investor trust via perceived front-running. Firms without real-time monitoring risk similar scrutiny, especially post-2021 remediation expectations; non-compliance could trigger "fitness and properness" reviews amid rising enforcement (e.g., multiple 2025-2026 cases).

References

AI-generated analysis. May contain errors or omissions — verify with the original SFC source before acting. Full disclaimer.

Sectors:

Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

April 9th 2026

ASIC permanently bans former financial adviser and credit representative Aristotle Papapavlou

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Wealth ManagerAll Firms

Capital Markets & Trading Investment Management Crypto & Digital Assets

🇺🇸 SEC Enforcement medium

April 8th 2026

SEC Appoints David Woodcock as Director of the Division of Enforcement

The Securities and Exchange Commission today announced that David Woodcock has been appointed Director of the Division of Enforcement, effective May 4, 2026. Mr. Woodcock is currently a partner in the Dallas and Washington, D.C. offices of Gibson, Dunn…

AI Analysis

The SEC has appointed David Woodcock, a Gibson Dunn partner and former SEC Regional Director, as the new Director of its Division of Enforcement, effective May 4, 2026, following the abrupt resignation of prior Director Margaret Ryan after six months. This leadership change signals a "significant course correction" under Chairman Paul Atkins, emphasizing investor protection and market integrity over prior aggressive enforcement approaches. Compliance professionals should monitor this closely, as it may shift enforcement priorities, potentially de-emphasizing certain areas like crypto crackdowns while intensifying focus on accounting fraud and financial reporting violations.

What Changed

There are no direct regulatory changes or new requirements in this announcement; it is a personnel appointment rather than a rulemaking or policy shift. However, SEC Chairman Atkins highlighted the Division's ongoing "course correction" to prioritize cases aligned with congressional intent for meaningful investor protection and market integrity, moving away from prior Gensler-era emphases. Woodcock's background in securities enforcement, financial reporting, and audit task forces suggests potential heightened scrutiny in those areas, though no specific mandates are outlined.

Suggested Considerations

Review current exposure to SEC enforcement matters, particularly in financial reporting, accounting, and disclosures, in light of Woodcock's expertise.
Monitor SEC announcements post-May 4, 2026, for signals on evolving priorities, such as reduced crypto focus or enhanced fraud detection.
Enhance internal compliance training on investor protection and market integrity cases, aligning with the stated "course correction."
Engage external counsel familiar with Woodcock's tenure (e.g., Gibson Dunn alumni or Fort Worth Regional Office veterans) for strategic advice.

Key Dates

March 2026

- Prior Director Margaret Ryan resigned after approximately six months in the role amid reported disagreements on enforcement priorities

May 4, 2026

- David Woodcock assumes role as Director of the Division of Enforcement, succeeding Acting Director Sam Waldon

Compliance Impact

Urgency: Medium. This matters because leadership transitions at the Enforcement Division can reshape investigative priorities, resource allocation, and case selection for a team of over 1,000 professionals, influencing enforcement trends across securities violations. While not imposing new obligations, the shift from prior leadership—coupled with Atkins' emphasis on targeted investor protection—could reduce risks in deprioritized areas (e.g., crypto) but heighten them in core areas like accounting fraud, warranting vigilance ahead of the May 4 effective date.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Topics:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

Asset ManagerBroker DealerHedge Fund

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

April 8th 2026

ASIC bans former ISG Financial Services Limited director Benjamin Godfrey for 10 years

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News medium

April 3rd 2026

Law of 23 July 2016 (consolidated version) (being updated) (Updated)

concerning the audit profession

Sectors:

Topics:

Prudential / Capital Requirements Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerAsset Manager

Crypto & Digital Assets Capital Markets & Trading Payments & E-Money

🇱🇺 CSSF Guidance high

April 1st 2026

Circular CSSF 26/909

Application of the Guidelines of the European Securities and Markets Authority for the criteria on the assessment of knowledge and competence under the Markets in Crypto Assets Regulation (MiCA) (ESMA35-24871704-2922)

AI Analysis

Circular CSSF 26/909 specifies how the CSSF applies ESMA's Guidelines (ESMA35-24871704-2922) for assessing **knowledge and competence** criteria under MiCA, targeting staff involved in crypto-asset services. It matters because it enforces MiCA's staff certification requirements, ensuring Luxembourg CASPs meet EU-wide standards for consumer protection and operational integrity amid the full MiCA rollout on 30 December 2024.

What Changed

- Adoption of ESMA Guidelines: CSSF mandates application of ESMA's criteria for evaluating staff knowledge and competence in crypto-asset services, including roles in custody, trading, portfolio...
Assessment Framework: Firms must implement standardized tests and processes to verify staff qualifications, aligning with MiCA Article 62 on CASP authorization, focusing on technical crypto...
No New Standalone Rules: This circular builds on prior CSSF MiCA circulars (e.g., 25/890 on crypto-asset classification), integrating competence checks into licensing dossiers and ongoing supervision.

Suggested Considerations

Assess Staff Competence: Implement ESMA-guided evaluations (e.g., exams, certifications) for all relevant personnel handling crypto services; document results in governance frameworks.
Update Policies and Training: Integrate competence criteria into HR, onboarding, and annual reviews; roll out MiCA-specific training on reporting, breaches, and governance.
Licensing Dossier Enhancement: Include competence attestations in CSSF applications; appoint dedicated compliance/risk officers with verified qualifications.
Ongoing Monitoring: Conduct regular audits, penetration tests, and incident planning; confirm compliance annually via management body statements.
Early CSSF Engagement: Schedule dialogues and info sessions; create MiCA readiness scorecards for board and regulator discussions.

Key Dates

1 April 2026

Circular CSSF 26/909 published; immediate application of ESMA competence guidelines.; [User-provided content]

Compliance Impact

Urgency: High – With publication today (1 April 2026) and MiCA's CASP regime live since 30 December 2024, firms face immediate supervisory scrutiny during licensing and VASP transitions ending 1 July 2026. Non-compliance risks authorization denial, enforcement, or operational halts, especially as CSSF audits dossiers for competence gaps amid Luxembourg's role as MiCA hub.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Consumer Protection / Conduct

Crypto ExchangeBankFintech

Consumer Credit Insurance & Pensions Mortgage & Lending

🇮🇪 CBI Enforcement medium

April 1st 2026

Indefinite Prohibition issued to Nicholas (Nick) Buckley in respect of all controlled functions, effective from 25 February 2026

The Prohibition Notice (PDF) issued after Mr Buckley signed a Statement of Undisputed Facts, in which he accepted that between 1 February 2021 and 12 December 2023, while he was employed at two different retail intermediaries, he issued invoices to clients directing payment to his personal bank account in place of his employers’ bank details. Mr Buckley also accepted that he misrepresented his financial qualifications to clients during the course of his employment. The Prohibition Notice issu...

AI Analysis

The Central Bank of Ireland (CBI) has issued an indefinite prohibition to Nicholas (Nick) Buckley from all controlled functions, effective 25 February 2026, following his admission of diverting client payments to his personal account and misrepresenting financial qualifications while at two retail intermediaries from 1 February 2021 to 12 December 2023. This enforcement action underscores the CBI's commitment to the Fitness and Probity Regime, emphasizing integrity in customer-facing roles to maintain public trust. Compliance professionals should note it as a precedent for severe sanctions on dishonesty, potentially influencing vetting and monitoring practices.

What Changed

This is not a new regulation but an enforcement outcome under the existing Fitness and Probity Regime, established by the Central Bank Reform Act 2010, which mandates high standards of competence, integrity, and honesty for individuals in controlled functions. No regulatory changes are introduced; instead, it reinforces enforcement mechanisms, including investigations and prohibitions for breaches, particularly in customer-facing roles where honesty is paramount.

Suggested Considerations

Firms employing similar roles: Immediately review invoicing processes to ensure payments direct only to firm accounts, with segregation of duties and dual approvals for client billing.
Fitness and Probity assessments: Conduct enhanced due diligence on customer-facing staff, verifying qualifications via independent sources and monitoring for personal financial gain conflicts.
Incident reporting: Escalate any suspected integrity breaches (e.g., qualification misrepresentation or fund diversion) to CBI under fitness and probity notification obligations.
Training programs: Update mandatory training on Fitness and Probity Standards (available at https://www.centralbank.ie/regulation/fitness-and-probity), focusing on honesty in client interactions.
Prohibition checks: Screen all controlled function holders against CBI's public prohibitions list before approvals or role changes.

Key Dates

1 February 2021

12 December 2023; Period of Buckley's admitted misconduct (diverting payments and misrepresenting qualifications)

25 February 2026

Effective date of the indefinite prohibition on Buckley performing any controlled functions

01 April 2026

Publication date of the CBI press release announcing the Prohibition Notice

Compliance Impact

Urgency: Medium – This is a specific enforcement precedent rather than a new rule, but it signals heightened CBI scrutiny on integrity breaches in retail intermediation, with indefinite bans as a tool to protect consumers. It matters because customer-facing misconduct erodes trust, prompting firms to strengthen controls proactively to avoid similar investigations, especially given CBI Director of Enforcement's warning on accountability. Non-compliance risks firm-level sanctions, reputational damage, and operational disruptions.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Effective Date: 25 February 2026

Sectors:

Topics:

Consumer Protection / Conduct Senior Managers / Governance Authorisation & Licensing

Wealth ManagerBroker DealerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

April 1st 2026

Three public companies fined more than a million dollars for breaching financial reporting and company officer obligations

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

BankAsset ManagerWealth Manager

Capital Markets & Trading Wealth & Private Banking

🇸🇬 MAS Enforcement high

April 1st 2026

Key Enforcement Actions Taken by MAS in Q1 2026

The table below provides an overview of the key public enforcement actions taken by the Monetary Authority of Singapore (“MAS”) from January to March 2026.

AI Analysis

This MAS publication summarizes key public enforcement actions in Q1 2026, focusing on prohibition orders (POs) against individuals for investor fraud and money laundering, plus a joint operation against a licensed firm for AML failures and related offences. It matters as it underscores MAS's aggressive enforcement on financial crime, individual accountability, and firm controls, signaling heightened scrutiny to protect Singapore's financial centre integrity.[MAS publication]

What Changed

This is not a regulatory change document but a retrospective enforcement summary; no new requirements are imposed. It highlights MAS's ongoing application of existing powers under the Financial Services and Markets Act 2022 (FSMA), Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA), and related frameworks, emphasizing deterrence via POs, composition penalties, civil penalties, and criminal referrals.[MAS publication] Related context shows MAS reinforcing AML/CFT expectations, such as robust controls, senior management oversight, and escalation of...

Suggested Considerations

Conduct immediate AML/CFT control gap assessments, focusing on customer due diligence (CDD), transaction monitoring, source-of-funds verification, and suspicious transaction reporting (STR) timelines; integrate proliferation financing (PF) risks.
Enhance senior management oversight and accountability, ensuring compliance functions are resourced and independent; review director/representative conduct for fraud or ML risks.[MAS publication]
For CMS licensees and LFMCs: Update risk assessments for high-risk clients (e.g., trusts, beneficial ownership), automate quarterly reporting (e.g., QDC for mandates >SGD 500m), and train staff on accelerated STRs.
Perform thematic reviews of past flagged transactions and escalate unresolved suspicious activities to avoid composition penalties or POs.
All FIs: Prepare for heightened MAS inspections by documenting governance, including liquidity frameworks and cyber/AI risks tied to financial crime.

March 27th 2026

Councils,The third meeting of the Expert Panel on the Revision of the Corporate Governance Code (2025-2026)

No description available.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance

BankWealth Manager

Banking & Credit Capital Markets & Trading Investment Management

🇪🇺 ECB Enforcement critical

March 27th 2026

ECB sanctions BofA Securities Europe SA for breaching reporting requirements

No description available.

AI Analysis

The ECB imposed a €6.2 million penalty on BofA Securities Europe SA for intentionally breaching market risk reporting requirements between 2022 and 2024. The bank systematically underreported risk-weighted assets by including unauthorized sovereign bond option positions in its internal models, resulting in inflated capital ratios and misrepresented financial strength—a "severe" breach that signals the ECB's heightened enforcement focus on reporting accuracy and internal control governance.

What Changed

This enforcement action does not introduce new regulatory requirements but rather clarifies existing obligations:
Internal Models Scope Limitation: Banks must strictly adhere to supervisory permissions when applying internal models approaches; unauthorized asset classes cannot be included regardless of...
Risk-Weighted Asset Accuracy: RWA calculations must reflect actual supervisory permissions, not theoretical modeling capabilities
Capital Ratio Integrity: Misreporting of RWAs directly affects CET1 ratios and capital adequacy disclosures, which are fundamental to regulatory reporting
Intentionality Standard: The ECB's classification of this breach as "intentional" (rather than negligent) indicates that awareness of supervisory limitations combined with non-compliance triggers...

Suggested Considerations

*Immediate (for all firms with internal models):
*Audit Internal Models Scope: Conduct comprehensive review of all asset classes currently included in internal models approaches to confirm supervisory permission exists for each category
*Verify Sovereign Bond Derivatives Treatment: Specifically validate that all sovereign bond options, forwards, and other derivatives are explicitly covered by supervisory approval documentation
*Reconcile RWA Calculations: Recalculate historical RWAs (at minimum for the past 3-5 years) to identify any unauthorized inclusions and assess whether prior reporting was accurate
*Strengthen Internal Controls: Implement automated controls to prevent unauthorized asset classes from being included in model calculations, with documented supervisory permission matrices

Key Dates

2022

2024; - Period during which BofA Securities Europe SA committed the breach across six consecutive reporting periods

27 March 2026

- ECB penalty announcement and effective date

Ongoing DEADLINE

- Bank has the right to challenge the decision before the Court of Justice of the European Union (no statutory deadline specified, but typically within 2 months of notification)

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original ECB source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankBroker Dealer

🇬🇧 FCA Consultation medium

March 27th 2026

Investment trust votes, conflicts of interest, and our role

On 3 March 2026, we said we’d bring forward our planned review of the UK Listing Rules for Investment entities, including how they apply to board independence and related party provisions.Since then, there has been substantial debate over our role in relation to investment trusts, including calls for us to ‘get to grips’ with voting rules ‘that allow a minority shareholder to repeatedly attack an investment trust’.Much of this debate suggests there are misunderstandings about how investment t...

AI Analysis

This FCA blog post announces an accelerated review of UK Listing Rules for investment entities, focusing on board independence, related party provisions, conflicts of interest, and shareholder rights amid debates over activist minority shareholders targeting investment trusts. It matters because it clarifies the FCA's limited role (rules apply to issuers, not shareholders), reinforces Companies Act protections, and signals upcoming proposals to ensure rules fit novel scenarios like concentrated ownership, potentially impacting governance and listing compliance for investment trusts.[FCA blog]

What Changed

No immediate regulatory changes or new requirements are introduced; this is a consultation precursor outlining a planned review. The review will assess:
Application of Listing Rules to board independence and related party transactions for investment entities.
How rules, alongside company law, support shareholder rights, engagement, and conflict management (e.g., protecting against "back door takeovers" by minority activists like Saba). Proposals will be...

Suggested Considerations

Monitor and engage: Investment trust boards/managers should track the upcoming consultation (expected end-2026) and consider submitting responses on board independence, conflicts, and shareholder protections.[FCA blog]
Review governance: Assess articles of association for voting enhancements (e.g., electronic voting, opt-ins) and ensure boards understand powers to challenge vexatious requisitions under Companies Act.[FCA blog]
Enhance shareholder engagement: Platforms and intermediaries to digitize voting processes; firms to promote high turnout (recently >80%) and clear information on director nominations.[FCA blog]
Conflict checks: Proactively manage related party issues and concentrated ownership risks in line with current Listing Rules, anticipating review focus.

Key Dates

End of 2026

- FCA to complete review and publish consultation paper with proposals.[FCA blog]

3 March 2026

- FCA announces acceleration of planned Listing Rules review for investment entities.[FCA blog]

Compliance Impact

Urgency: Medium. This signals future changes via consultation but imposes no immediate obligations; however, it heightens scrutiny on investment trust governance amid activist pressures, risking enforcement if conflicts or independence lapses occur pre-review. Matters for compliance teams to audit current setups against Listing Rules and Companies Act, avoiding missteps in high-profile cases like Saba campaigns, while preparing for end-2026 proposals that could tighten related party and board rules.[FCA blog]

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇮🇪 CBI News low

March 27th 2026

Central Bank Appointments

The Central Bank Commission has appointed Elizabeth Mahon as Secretary of the Central Bank, effective 30 March. Elizabeth has also been appointed to the role of Head of Governance in the Central Bank. Elizabeth has more than 20 years' experience in financial services, principally in the banking sector, where her career has focused on strategy and implementation, management consulting, organisational change, and stakeholder management. Since 2022 she has worked at the Central Bank as Head of S...

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance Authorisation & Licensing

BankWealth Manager

🇬🇧 PRA Guidance high

March 26th 2026

SS9/17 - Recovery planning

Supervisory Statement 9/17

AI Analysis

**SS9/17 - Recovery Planning** is the PRA's supervisory statement establishing expectations for how UK banks, building societies, and designated investment firms must prepare and maintain recovery plans to ensure financial stability during periods of stress. This guidance supersedes the previous SS18/13 and represents a substantial tightening of recovery planning requirements, making credible, testable, and executable recovery plans a core component of prudential regulation rather than a compliance checkbox.

What Changed

SS9/17 introduced several material enhancements to recovery planning requirements: Governance and Integration: Recovery planning must be embedded within firms' risk management frameworks, with board-level oversight and integration with stress testing and ICAAP processes. The PRA expects clear governance documentation showing how plans are produced, reviewed, signed off, and implemented. Fire Drill Exercises: Firms must conduct regular fire drill exercises that simulate recovery scenarios in a live environment, testing governance arrangements, management information systems, and the...

Suggested Considerations

*Develop comprehensive recovery plans containing all minimum elements specified in the Recovery Planning Part of the PRA Rulebook and detailed in SS9/17
*Establish governance frameworks documenting how recovery plans are produced, reviewed, approved by the board, and how recovery options would be implemented
*Conduct fire drill exercises that simulate recovery scenarios, test governance arrangements, and validate management information capabilities
*Create implementation playbooks (for complex plans) that enable rapid execution by senior management during stress
*Perform detailed impact analysis for each recovery option, quantifying capital and liquidity impacts with realistic timelines

Key Dates

Second half of 2017

- Proposed implementation date for superseding SS18/13 (achieved with December 2017 publication)

21 September 2017 DEADLINE

- PRA consultation deadline for CP9/17 (the consultation paper preceding this statement)

11 December 2017

- SS9/17 first published and became effective

Ongoing DEADLINE

- Firms must maintain and test recovery plans continuously; the PRA notes this statement "may be revised as recovery planning becomes further embedded in firms' risk management practices"

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

Topics:

BankAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇦 OSFI News

March 26th 2026

Superintendent Routledge to participate in virtual fireside chat at Bank of America Expert Insights Series on March 30, 2026

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankAsset ManagerWealth Manager

🇬🇧 BoE Enforcement high

March 24th 2026

PRA fines The Bank of London and its parent company Oplyse Holdings Limited £2m for failing to act with integrity and misleading the PRA over their capital position

The Prudential Regulation Authority (PRA) has fined The Bank of London Group Limited and Oplyse Holdings Limited (formerly The Bank of London Group Holdings Limited) £2 million for misleading the PRA over their capital positions, failing to act with integrity, failing to be open and cooperative with the regulator and failing to maintain adequate financial resources.

AI Analysis

The Prudential Regulation Authority (PRA) fined The Bank of London Group Limited and its parent Oplyse Holdings Limited £2 million (reduced from £12 million due to financial hardship) for serious breaches including misleading the regulator with fabricated documents on capital positions, failing to act with integrity, lacking openness, and breaching capital and large exposure rules from October 2021 to May 2024. This marks the PRA's first enforcement for integrity failures and first action against a parent holding company, signaling heightened scrutiny on governance, reporting accuracy, and parent-subsidiary accountability in UK banking. Compliance professionals should note this as a precedent reinforcing zero tolerance for deceptive practices, with potential for escalated penalties absent settlement or hardship claims.

What Changed

This enforcement action does not introduce new rules but enforces existing PRA requirements with landmark application:
First PRA fine for breaching Fundamental Rule 1 (conduct business with integrity), highlighting fabrication of documents as a core violation.
First enforcement against a parent financial holding company (Oplyse Holdings), extending liability to group entities for capital reporting and related party exposures.
Emphasizes strict adherence to Fundamental Rules 3, 4, and 7 (prudence, adequate resources, openness), CRR reporting (e.g., own funds on individual/consolidated basis), Large Exposures rules...

Suggested Considerations

Conduct capital position audits to verify CRR reporting accuracy (individual and consolidated own funds) and remediate any discrepancies.
Review intra-group exposures for large exposure limits (Articles 393-395), related party transactions (Rules 2.1/2.3), and notification obligations.
Enhance governance controls for integrity (Fundamental Rule 1), including document fabrication prevention, timely solvency disclosures (Fundamental Rule 7), and prudent management (Fundamental Rule 3).
Stress-test parent-subsidiary interactions and ensure openness with PRA on deteriorating positions.
Update training on PRA enforcement policies (PS1/24) and bank supervision (SS3/21).

Key Dates

7 October 2021 DEADLINE

22 May 2024; Period of identified breaches, including capital non-compliance, misleading submissions, and large exposure failures

Compliance Impact

Urgency: High – This sets a precedent for integrity-based fines and parent company liability, risking similar actions for any firm with capital misreporting or opaque group dealings; even settled penalties were reduced only due to hardship, indicating PRA's willingness to pursue £12m+ originally. Matters critically for banks/fintechs with complex structures, as it amplifies personal accountability under Senior Managers Regime and erodes trust, potentially triggering closer PRA supervision or prohibitions.

References

AI-generated analysis. May contain errors or omissions — verify with the original BoE source before acting. Full disclaimer.

Sectors:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

Topics:

BankFintech

Investment Management Capital Markets & Trading Wealth & Private Banking

🇭🇰 SFC Enforcement high

March 24th 2026

SFC bans Lui Pak Tong for life and fines him $17.43 million for misconduct

No description available.

AI Analysis

The SFC has imposed a **lifetime ban and $17.43 million fine** on Lui Pak Tong for orchestrating a scheme where he exploited a fund under his control by directing $22.5 million in unsecured loans to a company he owned, while concealing conflicts of interest and diverting loan proceeds to himself and associates. This enforcement action demonstrates the SFC's aggressive stance on fiduciary breaches, undisclosed conflicts of interest, and self-dealing by licensed representatives, with direct implications for fund governance, investment committee oversight, and compliance with the Code of Conduct.

What Changed

This is not a regulatory change but rather an enforcement precedent establishing the SFC's expectations regarding:
Conflict of Interest Disclosure: Licensed representatives must fully disclose all material conflicts of interest to investment committees and fund stakeholders, particularly when recommending...
Fiduciary Duty Standards: Fund managers and their representatives must ensure fair treatment of fund investors and cannot exploit their position to divert fund assets or loan proceeds to themselves...
Investment Committee Governance: Investment committees cannot rely solely on recommendations from conflicted parties without independent verification and proper conflict management protocols.
Connected Party Transactions: Unsecured loans to connected entities require heightened scrutiny, independent approval, and ongoing monitoring to prevent asset diversion.

Suggested Considerations

*Immediate Actions (0-30 days):
*Conflict of Interest Audit: Conduct a comprehensive review of all current and recent transactions involving connected parties, including loans, investments, or service arrangements where licensed staff have beneficial interests.
*Policy Review: Update or strengthen conflict of interest policies to explicitly require:
Written disclosure of all material conflicts before investment committee meetings
Independent review and approval of transactions involving conflicted parties

Key Dates

25 July 2017 – 31 August 2020

Period during which Lui held licenses for Types 1, 4, and 9 regulated activities

September 2017 – June 2020

Period during which the misconduct occurred (five unsecured loans totalling $22.5 million extended to Lui's controlled company)

31 July 2024

Thunder Capital Limited's (later renamed Yupei Fortune Capital Limited) SFC licence was revoked

24 March 2026

SFC announcement of lifetime ban and $17.43 million fine

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original SFC source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Senior Managers / Governance Authorisation & Licensing

Asset ManagerWealth ManagerBroker Dealer

Banking & Credit Wealth & Private Banking

🇱🇺 CSSF News

March 23rd 2026

Mr Davy Reinard sworn in by the Minister of Finance as Director Resolution (only in French)

Press release 26/07

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance

Bank

Banking & Credit Mortgage & Lending Investment Management

🇬🇧 FCA policy_statement critical

March 20th 2026

Investigation into Market Financial Solutions Limited

We have opened an enforcement investigation into Market Financial Solutions Limited (MFS). MFS is an Annex 1 business, which is solely registered with and supervised by us for its compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.Annex 1 registered firms are not authorised or subject to wider FCA regulation.MFS entered administration on 25 February 2026.

AI Analysis

The FCA has opened an enforcement investigation into Market Financial Solutions Limited (MFS) following the firm's entry into administration on 25 February 2026, amid allegations of serious financial irregularities, fraud, and double-pledging of collateral. This investigation is significant because it represents regulatory scrutiny of an Annex 1 business—a firm with limited FCA oversight—whose collapse exposed structural weaknesses in private credit markets and raised questions about due diligence practices across the financial sector.

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

BankAll Firms

Banking & Credit Consumer Credit

🇬🇧 FCA News high

March 20th 2026

FCA orders Beauforce Corporation to stop operating and return client money

We have restricted Beauforce Corporation Limited from carrying out any regulated activities. This means it cannot provide regulated debt advice or debt management services to consumers. We have also ordered the firm to return money held in its bank accounts to its clients.We’ve taken this action following concerns about the suitability of the firm’s senior management and its conduct in dealing with us. Read the full Notice (PDF)

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

All Firms

🇱🇺 CSSF News

March 20th 2026

List of members of the Investment Fund Managers Committee (Updated)

No description available.

Sectors:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

Topics:

Asset ManagerWealth ManagerBank

🇭🇰 SFC Enforcement high

March 19th 2026

SFC bans Kuo Che-jung for four and a half years and fines him $1 million

No description available.

AI Analysis

The SFC has banned former responsible officer Kuo Che-jung from the industry for 4.5 years (effective 19 March 2026 to 18 September 2030) and fined him HK$1 million for executing 25 matched trades in Hang Seng Index options between Yuanta's proprietary account and his wife's secret account, plus concealing beneficial interests and submitting false declarations. This enforcement action underscores the SFC's zero-tolerance for market abuse via matched trades, staff dealing violations, and dishonesty, signaling heightened scrutiny on proprietary traders and internal controls to protect market integrity. Compliance professionals must prioritize robust staff trading surveillance and disclosure enforcement to mitigate similar risks.

What Changed

This is an enforcement decision, not a new rule or circular introducing regulatory changes. It reinforces existing requirements under the Securities and Futures Ordinance (SFO), particularly:
Prohibitions on matched trades (defined as coordinated buy-sell transactions at non-market prices creating false trading appearances, per Note 2 in the publication), which can distort price formation...
Staff dealing policies mandating full disclosure of personal accounts, beneficial ownership, and trading activities; concealment via false declarations breaches fitness and properness standards for...
Accountability for responsible officers (ROs) in Type 1 (dealing in securities) and Type 2 (dealing in futures contracts) activities, where proprietary trading must not favor personal interests over...

Suggested Considerations

Conduct immediate staff dealing audits: Review disclosures for accuracy, verify beneficial ownership in spouse/associate accounts, and cross-check against trading records (https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=26PR44).
Enhance trading surveillance: Implement real-time monitoring for matched trades (e.g., coordinated patterns outside bid-ask spreads in derivatives like Hang Seng Index options); flag proprietary vs. personal account interactions.
Update internal policies: Strengthen RO oversight, mandatory training on SFO market misconduct rules, and escalation protocols for false declarations.
Firm-wide attestation: Require annual (or more frequent) certifications of no undisclosed accounts; integrate with pre-trade controls.
Risk assess proprietary trading: Segregate duties to prevent self-dealing; report suspicious patterns to SFC promptly.

Key Dates

21 November 2019 to 23 June 2025

- Kuo's tenure as RO for Type 1 and Type 2 at Yuanta

2 July 2020 to 24 November 2020

- Period of matched trades and secret account operations

19 March 2026

- Ban commencement date (today, marking start of 4.5-year prohibition)

18 September 2030

- Ban end date

Compliance Impact

Urgency: High - Demonstrates SFC's aggressive 2026 enforcement wave (e.g., multiple bans, fines >HK$20M, asset freezes), with matched trades directly harming firm interests and market fairness. Firms face reputational damage, fines, and RO suspensions if controls fail; proprietary desks in volatile products like index options are prime targets. Act now to audit, as ban starts today and signals broader crackdown on hidden conflicts.

References

AI-generated analysis. May contain errors or omissions — verify with the original SFC source before acting. Full disclaimer.

Sectors:

Market Abuse / Surveillance Authorisation & Licensing Senior Managers / Governance

Topics:

Broker DealerAll Firms

Capital Markets & Trading Investment Management

🇪🇺 ESMA News low

March 18th 2026

SEC confirms exemption for directors and officers of EEA Foreign Private Issuers

SEC confirms exemption for directors and officers of EEA Foreign Private Issuers 18 March 2026 Market Abuse Post Trading The United States Securities and Exchange Commission (SEC) has decided to exempt directors and officers of European Economic Area (EEA) foreign private issuers (FPIs) from the reporting requirements under Section 16(a) of the US Securities Exchange Act of 1934. The SEC’s decision means that directors and officers of EEA FPIs will not be required to comply with these specifi...

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Asset ManagerBroker DealerBank

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News

March 17th 2026

DORA – Register of Information collection - Update

No description available.

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇸🇬 MAS Enforcement high

March 17th 2026

MAS Issues Prohibition Orders against former Relationship Managers, Mr Wang Qiming and Mr Liu Kai

Singapore, 17 March 2026 … The Monetary Authority of Singapore (MAS) has issued Prohibition Orders (POs) under the Financial Services and Markets Act 2022 (FSMA) against Mr Wang Qiming and Mr Liu Kai, former relationship managers, who were convicted of charges connected to the major money laundering case of August 2023. Given the gravity of their misconduct, MAS has issued a 16-year PO against Mr Wang Qiming and a 7-year PO against Mr Liu Kai.

AI Analysis

The Monetary Authority of Singapore (MAS) issued Prohibition Orders (POs) on 17 March 2026 under the Financial Services and Markets Act 2022 (FSMA) against former relationship managers Wang Qiming (16-year PO) and Liu Kai (7-year PO) for convictions tied to Singapore's S$3 billion money laundering scandal of August 2023. This enforcement action underscores MAS's rigorous application of fit and proper criteria, barring them from regulated activities due to forgery, money laundering, and related offences. It matters for compliance professionals as it signals heightened scrutiny on individual accountability in AML failures within wealth management.

What Changed

This is not a new regulation but an enforcement action applying existing FSMA powers. Key elements include:
MAS deeming individuals "not fit and proper" under Guidelines on Fit and Proper Criteria (section 7, FSMA), based on convictions for forgery (Penal Code), money laundering (Corruption, Drug...
POs prohibit: (i) carrying on MAS-regulated activities; (ii) direct/indirect management of financial institutions; (iii) acting as director/partner/manager of financial institutions; (iv)...
Durations reflect misconduct gravity: 16 years for Wang (four convictions, 24 months' jail, six taken into consideration); 7 years for Liu (one conviction, 4 months' jail). No broader regulatory...

Suggested Considerations

Screen existing/prospective staff: Immediately verify no employment of Wang/Liu or prior prohibited individuals (e.g., via MAS enforcement list); cease any roles if discovered.
Enhance RM onboarding/monitoring: Review KYC/CDD for HNWIs, especially from high-risk jurisdictions (e.g., Fujian-linked); audit forgery detection in documents.
Senior manager accountability: Ensure policies for AML audits, risk assessments; train on fit and proper obligations under FSMA Guidelines.
Report breaches: Disclose any inadvertent involvement to MAS promptly.
Firm-wide review: For scandal-linked FIs (e.g., 9 fined S$27.45m, 4 Blue Ocean staff POs), confirm remediation; others benchmark controls against MAS actions.

Key Dates

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankAsset ManagerWealth Manager

Capital Markets & Trading Investment Management Banking & Credit

🇺🇸 SEC Enforcement high

March 16th 2026

SEC Announces Enforcement Division Director Judge Margaret A. Ryan Has Resigned From Agency

The Securities and Exchange Commission today announced that Judge Margaret A. Ryan has resigned from her role as Director of the Division of Enforcement. Principal Deputy Director Sam Waldon has been named Acting Director of the Division, effective March…

AI Analysis

Judge Margaret A. Ryan, who assumed the role of SEC Enforcement Division Director in August 2025 and signaled a significant recalibration of enforcement priorities toward fraud and market integrity while reducing enforcement actions for technical violations, has resigned from the agency. Principal Deputy Director Sam Waldon has been named Acting Director, creating immediate uncertainty regarding continuity of the enforcement approach that was just articulated in February 2026 and may signal a shift in the SEC's enforcement trajectory going forward.

What Changed

The resignation itself does not constitute a regulatory change, but it creates operational uncertainty regarding the enforcement priorities and procedural reforms that Director Ryan had recently...
Reduced enforcement for technical violations: Director Ryan had signaled that routine violations concerning reporting requirements, recordkeeping, and internal accounting controls should not...
"Middle ground" approach: For non-fraud violations posing investor or market integrity risks, the Division was to pursue resolutions emphasizing remediation over punishment.
Continued fraud focus: The Division was to maintain rigorous enforcement on fraud, insider trading, market manipulation, and scams targeting retail investors. Enforcement Manual Updates (Effective...
Four-week timeline for post-Wells meetings with senior leadership (Associate Director level or above)

Suggested Considerations

*Immediate (Next 30 Days):
*Monitor Acting Director's statements: Compliance teams should closely track any public remarks or guidance from Acting Director Sam Waldon regarding enforcement priorities and procedural expectations.
*Assess Wells submissions in progress: For entities with pending Wells submissions, evaluate whether the change in leadership creates opportunities to supplement submissions or request expedited meetings under the four-week timeline.
*Review investigation status: Entities in early-stage investigations should assess whether the leadership transition may affect investigation trajectory or resolution opportunities.
*Update compliance calendars: Ensure all enforcement-related deadlines and procedural requirements under the updated Enforcement Manual remain tracked and current.

Key Dates

February 11, 2026

- Director Ryan delivered public remarks outlining enforcement priorities and Wells process commitments

February 24, 2026

- SEC announced comprehensive updates to Enforcement Manual (first update since 2017)

March 17, 2026

- Judge Margaret A. Ryan's resignation announced; Sam Waldon named Acting Director (effective immediately)

Ongoing

- Four-week timeline for post-Wells meetings with senior leadership remains in effect pending Acting Director's confirmation of policy continuity

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Topics:

Reporting & Disclosure Senior Managers / Governance Authorisation & Licensing

Broker DealerAsset ManagerBank

Consumer Credit Banking & Credit Mortgage & Lending

🇬🇧 FCA Guidance critical

March 16th 2026

Creating a redress system that works better for consumers and firms

We’ve reached a significant milestone in our joint work with the Financial Ombudsman Service and the Government to modernise the redress systemso that consumers get fair outcomes quicker and firms have greater clarity about how issues will be handled.We’re delivering change at speed by acting now within our current powers, with a focus on improving how the system works in practice. This includes a new registration stage for complaints, updated dismissal grounds and clearer guidance on the fai...

AI Analysis

The FCA, in collaboration with the Financial Ombudsman Service (FOS) and the Government, has announced modernization of the UK's financial redress system to accelerate consumer compensation and provide firms with greater regulatory clarity. This initiative represents a fundamental shift in how complaints are registered, assessed, and resolved, with immediate implementation underway within existing FCA powers and broader legislative reforms planned.

What Changed

The redress system modernization introduces several structural and procedural reforms: Registration Stage for Complaints A new formal registration stage has been introduced to standardize how complaints enter the system, improving tracking and early identification of systemic issues across firms and markets. Updated Dismissal Grounds The FCA has revised the criteria for dismissing complaints, providing clearer standards that should reduce disputes about complaint admissibility and improve consistency in decision-making. Enhanced Fair and Reasonable Test Guidance Clearer guidance on how the...

Suggested Considerations

*Immediate Operational Priorities (Pre-May 2026):
*Governance and Accountability
Appoint senior managers with explicit accountability for complaints handling and redress programmes
Establish board-level oversight structures with regular reporting on complaints volumes, redress calculations, and regulatory compliance
Document decision-making frameworks for complaint eligibility and dismissal grounds

Key Dates

Before end of 2026

- Consumers expected to begin receiving compensation under motor finance scheme

End of March 2026

- FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales

31 May 2026 DEADLINE

- Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes

Mid

2026 onwards; - Motor finance compensation payments anticipated to commence

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

BankFintechPayment Provider

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News low

March 16th 2026

SSM Calendar Claude Wampach – 12/2025

No description available.

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankWealth ManagerAsset Manager

🇭🇰 SFC Speech

March 13th 2026

New speech by Kelvin Wong: Remarks at The Hong Kong Independent Non-Executive Director Association’s Spring Luncheon 2026

No description available.

Sectors:

Consumer Protection / Conduct Senior Managers / Governance

Topics:

Asset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

March 12th 2026

ASIC disqualifies Simon Raftery from managing corporations for two and a half years

Sectors:

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

BankWealth ManagerAll Firms

Investment Management Wealth & Private Banking Capital Markets & Trading

🇱🇺 CSSF Guidance high

March 12th 2026

List of professional activities and mandates performed by members of the management body/governing body and by conducting officers (points 105 and 107 of Circular CSSF 18/698) (Updated)

Table listing the professional activities and the mandates performed

AI Analysis

This CSSF publication is an updated table (in XLSX format) listing standardized professional activities and mandates for members of the management body/governing body and conducting officers, as required under points 105 and 107 of Circular CSSF 18/698. It matters because it ensures consistent, transparent reporting of senior personnel roles in Luxembourg investment fund managers (IFMs), supporting governance, conflict-of-interest management, and CSSF supervisory oversight. Compliance professionals must use this list to standardize disclosures in authorization files and ongoing reporting.

What Changed

The document was originally published on 14 January 2019 and updated on 12 March 2026, reflecting revisions to the predefined list of professional activities and mandates[Source URL].
Alignment with Circular CSSF 18/698 requirements for IFMs (management companies for UCIs and AIFs), specifying reportable roles like those in collective portfolio management, risk management,...
Emphasis on detailed documentation of mandates to demonstrate fitness, properness, and avoidance of conflicts, including for shareholders with qualifying holdings.
No entirely new requirements introduced, but the update likely incorporates evolving governance expectations, such as enhanced delegate oversight and AML/CFT compliance officer designations.

Suggested Considerations

Download and use the XLSX table: Incorporate the exact list of activities/mandates into internal templates for reporting management body and conducting officer roles[Source URL].
Update authorization and notification files: Include detailed CVs, criminal record extracts, wealth declarations, and organization charts for relevant personnel/shareholders; notify CSSF of changes (e.g., qualifying holdings, guarantees).
Conduct fit-and-proper assessments: Ensure declarations cover all listed mandates, demonstrating no conflicts and adequate resources; perform initial/ongoing due diligence on delegates.
Annual compliance review: Document roles in compliance monitoring plans, training, and reporting to senior management/CSSF; align with delegate oversight (e.g., risk-based monitoring of compliance, audit functions).
Policy updates: Revise governance policies to reflect the updated list, including AML/CFT officer designations and own funds proofs.

Key Dates

23 August 2018

- Publication of underlying Circular CSSF 18/698, setting baseline requirements

14 January 2019

- Original publication of the list

12 March 2026

- Latest update to the list, requiring immediate review and integration into reporting processes[Source URL]

End of May (post DEADLINE

financial year); - Compliance deadline for Circular 18/698 obligations, including governance reporting (e.g., 5 months after year-end)

Compliance Impact

Urgency: High – The March 12, 2026 update coincides with today's date, demanding immediate review to avoid supervisory findings during CSSF inspections or authorization processes. Non-compliance risks authorization delays, fines, or reputational damage, as Circular 18/698 emphasizes robust governance in a heightened scrutiny environment for IFMs (e.g., delegate oversight, AML).

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Reporting & Disclosure Authorisation & Licensing

Asset ManagerBankAll Firms

🇬🇧 BoE Enforcement high

March 11th 2026

PRA fines U K Insurance Limited £10,625,000

The Prudential Regulation Authority (PRA) has imposed a financial penalty of £10,625,000 on U K Insurance Limited (UKI Limited) in connection with a miscalculation of their Solvency II balance sheet during 2023 and 2024.

AI Analysis

The PRA fined U K Insurance Limited (UKI Limited) £10.625 million (reduced from £21.25 million via 50% Early Account Scheme discount) for breaching Solvency II reporting rules due to a miscalculation overstating its solvency balance sheet in 2023-2024, stemming from ineffective controls and resourcing in finance/actuarial functions. This landmark case highlights PRA's emphasis on accurate prudential reporting and rewards early self-reporting/cooperation, signaling heightened enforcement scrutiny on insurers' control frameworks. It matters as it demonstrates PRA's use of the EAS for efficiency and underscores risks of control failures undermining supervisory effectiveness.

What Changed

No new regulatory rules or requirements are introduced; this is an enforcement action applying existing PRA rules. Key breaches include:
PRA Fundamental Rule 6: Failure to organise/control affairs responsibly/effectively due to ineffective preventative/detective controls and resourcing issues.
Notifications Rule 6.1: Information to PRA not factually accurate or complete.
Reporting Rules 2.4 and 3.2: Submissions lacked completeness, reliability, and compliance with SFCR structure/principles. This is the first EAS application, per PRA's enforcement approach (pages...

Suggested Considerations

Conduct control reviews: Assess finance/actuarial functions for preventative/detective control gaps, resourcing adequacy, and documentation (e.g., double-counting risks in Solvency II balance sheets).
Test reporting accuracy: Validate Solvency II submissions (e.g., SFCR, SCR Coverage Ratio) against Rules 6.1, 2.4, 3.2; ensure factual accuracy, completeness, and reliability.
Leverage EAS: Self-report errors early, provide candid root-cause analyses, and make admissions to qualify for penalty discounts.
Remediate proactively: Invest in control enhancements, as UKI did post-identification; align with PRA 2026 priorities on data quality, internal models, and operational resilience.
Document governance: Address longstanding resourcing concerns, per PRA's 2023 PSM letter risks.

Key Dates

2023

2024; Relevant period of miscalculation and breaches

13 August 2024

Firm notified PRA of error with preliminary root cause analysis

23 August 2024

Public disclosure via Regulatory News Service on SCR Coverage Ratio impact

1 July 2025

Aviva acquired DLG/UKI Limited (events pre-date)

10 March 2026

PRA issued Final Notice and imposed penalty

Compliance Impact

Urgency: High – This enforcement validates PRA's zero-tolerance for solvency misreporting, risking supervisory misjudgment and policyholder threats; firms face similar fines without EAS discounts. It amplifies 2026 priorities on internal models, data quality, and controls amid softening markets/BPA pressures, demanding immediate control audits to avoid escalation.

References

AI-generated analysis. May contain errors or omissions — verify with the original BoE source before acting. Full disclaimer.

Sectors:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

Topics:

InsuranceAll Firms

Banking & Credit Capital Markets & Trading Payments & E-Money

🇺🇸 CFTC News medium

March 9th 2026

CFTC Announces Marc H. Sielski as Executive Director

No description available.

Sectors:

Topics:

Operational Resilience / Outsourcing Authorisation & Licensing Senior Managers / Governance

BankBroker DealerFintech

Capital Markets & Trading Crypto & Digital Assets

🇺🇸 CFTC News medium

March 6th 2026

CFTC Chairman Selig Announces Departure of Senior Advisor Brigitte Weyls

No description available.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance

Broker DealerCrypto Exchange

🇱🇺 CSSF Enforcement medium

March 6th 2026

Administrative sanction of 2 December 2025

Administrative sanction imposed on a réviseur d’entreprises agréé

AI Analysis

The CSSF imposed an administrative sanction on 2 December 2025 against an approved statutory auditor (*réviseur d’entreprises agréé*) for breaches of professional obligations, likely related to continuing education requirements under Luxembourg's Audit Law, mirroring patterns in recent similar cases. This enforcement action underscores the CSSF's rigorous oversight of audit professionals, emphasizing compliance with ongoing training mandates to maintain audit quality and market integrity. Compliance professionals should note it as evidence of heightened scrutiny on non-delegable professional duties.

What Changed

This is not a regulatory change or new requirement but an enforcement action applying existing rules under point f) of Article 43(1) read with point a) of Article 43(2) and Article 44 of the Law of 23 July 2016 on the audit profession (Audit Law), alongside CSSF Regulation N°16-10 on continuing education.

Suggested Considerations

Immediate self-audit: Statutory auditors must verify personal compliance with continuing education hours under CSSF Regulation N°16-10, documenting hours against Article 3(1) requirements and submitting evidence if requested.
Remediation plan: If shortfalls identified, complete deficit training promptly and notify CSSF of corrective measures, as seen in related governance cases where entities implemented remediation.
Internal training programs: Audit firms should enhance monitoring of auditor CPE (continuing professional education) logs, integrating CSSF controls akin to Article 10 of the Audit Law.
Fit-and-proper reviews: Boards and compliance officers assess auditor qualifications, escalating any gaps to CSSF per professional obligations.
Record retention: Maintain verifiable CPE records for at least the reference period plus CSSF inspection windows (typically 3-5 years).

Key Dates

31 December 2024 DEADLINE

- Likely reference period end for continuing education non-compliance (inferred from identical prior case)

2 December 2025

- Date of administrative sanction imposition by CSSF

6 March 2026

- Publication date of the sanction notice (today's date, aligning with CSSF practice for transparency under Article 48(2) of the Audit Law)

Compliance Impact

Urgency: Medium. This matters as a signal of CSSF's proactive controls on auditor CPE, with fines starting at EUR 1,500 for initial breaches but scaling with severity/duration; repeated actions (e.g., multiple 2025 sanctions) indicate rising enforcement tempo, risking broader audit ecosystem scrutiny. Affected parties face direct fines and reputational harm, while others must prioritize CPE to avoid chain-reaction liabilities in financial reporting.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

Topics:

All Firms

🇱🇺 CSSF Enforcement medium

March 6th 2026

Administrative sanction of 2 December 2025

Administrative sanction imposed on a réviseur d’entreprises agréé

AI Analysis

What Changed

No new regulatory changes are introduced; this is an enforcement action applying existing rules under point f) of Article 43(1) read with point a) of Article 43(2) and Article 44 of the Law of 23 July 2016 concerning the audit profession (Audit Law), alongside CSSF Regulation N°16-10 on continuing education for statutory auditors. Breaches typically involve failing to meet the minimum total hours of continuing education by the reference period end (e.g., December 31, 2024, as in a comparable August 2025 case).

Suggested Considerations

Statutory auditors must immediately verify compliance with Article 3(1) of CSSF Regulation N°16-10, ensuring minimum continuing education hours are met for relevant periods.
Audit firms should conduct internal audits of training logs and implement remediation plans, including supplementary training if deficits exist.
All affected parties must report any identified breaches to CSSF proactively and retain evidence of corrective actions, as CSSF controls under Article 10 of the Audit Law can trigger fines.

Key Dates

31 December 2024 DEADLINE

- Reference period end for continuing education compliance (inferred from similar case)

2 December 2025

- Date of administrative sanction imposition by CSSF

6 March 2026

- Publication date of the sanction notice

Compliance Impact

Urgency: Medium. This matters due to the pattern of CSSF enforcement on audit continuing education (e.g., EUR 1,500 fine in August 2025 case for similar breaches), signaling ongoing supervisory controls that could expand to on-site inspections. Non-compliance risks fines, public naming (or anonymous publication per Article 48(2) Audit Law), and reputational damage, but lacks immediate firm-wide deadlines, reducing to medium urgency for proactive reviews.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance

Topics:

All Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

March 6th 2026

Additional charges brought against financial services company director

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Wealth ManagerBankFintech

Investment Management Wealth & Private Banking Capital Markets & Trading

🇦🇺 ASIC News high

March 6th 2026

Administrative sanction imposed on an investment firm

AI Analysis

The CSSF imposed an administrative sanction on 8 October 2025 against an unnamed investment firm, as detailed in a publication released on 4 March 2026. This enforcement action underscores CSSF's rigorous oversight of investment firms, particularly in areas like AML/CFT compliance, conduct rules, and organizational requirements, serving as a warning for similar entities to strengthen cooperation and internal controls. It matters because it highlights escalating fines for repeated or material breaches, potentially influencing supervisory expectations across Luxembourg's financial sector.

What Changed

No new regulatory changes or requirements are introduced; this is an enforcement action applying existing rules.
Failure to cooperate with CSSF requests, e.g., not submitting required AML/CFT questionnaires by deadlines, violating Article 5(1) of the amended Law of 12 November 2004 on AML/CFT.
Non-compliance with investment policies, organizational requirements, or conduct rules under the UCI Law (e.g., Articles 41, 43, 109), including improper broker exposures or valuation failures.
These reflect ongoing enforcement of established frameworks like the AIFM Law, UCI Law, and AML/CFT Law, with fines calibrated by factors like breach duration, firm size, cooperation level, and prior...

Suggested Considerations

Enhance cooperation protocols: Implement automated tracking for CSSF requests (e.g., questionnaires) with escalations for reminders; document all responses.
Review investment compliance: Audit broker exposures, valuation processes, and subscription/redemption controls against UCI Law Articles 41-43, 109; suspend dealings if uncertainties arise.
Strengthen governance: Conduct gap analyses on internal controls, risk assessments, and reporting for depositary/oversight functions per AIFM Law Article 19(9) and CDR 231/2013.
Training and monitoring: Roll out firm-wide training on AML/CFT obligations (Article 5(1)) and perform reconciliations of assets/records; prepare for on-site/off-site CSSF inspections.
Self-reporting: Proactively disclose prior breaches to mitigate fine severity.

Key Dates

10 January 2025

- Date of prior depositary oversight fine

4 April 2025 DEADLINE

- Deadline for submitting CSSF AML/CFT Questionnaire (breach example from similar case)

16 July 2025

- Date of fine imposition for UCITS investment policy breaches

11 September 2025

- Date of fine imposition in comparable AIFM non-cooperation case

8 October 2025

- Date of the sanction in question

Compliance Impact

Urgency: High - This matters due to CSSF's pattern of publicizing nominative sanctions (e.g., Max Gain Capital, Zeus Asset Management), signaling increased scrutiny on investment firms amid AML/CFT and conduct risks. Fines (EUR 10,000–127,500) represent material hits (up to 10% of turnover), with factors like poor cooperation amplifying penalties; firms with similar exposures face elevated inspection risk, especially post-2025 enforcement wave.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Asset ManagerBroker DealerWealth Manager

Consumer Credit Mortgage & Lending Banking & Credit

🇬🇧 FCA policy_statement critical

March 4th 2026

Motor finance compensation scheme to include implementation period

We'd also streamline the scheme, so millions get compensation in 2026. We're considering over 1,000 responses to our proposals for a compensation scheme for motor finance customers who were treated unfairly.If we proceed with a scheme, we are likely to make several changes. If we do go ahead, we expect to publish final rules in late March. The timing of publication will be outside market hours and we'll confirm the date in advance. Final decisions on the scheme have not yet been made. But to ...

AI Analysis

The FCA is implementing a **streamlined motor finance compensation scheme** to address unfair commission disclosure practices, with final rules expected in late March 2026 and scheme launch in early 2026. This represents a major regulatory intervention affecting approximately 14 million motor finance agreements with estimated total redress costs of £8.2 billion, requiring immediate operational preparation by all lenders and finance providers.

What Changed

The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal: Process Streamlining
Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted. Implementation Timeline
Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.

Suggested Considerations

*Immediate Priorities (Q1 2026):
*Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
*Redress Calculator Development: Build auditable, validated redress calculators capable of:
Repricing loans based on proposed APR reductions
Calculating compensatory interest at BoE base rate + 1%

Key Dates

Early 2026

– Scheme implementation begins (exact date dependent on final rules publication)

Late March 2026

– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)

31 May 2026 DEADLINE

– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme

11 April 2031 DEADLINE

– Record retention deadline for all relevant scheme documentation

Three months from scheme launch

– Standard implementation period for lenders to contact prior complainants and provide compensation notifications

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

BankFintechAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

March 4th 2026

ASIC disqualifies NSW director for the maximum period of five years

Sectors:

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

BankWealth ManagerAll Firms

Banking & Credit Investment Management Capital Markets & Trading

🇯🇵 JFSA Consultation high

March 3rd 2026

Publication,Publication of AI Discussion Paper (Version 1.1)

No description available.

AI Analysis

The Financial Services Agency (FSA) has released the **AI Discussion Paper (Version 1.1)**, an updated consultation document addressing the sound utilization of artificial intelligence in Japan's financial sector. This revised version incorporates stakeholder feedback from the FSA AI Public-Private Forum (June-December 2025) and establishes the regulatory foundation for how financial institutions should approach AI governance, risk management, and compliance as AI adoption accelerates.

What Changed

The Version 1.1 update reflects a stakeholder-informed evolution rather than a complete regulatory overhaul:
Incorporation of industry feedback: The revision integrates insights from the FSA AI Public-Private Forum discussions on AI utilization status, risk management practices, and regulatory application...
Expanded scope: The paper now addresses "a broad range of related issues" beyond the initial Version 1.0 framework, reflecting emerging challenges identified through industry dialogue
Preliminary guidance framework: The document provides initial guidance on current state assessment and challenge identification, explicitly acknowledging that technological advancements may alter...
Regulatory clarity initiative: The paper addresses "situations that require clarification on how regulations apply" to AI implementations, signaling the FSA's intent to reduce regulatory ambiguity...

Suggested Considerations

*Immediate (for compliance and risk teams):
*Obtain and review the full AI Discussion Paper (Version 1.1) (available as Attachment 1 from the FSA website)
*Assess current AI implementations against the preliminary discussion points outlined in the paper
*Identify regulatory gaps in existing AI governance frameworks relative to FSA expectations
*Short-term (30-90 days):

Key Dates

March 2025

- Original AI Discussion Paper (Version 1.0) published

March 3, 2026

- FSA publishes AI Discussion Paper (Version 1.1) in Japanese

Ongoing

- Comment submission period (no specified end date provided; comments accepted via email to ai.survey@fsa.go.jp)

June

December 2025; - Previous stakeholder engagement period (completed; informed Version 1.1)

Compliance Impact

Urgency Rating: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original JFSA source before acting. Full disclaimer.

Sectors:

Topics:

Technology & Cyber Operational Resilience / Outsourcing Senior Managers / Governance

BankAsset ManagerBroker Dealer

🇬🇧 FCA policy_statement high

March 3rd 2026

UK Listing Rules for investment entities review

We are bringing forward a review of some aspects of the UK Listing Rules to consider how they apply to specific types of investment entities. As part of the Primary Markets EffectivenessReviewwe explored which types of investment entities could be eligible to be listed. Since introducing the new listingruleswe have heard from stakeholders that these eligibility criteria, particularlyregardingrisk-spreading, may be unduly restrictive. We will use this review to assess if changes should be made...

AI Analysis

The FCA is conducting a targeted review of UK Listing Rules applicable to investment entities, with particular focus on whether current risk-spreading eligibility criteria are unduly restrictive and how rules support shareholder rights and conflict management. This review represents a potential material shift in listing accessibility for alternative investment funds and closed-ended investment vehicles, with final proposals expected by end-2026.

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

Topics:

Asset ManagerHedge Fund

🇱🇺 CSSF Guidance high

March 2nd 2026

Publication of guidance on documents and information to be submitted for the assessment of the shareholding structure of authorised IFMs – initial authorisation and modification of an authorised IFM (qualified and non-qualified shareholders)

No description available.

AI Analysis

The CSSF published guidance on 2 March 2026 specifying minimum documents and information required for assessing shareholding structures of authorised Investment Fund Managers (IFMs) during initial authorisation and subsequent modifications, covering both qualified and non-qualified shareholders. This matters because incomplete submissions will not be processed, potentially delaying authorisations or amendments amid ongoing CSSF scrutiny of governance and ownership in Luxembourg's fund sector.

What Changed

- Minimum Document Requirements: Establishes a mandatory list of documents for each new shareholder candidate, differentiated by type (e.g., natural person, legal person, beneficial owner,...
Additional Mandatory Submissions: For changes involving qualified holdings (entry, increase/decrease, removal), requires updated group structure charts, MEF (in some cases), financing information,...
Enforcement Mechanism: From 2 March 2026, applications lacking these minimums are deemed incomplete, halting analysis until fully submitted.
No prior formalised list existed in this detail for IFMs, shifting from case-by-case to standardised requirements.

Suggested Considerations

Review Guidance: Download and study the XLSX document (Version 1.0) detailing per-shareholder/per-change requirements.
Prepare Complete Packages: For initial authorisation or amendments, compile minimum docs (e.g., IDs for beneficial owners/PEPs, group charts, financing details, MEF, fees); use *MEF templates where noted.
Submit Fully: Ensure all minimums included in future filings to avoid delays; anticipate CSSF requests for extras.
Internal Processes: Update compliance checklists, train teams on shareholder due diligence, and integrate into authorisation workflows.

Key Dates

2 March 2026

Publication and effective date; Guidance applies immediately; incomplete applications received on/after this date will not start processing until complete

Compliance Impact

Urgency: High – Effective immediately on publication (2 March 2026), with strict non-processing of incomplete files risking significant delays in time-sensitive authorisations/amendments. Matters for maintaining operational timelines in competitive fund markets, where CSSF oversight of IFM ownership ties to broader governance expectations (e.g., board composition, qualifications).

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

Topics:

Asset Manager

🇱🇺 CSSF Guidance high

March 2nd 2026

Guidance on the documents and information to be submitted for the assessment of the shareholding structure of authorised IFMs – initial authorisation and modification of an authorised IFM (qualified and non-qualified shareholders)

Version 1.0

AI Analysis

This CSSF guidance (Version 1.0, published 2 March 2026) specifies the minimum documents and information required for assessing shareholding structures of authorised Investment Fund Managers (IFMs) during initial authorisation or modifications involving qualified and non-qualified shareholders. It standardises submissions to ensure completeness, with incomplete applications rejected until fully provided, enhancing regulatory efficiency and scrutiny of ownership changes. Compliance professionals must prioritise this to avoid delays in authorisation processes for Luxembourg-domiciled IFMs.

What Changed

- Minimum Document Lists: Introduces detailed checklists in an XLSX format covering candidate shareholder documents (e.g., ID, CV, declarations of honour (DH), criminal records (CR) for natural...
Differentiation by Shareholder Type: Requirements vary by natural/legal person, beneficial owner, direct/indirect qualified/unqualified shareholders, and involvement in financing (e.g., "Yes, if PEP...
Other Mandatory Submissions: For qualified holding changes (entry, increase/decrease, removal), requires updated group structure charts, Market Entry Forms (MEF), financing details, and fee forms;...
Enforcement Mechanism: From 2 March 2026, incomplete submissions halt analysis until remedied; CSSF may request additional info.

Suggested Considerations

Prepare Complete Packages: For each new shareholder candidate, compile type-specific docs (e.g., ID/CV/DH/CR for direct unqualified shareholders; financing proof if indirect qualified lacks resources).
Submit Core Items: Always include updated group structure chart, MEF (template available), acquisition financing details, fee form; classify request type (e.g., prior authorisation for qualified changes).
Initial/Modification Filings: Use XLSX guidance as checklist; ensure beneficial owner verification per Circular CSSF 19/732.
Ongoing: Notify CSSF of changes; anticipate ad-hoc requests for extras like PEP declarations.

Key Dates

Asset ManagerWealth Manager

🇺🇸 SEC policy_statement critical

February 27th 2026

SEC Adopts Final Rules for the Holding Foreign Insiders Accountable Act

The Securities and Exchange Commission today adopted final rule and form amendments to reflect the requirements of the recently enacted Holding Foreign Insiders Accountable Act (HFIA), which will increase transparency into the holdings and transactions…

AI Analysis

The SEC adopted final rules on February 27, 2026, implementing the Holding Foreign Insiders Accountable Act (HFIA), which extends Section 16(a) beneficial ownership reporting requirements to directors and officers of foreign private issuers (FPIs) with Exchange Act Section 12-registered equity securities, effective March 18, 2026. This aligns FPI insiders' disclosure obligations with those of U.S. domestic issuers, enhancing market transparency while exempting >10% holders from reporting. Compliance professionals must prioritize preparation as the deadline approaches in two weeks from today (March 3, 2026).

What Changed

- Extension of Section 16(a) Reporting: Directors and officers of FPIs must now file Forms 3 (initial beneficial ownership), 4 (changes in ownership), and 5 (annual summary) electronically and in...
Rule Amendments: - Rule 3a12-3(b): Removes full Section 16 exemption for FPI insiders; retains exemptions only for Section 16(b) short-swing profits and Section 16(c) short-selling prohibitions....
Form Updates: Forms 3, 4, and 5 amended to include non-U.S. issuers and reporters; technical changes to instructions for EDGAR support contacts and paper filing addresses.
Exemptive Authority: SEC may exempt persons/securities/transactions if foreign laws impose "substantially similar" requirements, but no exemptions granted yet; staff evaluating.

Suggested Considerations

For FPIs and Insiders: Identify all directors/officers subject to Section 16; implement processes for electronic/English-language filings via EDGAR; file initial Form 3 by March 18, 2026 (or sooner for new appointees); establish transaction monitoring for prompt Form 4 filings.
Training and Policies: Update insider trading policies, provide training on forms/reporting timelines; designate EDGAR filers with proper contacts.
Systems Preparation: Integrate with trading/brokerage systems for real-time ownership tracking; prepare for Form 5 annual reconciliations.
Monitor Exemptions: Watch for SEC exemptive relief based on foreign law equivalency; assume compliance required absent announcement.

Key Dates

December 18, 2025

HFIA enacted into law

February 27, 2026

SEC adopts final rules (ahead of 90-day mandate)

March 18, 2026 DEADLINE

Effective date; directors/officers of existing FPIs must file initial Form 3; new directors/officers file within 10 days of appointment; ongoing Forms 4 within 2 business days of transactions

Ongoing

Annual Form 5 for unreported transactions; adopting release published in Federal Register (date TBD)

Compliance Impact

Urgency: Critical – With the March 18, 2026, effective date just two weeks away (as of March 3, 2026), non-compliance risks SEC enforcement, including public disclosure failures and potential civil penalties under Section 16. This materially heightens governance burdens for FPIs, demands immediate system/process overhauls, and aligns foreign insiders with U.S. standards to prevent opacity in cross-border listings.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Reporting & Disclosure Senior Managers / Governance

Topics:

All Firms

Banking & Credit Investment Management Wealth & Private Banking

🇭🇰 SFC News high

February 26th 2026

SFC bans Andy Lau Ka Ho for life

No description available.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Broker DealerWealth ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇯🇵 JFSA News medium

February 25th 2026

Councils,The Expert Panel on the Revision of the Corporate Governance Code (2nd meeting) Material

No description available.

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankAsset ManagerBroker Dealer

Banking & Credit Investment Management Capital Markets & Trading

🇪🇺 ESMA Consultation high

February 25th 2026

The EBA and ESMA consult on revised suitability assessment requirements for banks and investment firms

The EBA and ESMA consult on revised suitability assessment requirements for banks and investment firms 25 February 2026 Investor protection The European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) today launched a consultation on the revised joint guidelines on the assessment of the suitability of members of the management body and key function holders . The revised guidelines form part of a broader package designed to harmonise suitability assessments and...

AI Analysis

The EBA and ESMA have launched a consultation on revised joint guidelines updating suitability assessments for management body members and key function holders in banks and investment firms, incorporating new requirements from the revised CRD and MiFID II to enhance harmonization and supervisory convergence. This matters for compliance professionals as it introduces mandatory assessments for additional roles, strengthens AML/CFT links, and includes simplifications to reduce burdens, potentially impacting governance processes once finalized and replacing the 2021 guidelines.

What Changed

- Incorporation of revised CRD requirements for large institutions, including ex-ante applications where authorities perform ex-post assessments, and mandatory suitability assessments for key roles...
Expanded application to CRD-covered entities and MiFID II investment firms, with further specifications for third-country branches.
Strengthened integration with AML/CFT framework, providing guidance on identifying reasonable grounds to suspect money laundering or terrorist financing risks during assessments.
Introduction of targeted simplifications to streamline processes, reduce administrative burdens, and offer greater flexibility/clarity for institutions and supervisors.
Parallel EBA consultation on RTS specifying standardized documentation (e.g., suitability questionnaires, CVs, internal assessments) for large institutions to ensure consistent submissions.

Suggested Considerations

Assess current suitability processes against new requirements (e.g., ex-ante applications, AML/CFT checks, third-country branch specs) and prepare for mandatory assessments of additional roles like CFOs.
For large institutions, evaluate EBA RTS on documentation and align internal templates (e.g., suitability questionnaires, CVs).
Participate in public hearings on 15 April 2026 if relevant.
Plan governance updates, including ongoing monitoring of collective/individual suitability and corrective measures.

Key Dates

15 April 2026, 14:00

15:30; - Public hearing on joint guidelines

15 April 2026, 15:30

16:30; - Public hearing on EBA RTS

25 May 2026 DEADLINE

- Deadline for submitting comments on joint guidelines and EBA RTS

Post

25 May 2026; - EBA publishes all contributions (unless requested otherwise)

TBD (post

consultation); - Revised guidelines enter into force, repealing 2021 guidelines

Compliance Impact

Urgency: High - As a consultation launched today (25 February 2026), firms have ~3 months to engage, but final guidelines will repeal existing ones, mandating process updates for core governance/AML functions in banks and investment firms; delays risk non-compliance with harmonized EU standards, especially for large institutions facing RTS on documentation. Matters due to expanded scope (e.g., CFOs, third-country branches) and AML ties, amplifying fit-and-proper regime enforcement amid supervisory convergence push.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance AML / Financial Crime Prudential / Capital Requirements

BankBroker DealerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

February 25th 2026

Misconduct reports to ASIC highlight spike in corporate governance issues

Sectors:

Topics:

Consumer Protection / Conduct Operational Resilience / Outsourcing Senior Managers / Governance

BankWealth ManagerAll Firms

Capital Markets & Trading Investment Management Banking & Credit

🇺🇸 SEC Enforcement high

February 24th 2026

SEC’s Division of Enforcement Announces Updates to Enforcement Manual

The Securities and Exchange Commission’s Division of Enforcement today announced significant updates to its Enforcement Manual. These updates underscore the Commission’s ongoing commitment to fairness, transparency, and efficiency in the investigations…

AI Analysis

The SEC's Division of Enforcement announced updates to its Enforcement Manual on February 24, 2026, focusing on enhancing fairness, transparency, and efficiency in investigations through standardized procedures like the Wells process and settlement considerations. These changes, the first major revisions since 2017, introduce uniform timelines and best practices to streamline resolutions and improve dialogue with investigated parties. Compliance professionals should prioritize this as it directly affects how firms respond to SEC inquiries, potentially accelerating outcomes and reducing uncertainties in enforcement actions.

What Changed

The updates target investigative and enforcement procedures for greater consistency:
Uniform Wells process: Recipients of a Wells notice receive four weeks to submit responses; Wells meetings are scheduled within four weeks of submission and include senior Division leadership.
Simultaneous settlement and waiver consideration: Restores practice allowing settling parties to request Commission waivers from collateral consequences (e.g., disqualifications) alongside settlement...
Additional enhancements: Details framework for evaluating cooperation (including civil penalty impacts); promotes internal collaboration; updates formal order processes, criminal referrals, and...

Suggested Considerations

Review the updated Enforcement Manual (https://www.sec.gov/files/enforcementmanual.pdf) and train compliance/in-house legal teams on new Wells timelines and submission guidance.
Update internal policies for responding to Wells notices: Prepare submissions within four weeks, focusing on elements staff find "most helpful" (e.g., detailed facts, legal analysis).
For settlements, incorporate simultaneous waiver requests in offers to leverage restored process and mitigate collateral impacts.
Enhance cooperation strategies per new evaluation framework to potentially reduce civil penalties; document internal collaboration for enforcement interactions.
Monitor annual Manual reviews via SEC Division of Enforcement page (https://www.sec.gov/about/divisions-offices/division-enforcement).

Key Dates

February 24, 2026

- Updates to Enforcement Manual announced and effective; last major revision was 2017, with annual reviews planned going forward

Four weeks from Wells notice receipt DEADLINE

- Standard deadline for Wells submissions

Four weeks from Wells submission receipt

- Scheduling of Wells meetings with senior leadership

Compliance Impact

Urgency: High - These procedural updates are immediately effective and alter critical interaction points with SEC staff, such as Wells responses and settlements, which can determine investigation closure, enforcement recommendations, or penalty severity. Firms under active scrutiny or anticipating inquiries gain from predictable timelines reducing prolonged uncertainty, but must adapt quickly to avoid suboptimal outcomes; non-compliance risks inefficient resolutions or missed cooperation credits.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Topics:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

Asset ManagerBroker DealerHedge Fund

Banking & Credit Payments & E-Money Consumer Credit

🇬🇧 FCA policy_statement medium

February 24th 2026

Independent Football Regulator and FCA Memorandum of Understanding

We have signed a Memorandum of Understanding (MoU) with the Independent Football Regulator (IFR). The MoU establishes how the 2 organisations will work together and support effective regulation where football and financial services intersect.It also sets out a high-level framework for principles for cooperation between the IFR and the FCA.Read the MoU (PDF)

AI Analysis

The FCA has signed a Memorandum of Understanding (MoU) with the newly established Independent Football Regulator (IFR) to define cooperation on regulating intersections between football clubs and financial services, such as ownership suitability, licensing, and financial sustainability. This matters for compliance professionals as it formalizes information sharing and joint oversight, potentially impacting firms involved in football-related financing, investments, or consumer credit products tied to sports. It supports the Football Governance Act 2025 framework, enhancing regulatory alignment where financial misconduct could affect club operations.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]

What Changed

- Establishes a high-level framework of principles for cooperation between FCA and IFR, focusing on effective regulation at the football-financial services nexus.
Outlines how the organizations will work together, including information sharing on matters like club owners' financial dealings, licensing compliance, and enforcement where financial services...
Builds on prior MoUs (e.g., FCA-UKGC models) by addressing regulatory overlaps, with IFR gaining powers for investigations, enforcement sanctions, and revenue distribution resolutions under the...

Suggested Considerations

Review and map exposures: Firms should assess football-related client portfolios for IFR overlap (e.g., loans to clubs, owner financing) and prepare for dual FCA-IFR scrutiny.
Enhance information sharing protocols: Update compliance policies to respond promptly to IFR requests for data on regulated activities (e.g., under IFR's clause 65 powers), mirroring FCA's existing MoU frameworks.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
Incorporate IFR factors in due diligence: For owner suitability, align with IFR tests (fit/proper custodians, resource adequacy); flag potential divestment risks in advisory services.
Monitor joint enforcement: Participate in escalation procedures if disputes arise, ensuring internal records of regulatory remit discussions.

Key Dates

2025

Football Governance Act 2025 enactment; Establishes IFR statutory powers, including provisional/full club licensing from this date onward

Ongoing

IFR licensing rollout; Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date

Compliance Impact

Urgency: Medium – This MoU does not impose new binding rules or deadlines but signals heightened cross-regulator focus on football finances post-Football Governance Act 2025, risking enforcement overlaps or info requests. It matters for firms with niche exposures (e.g., sports financing) to avoid gaps in owner due diligence or financial promotions, potentially amplifying AML/conduct risks amid IFR's divestment powers.

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

BankFintechPayment Provider

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

🇺🇸 CFTC News medium

February 23rd 2026

CFTC Chairman Selig Announces Senior Staff Appointments

No description available.

Sectors:

Topics:

Technology & Cyber Authorisation & Licensing Senior Managers / Governance

BankFintechCrypto Exchange

🇪🇺 ESMA Enforcement high

February 20th 2026

ESMA sanctions Regis-TR for serious breaches of organisational obligations

ESMA sanctions Regis-TR for serious breaches of organisational obligations 19 February 2026 Press Releases Securities Financing Transactions Supervision Trade Repositories The European Securities and Markets Authority (ESMA), the European Union’s (EU) financial markets regulator and supervisor, has fined the trade repository (TR) REGIS-TR, S.A. a total of EUR 1,374,000 for seven infringements under the European Market Infrastructure Regulation (EMIR) and the Securities Financing Transactions ...

AI Analysis

ESMA has fined REGIS-TR, S.A. €1,374,000 for seven negligent breaches of organisational obligations under EMIR and SFTR, marking the first SFTR enforcement action and ESMA's highest fine against a trade repository. The breaches involved deficiencies in policies, procedures, organisational structure, operational risk management, and data confidentiality, compromising SFTR reporting and market data integrity. This underscores ESMA's intensified enforcement on trade repositories (TRs) to ensure high-quality data for market surveillance and financial stability.

What Changed

This is an enforcement decision, not new legislation, but it reinforces existing EMIR and SFTR requirements on TRs, particularly:
Policies and procedures: Must be adequate to ensure compliance, with clear roles and responsibilities for governing bodies (breaches under EMIR Art. 78(3) and SFTR Art.
Organisational structure: Must ensure business continuity and orderly functioning, especially for SFTR services (breach under SFTR).
Operational risk management: Identify and minimise risks via systems, controls, and procedures (breaches under EMIR and SFTR, Point (a) Section II Annex I EMIR).
Data confidentiality and integrity: Protect information received under EMIR and prevent misuse (breaches under EMIR). Fines were calculated per EMIR Art.

Suggested Considerations

For REGIS-TR specifically: Cease three ongoing breaches (policies/procedures under EMIR/SFTR; SFTR organisational structure for business continuity) per ESMA supervisory measures (EMIR Art. 73).
For all TRs: - Review and strengthen policies/procedures for clarity on governance roles/responsibilities.
Audit organisational structure for SFTR business continuity and orderly functioning.
Conduct operational risk assessments, implementing controls/systems to minimise risks under EMIR/SFTR.
Enhance data confidentiality/integrity protections and misuse prevention measures.

Key Dates

14 November 2013

- REGIS-TR initial registration with ESMA under EMIR

7 May 2020

- REGIS-TR registration extended to SFTR reporting

14 June 2024

- ESMA Supervisory Report identifying serious indications of breaches

17 June 2024

- Public notice references investigations leading to findings (dated in decision docs)

17 February 2026

- ESMA Board of Supervisors meeting discussing the case

Compliance Impact

Urgency: High – As the first SFTR enforcement and record TR fine (€1.374M), it demonstrates ESMA's commitment to punitive action on negligence causing systemic data risks, directly threatening market integrity and surveillance. TRs face immediate remediation pressure (three breaches ongoing), with fines amplified by duration/systemic factors; non-TRs using TRs risk indirect exposure via poor data quality. Firms should prioritise audits now to avoid similar "negligent" findings.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Reporting & Disclosure Operational Resilience / Outsourcing Senior Managers / Governance

Topics:

All Firms

Capital Markets & Trading Wealth & Private Banking

🇯🇵 JFSA News

February 19th 2026

Councils,The second meeting of the Expert Panel on the Revision of the Corporate Governance Code (2025-2026)

No description available.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance

BankWealth Manager

Banking & Credit Capital Markets & Trading Payments & E-Money

🇮🇪 CBI Enforcement medium

February 18th 2026

Institutions, Anchors, and Their Discontents: The Role of Central Banks - Speech by Governor Gabriel Makhlouf to Blavatnik School of Government

It is a pleasure to be here in Oxford 1 While I’m aware that this is a school of government and I’m a central banker, the two are inextricably linked. Societies and indeed economies are shaped by their institutions, specifically the legal, social, cultural, formal and informal norms that impact the way citizens interact with each other. Successful institutions are those that are trusted by the societies that created them and for which they ultimately serve. Today I am going to resist the oppo...

AI Analysis

Governor Gabriel Makhlouf's speech at the Blavatnik School of Government addresses central bank independence as a foundational institutional mechanism for delivering price stability and economic prosperity, rather than as a shield from accountability. The speech is not a regulatory enforcement action or new requirement, but rather a governance statement clarifying the Central Bank of Ireland's institutional philosophy on independence, credibility, and accountability—matters that directly affect how the CBI exercises supervisory discretion over regulated firms.

What Changed

This is not a regulatory change document but a governance clarification with compliance implications:
Reframing of independence: Central bank independence is characterized as an "anchor" enabling long-term decision-making rather than isolation from society.
Credibility framework: Credibility depends on competence, engagement, coherence, and public trust—not institutional distance alone.
Accountability emphasis: Independence requires continuous dialogue with society and other economic governance institutions; it "does not mean isolation."
Historical validation: The speech references the 1960s-1970s macroeconomic instability under political pressure versus post-pandemic effectiveness of credible central banks in controlling inflation.

Suggested Considerations

*Understand CBI decision-making philosophy: Recognize that CBI supervisory decisions are grounded in long-term economic stability objectives, not short-term political cycles.
*Align governance with credibility principles: The speech identifies four credibility pillars—competence, engagement, coherence, and public trust. Regulated firms should ensure their governance frameworks reflect these principles in their own operations.
*Monitor 2026 supervisory priorities: The speech references CBI's published 2026 Regulatory and Supervisory Priorities, which include maintaining resilience to geopolitical risks, securing consumer and investor interests, and delivering new responsibilities under Access to Cash legislation.

Key Dates

Second half 2026

- Ireland assumes EU Council Presidency; CBI will support government during this period

10 February 2026

- CBI published its 2026 Regulatory and Supervisory Priorities, which establish the operational framework within which this governance philosophy applies

18 February 2026

- This speech delivered, reinforcing institutional independence principles

Compliance Impact

Urgency: MEDIUM

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Operational Resilience / Outsourcing Prudential / Capital Requirements

BankAsset ManagerPayment Provider

🇱🇺 CSSF Guidance high

February 18th 2026

Circular CSSF 26/907 (only in French)

Exigences applicables au réviseur d’entreprises agréé spécial auprès des établissements de crédit émetteurs de lettres de gage

AI Analysis

Circular CSSF 26/907, published on February 18, 2026, establishes requirements for **approved special statutory auditors (réviseurs d'entreprises agréés spéciaux) serving credit institutions that issue mortgage bonds (lettres de gage)**. This circular formalizes the governance and audit standards applicable to a specialized auditor role within Luxembourg's credit institution framework, ensuring enhanced oversight of entities engaged in mortgage bond issuance.

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Senior Managers / Governance Reporting & Disclosure

Topics:

Bank

Banking & Credit Payments & E-Money Investment Management

🇪🇺 ESMA Enforcement medium

February 18th 2026

ESMA supports the simplified European Sustainability Reporting Standards and suggests targeted adjustments

ESMA supports the simplified European Sustainability Reporting Standards and suggests targeted adjustments 18 February 2026 Issuer disclosure Press Releases Sustainable finance The European Securities and Markets Authority, the EU’s financial markets regulator and supervisor, has delivered its opinion on the draft revised European Sustainability Reporting Standards (ESRS) developed by EFRAG. ESMA strongly supports the European Commission’s goal of enhancing competitiveness and growth through ...

AI Analysis

ESMA has issued an opinion supporting EFRAG's draft simplified European Sustainability Reporting Standards (ESRS) under the CSRD, praising improvements in readability and materiality focus while recommending targeted adjustments to enhance investor protection and financial stability. This matters for compliance professionals as it signals upcoming refinements to sustainability disclosures, with pragmatic supervision promised during the transition, potentially reducing short-term burdens but requiring monitoring of final delegated act adoption by summer 2026.

What Changed

The draft revised ESRS introduce simplifications such as improved readability, language, format, reduced volume of requirements, and a focus on material matters.
Introduce time limits to certain permanent reliefs (e.g., reliefs #3, #4, #9, #11 on quantitative information for anticipated financial effects until FY 2029, and metrics).
Refine requirements on transition plans (e.g., consistent disclosure of absolute financed emissions and contextual information).
Strengthen reporting on sustainability competences of administrative, management, and supervisory bodies.
Enhance transparency on financial resources allocated to sustainability actions.

Suggested Considerations

Monitor Commission process: Track final delegated act by summer 2026, incorporating ESMA/EBA/EIOPA/ECB opinions; review full ESMA opinion PDF for detailed recommendations.
Assess current reporting: Evaluate use of permanent/temporary reliefs (e.g., #3/#4 on quantitative data, #9/#11 on metrics) and prepare for time limits; refine transition plans for emissions/targets.
Enhance governance disclosures: Strengthen reporting on sustainability competences in management/supervisory bodies and financial resources for actions.
Review subsidiary exemptions: Check materiality exclusions for sustainability risks/opportunities in consolidated statements.
Prepare for supervision: Leverage NCAs flexibility during transition; integrate into data governance and risk systems per CSRD implementation trends.

Key Dates

AI Analysis

The CSSF Circular Letter 2026-02-12 announces a standardized data collection exercise on AML/CFT for supervised entities, scheduled for 2026, aimed at enhancing regulatory oversight of money laundering and terrorist financing risks. This matters because it signals intensified CSSF scrutiny on AML/CFT compliance, requiring firms to prepare structured data submissions that could inform future supervisory actions, risk assessments, and enforcement. As part of broader CSSF AML/CFT initiatives, non-compliance risks fines or heightened inspections.

What Changed

- Introduction of standardized AML/CFT data collection: CSSF mandates uniform reporting formats for collecting data on AML/CFT risks, controls, and practices across supervised sectors, building on...
Alignment with ongoing AML/CFT enhancements: Complements recent governance-focused circulars (e.g., Circular 26/906 on central administration and risk management for payment/e-money institutions) by...
No explicit new obligations beyond preparation for data submission, but implies deeper integration of tax-related AML indicators and sub-sector risk updates, as seen in related CSSF activities.

Suggested Considerations

Assess and document AML/CFT data readiness: Inventory current risk assessments, transaction monitoring logs, KYC processes, SAR filings, and third-party oversight records in standardized formats; map to proportionality factors (e.g., transaction volumes, outsourcing).
Update governance and controls: Ensure compliance functions have independence, direct board reporting, and audit coverage of AML/CFT; test ICT resilience for monitoring continuity.
Conduct internal reviews: Perform gap analyses against Circular 26/906 (e.g., fund safeguarding, escalation protocols) and recent conference topics (e.g., terrorist financing, tax indicators); remediate deficiencies with board-approved plans.
Prepare for submission: Designate resources for data compilation; cooperate fully with CSSF/FIU requests, including transfer-of-funds information under EU 2015/847.
Engage auditors: Leverage approved auditors for validation of AML/CFT effectiveness ahead of collection.

Key Dates

2026 (exact date TBD) DEADLINE

AML/CFT standardised data collection exercise; Firms must submit required data during this period; preparation recommended immediately given today's date (12 February 2026)

20 January 2026 DEADLINE

Issuance of related Circular 26/906; Establishes governance baselines (e.g., compliance independence, risk proportionality) informing data collection expectations

26 January 2026

CSSF AML/CFT Conference for Specialised PFS; Provided updates on sub-sector risks, terrorist financing reviews, and FIU insights relevant to data preparation

28 January 2026 DEADLINE

Conference materials published; Available for download to guide compliance alignment

Compliance Impact

Urgency: High – With data collection in 2026 underway today (12 February 2026), firms face immediate preparation needs amid recent enforcement (e.g., EUR 102,000 fine on depositary for AML-related gaps) and conferences signaling sub-sector focus. This elevates AML/CFT as a supervisory priority, potentially triggering on-site inspections, fines, or remediation orders for inadequate data/risks; proactive alignment prevents escalation in a risk-based regime.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Senior Managers / Governance

BankPayment ProviderAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇪🇺 ECB News medium

February 11th 2026

Report on declared time commitment of non-executive directors in the SSM

No description available.

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance Reporting & Disclosure

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Insurance & Pensions

🇮🇪 CBI Enforcement medium

February 11th 2026

Reinforcing Resilience, Responding to Change: Priorities for the Year Ahead - Speech by Governor Gabriel Makhlouf to Head of EU Missions

I would like to welcome you all to the Central Bank of Ireland today 1 . We are delighted to host this gathering of EU Heads of Missions, representatives of our friends and partners from across the EU. A little over a year ago I had the pleasure to meet with you all. I spoke then of a geopolitical landscape facing significant strain and complexity; of the rise of economic nationalism and trade disputes; as well as the shift from cooperation to competition, and its impact on our ability to mee...

AI Analysis

This speech by Central Bank of Ireland (CBI) Governor Gabriel Makhlouf outlines priorities for building economic and financial resilience amid geopolitical risks, climate change, technological shifts, and geoeconomic fragmentation, emphasizing domestic policy focus areas like infrastructure, indigenous business growth, and fiscal buffers. It matters for compliance professionals as it previews CBI's forthcoming 2026 regulatory and supervisory priorities, signaling heightened scrutiny on operational and financial resilience, consumer protection, and alignment with a transforming regulatory framework. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026

What Changed

This is a forward-looking speech, not announcing immediate regulatory changes, but it references CBI's ongoing transformation agenda, including:
Four overarching supervisory priorities for 2026: (1) Maintaining/building resilience to geopolitical/macro-financial risks (operational and financial resilience); (2) Securing consumer/investor...
Upcoming publication of full 2026 Regulatory and Supervisory Priorities "in the next few weeks." https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026
Broader roadmap initiatives: Integrated risk-based supervision; rulebook updates (e.g., AIF/UCITS, Fund Service Provider framework review post-AIFMD II, insurance compatibility with Solvency II,...

Suggested Considerations

Review and prepare for priorities: Monitor for 2026 priorities release (imminent); assess firm alignment with resilience themes (geopolitical/macro-financial risks, operational resilience, consumer protection).
Enhance resilience planning: Strengthen operational/financial resilience frameworks, including stress testing for geopolitical shocks, infrastructure dependencies, and climate risks; update outsourcing/governance per cross-sectoral guidance.
Engage on consultations: Participate in H1 2026 RIA Framework consultation and upcoming FSP review; review internal reporting/data processes for proportionality.
Sector-specific: Funds/asset managers—prepare for AIF/UCITS updates and FSP review; banks/insurers—align with CRD V/Solvency II compatibility reviews; all firms—ensure business models address narrow economic vulnerabilities.

Key Dates

2025

2026; - Ongoing implementation of banking/payments supervisory activities and multi-year roadmap (supervision, regulation, gatekeeping, reporting). https://www.matheson.com/insights/fig-top-5-at-5-06-03-2025/ https://www.centralbank.ie/news/article/press-release-central-bank-of-ireland-publishes-roadmap-to-deliver-a-more-effective-and-efficient-regulatory-framework-10-december-2025

Next few weeks from 11 February 2026

- Publication of CBI's full 2026 Regulatory and Supervisory Priorities. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026

H1 2026

- Consultation on new Regulatory Impact Assessment (RIA) Framework. https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf

Shortly (2026)

- Launch of comprehensive Fund Service Provider (FSP) Framework review. https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf

Compliance Impact

Urgency: Medium—This speech signals strategic direction rather than enforceable rules, but imminent priorities publication and 2026 consultations demand proactive preparation to avoid intensified supervision/enforcement. It matters because CBI emphasizes resilience in a high-risk environment (geopolitics, AI, climate), with non-compliance risking closer scrutiny under new integrated approach; firms ignoring this could face heightened operational reviews amid efficiency drive without standards reduction. https://www.centralbank.ie/regulation/transforming-regulation-and-supervision

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Operational Resilience / Outsourcing Prudential / Capital Requirements Senior Managers / Governance

BankAsset ManagerInsurance

🇱🇺 CSSF Guidance high

February 10th 2026

UCI Reports foreseen by Circular CSSF 21/790 for year-ends 31 January 2026, 28 February 2026, 31 March 2026 and 30 April 2026 now available on eDesk and information on main updates

No description available.

AI Analysis

This CSSF communiqué announces the availability of updated UCI Reports (SAQ, SR, and ML) under Circular CSSF 21/790 on the eDesk platform's CISERO module for specific 2026 year-ends, with key enhancements focused on valuation, NAV determination, and risk-based streamlining. It matters for Luxembourg UCIs as it reflects evolving supervisory priorities, aligns with EU directives like Directive (EU) 2024/927, and imposes refined self-assessment obligations to bolster resilience in stressed conditions and liquidity management.

What Changed

- SAQ Updates (Valuation Section): New questions on valuation policies for stressed market conditions/exceptional circumstances; coverage for new sub-funds/strategies; independent validation of...
SAQ Simplifications and Clarifications: Removed questions on sub-funds with significant non-standard OTC derivatives, unquoted assets, or external valuer OTC FDIs (including NAV proportions); refined...
SAQ NAV Determination: Updated Liquidity Management Tools (LMTs) sub-section to align with Annexes of AIFM/UCITS Review Directive (Directive (EU) 2024/927); added question on compliance with ESMA...
SR Streamlining: Removed procedures in investment compliance (e.g., eligibility assessments for closed-ended funds, structured instruments, non-plain vanilla OTC derivatives; credit quality for money...
Reports for year-ends after 30 April 2026 available three months prior.

Suggested Considerations

Access updated Reports on eDesk CISERO module immediately and review changes vs. 31 December 2025 versions.
Update valuation policies/procedures to explicitly cover stressed conditions, new sub-funds/strategies, model validations, and backtesting; document compliance.
Revise NAV processes for LMT alignment with Directive (EU) 2024/927 Annexes and ESMA performance fee guidelines; confirm for open-ended UCIs.
Dirigeants/management: Complete/validate SAQ addressing new/clarified questions; prepare for REA SR/ML review.
REAs: Perform streamlined SR procedures; issue ML on prior weaknesses with remediation timelines.

Key Dates

9 February 2026

Reports (SAQ, SR, ML) made available on eDesk CISERO for year-ends 31 January, 28 February, 31 March, 30 April 2026

16 April 2026

Entry into application of AIFM/UCITS Review Directive LMT requirements

Financial year DEADLINE

end +5 months (UCITS/Part II UCIs); SAQ/SR submission deadline

Financial year DEADLINE

end +6 months (SIFs/SICARs); SAQ/SR submission deadline

Three months before year

end (post-30 April 2026); Future Reports availability

Compliance Impact

Urgency: High – Immediate access required for imminent submissions (e.g., 31 January 2026 year-end due ~June 2026); new valuation questions demand policy reviews to avoid supervisory findings, especially amid stressed markets; SR simplifications reduce burden but shift focus to SAQ self-assessment, heightening dirigeants' accountability. Non-compliance risks CSSF follow-up on modified audits or weaknesses, per Circular 21/790.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Reporting & Disclosure Senior Managers / Governance

Topics:

Asset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇭🇰 SFC News high

February 10th 2026

SFC obtains compensation and disqualification orders against former directors of Arta TechFin Corporation Limited

No description available.

Sectors:

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

BankBroker DealerAsset Manager

Senior Managers / Governance

🇭🇰 SFC Enforcement high

February 9th 2026

SFC reprimands and fines Kylin International (HK) Co., Limited $9 million for fund management failures

No description available.

AI Analysis

The SFC reprimanded and fined Kylin International (HK) Co., Limited $9 million for systemic failures in managing private sub-funds from August 2018 to July 2021, including unmanaged conflicts of interest, inadequate reconciliations/valuations, weak KYC/suitability controls, AML/CTF record-keeping lapses, and misrepresentations to investors. This enforcement action underscores the SFC's heightened scrutiny of private fund managers, emphasizing senior management accountability and robust systems/controls to protect market integrity. Compliance professionals should note it as a deterrent signal, aligning with recent SFC circulars on escalating penalties for persistent misconduct.

What Changed

This is an enforcement action, not a new rule change, but it reinforces and exemplifies existing obligations under the Securities and Futures Ordinance (SFO), Fund Manager Code of Conduct (FMCC), and...
Mandatory conflict management and disclosure: Firms must identify, manage, and disclose conflicts, e.g., loans from the manager or directors to funds.
Asset reconciliation and valuation: Monthly reconciliations, regular valuations, and independent audits of fund financials are required.
KYC/suitability assessments: Adequate systems/controls for client due diligence and suitability, even for professional investors (no blanket exemptions).
AML/CTF compliance: Records must demonstrate ongoing adherence; misrepresentations to investors on exemptions are prohibited.

Suggested Considerations

Conduct gap analysis: Review private fund operations against five failure areas (conflicts, reconciliations/valuations/audits, KYC/suitability, AML/CTF records, investor representations) using FMCC and 9 Oct 2024 circular.
Enhance systems/controls: Implement monthly asset reconciliations, independent audits, automated KYC/suitability tools, and conflict registers; ensure AML/CTF records are audit-ready.
Senior management oversight: ROs/MICs to document personal accountability; train on self-reporting breaches (Code of Conduct para 12.5).
Investor communications: Cease any claims of suitability exemptions for professional investors; update disclosures.
Remediation evidence: Like Kylin, document post-review fixes to mitigate sanctions.

Key Dates

August 2018

Topics:

Insurance

🇿🇦 FSCA Enforcement medium

February 7th 2026

Enforcement Matters

OVERVIEW

AI Analysis

This FSCA "Enforcement Matters" publication details the regulator's ongoing supervisory enforcement activities, primarily through curatorships imposed on non-compliant financial institutions under South African financial sector laws. It matters for compliance professionals as it exemplifies the FSCA's readiness to escalate to court-ordered curatorships and administrative penalties for serious breaches, signaling a robust enforcement posture to deter misconduct and protect market integrity.

What Changed

No new regulatory changes or requirements are introduced; this is a static resource page listing historical and ongoing enforcement outcomes, focused on curatorship reports and court orders. It underscores the FSCA's established powers to apply remedial actions like curatorships (court-appointed oversight of failing institutions) and administrative penalties, with appeals available to the Tribunal. Key themes include prolonged curatorships for cases involving FAIS (Financial Advisory and Intermediary Services Act) violations, asset mismanagement, and failure to comply with financial laws.

Suggested Considerations

Monitor ongoing curatorships: Firms should review listed cases (e.g., CMM, Fidentia) for parallels to their operations, ensuring robust compliance with FAIS and financial sector laws to avoid similar interventions.
Strengthen governance and reporting: Implement controls to prevent triggers like asset misappropriation or non-compliance, including regular internal audits and transparency with FSCA.
Prepare for escalation: Maintain records for potential Tribunal appeals; engage legal counsel if supervisory concerns arise, as FSCA prioritizes remedial action before penalties.
Proactive remediation: Address any identified issues promptly, aligning with FSCA's emphasis on supervision-driven enforcement.

Compliance Impact

Urgency: Medium. This matters as a stark reminder of FSCA's curatorship tool for severe, persistent non-compliance, particularly in investment mismanagement, which can lead to loss of control and reputational damage. While not announcing new rules, it highlights long-running cases (e.g., 15+ years for some), urging firms to prioritize governance and FAIS adherence amid FSCA's 2025-2028 strategy for increased enforcement transparency and actions.

References

AI-generated analysis. May contain errors or omissions — verify with the original FSCA source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset ManagerWealth ManagerAll Firms

🇱🇺 CSSF Enforcement high

February 6th 2026

Administrative sanction of 6 February 2026

Administrative sanction imposed on Corestate Capital Holding S.A.

AI Analysis

The CSSF published an administrative sanction on 6 February 2026 against Corestate Capital Holding S.A., likely for breaches in regulatory compliance such as depositary duties, oversight, or governance under Luxembourg financial laws, marking a repeat enforcement action following a prior sanction in June 2025. This matters for compliance professionals as it underscores CSSF's aggressive enforcement on alternative investment fund managers (AIFMs) and depositaries, signaling heightened scrutiny on safekeeping, oversight, and internal controls to prevent systemic risks in Luxembourg's fund sector. It highlights the regulator's willingness to impose public nominative sanctions, amplifying reputational damage alongside fines.

What Changed

No new regulatory changes or requirements are introduced; this is an enforcement action enforcing existing obligations under laws like the AIFM Law of 12 July 2013 (e.g., Articles 19(8), 19(9), 19(11) on safekeeping and oversight duties), the Law of 5 April 1993 on the financial sector, and Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013, e.g., Articles 92, 94, 96 on risk assessment, valuation verification, and cash flow monitoring).

Suggested Considerations

Conduct immediate gap analysis: Review safekeeping processes for ownership verification (Article 19(8)(b) AIFM Law), ensuring transaction documentation, segregated account proofs, and full holding chain records are available at transaction points.
Enhance oversight duties: Implement risk assessments per Article 92(1) CDR 231/2013, valuation compliance checks (Article 94), and cash remittance monitoring (Article 96); appoint delegates with due diligence.
Strengthen governance: Update internal controls, procedures, and conflict-of-interest policies (e.g., director overlaps); ensure key documentation availability and evidence of controls.
Firm-wide audit: For repeat offenders like Corestate, perform root-cause analysis on prior sanctions and submit remediation plans to CSSF if inspected.
Training and reporting: Train staff on CSSF expectations; improve cooperation mechanisms to avoid AML/CFT fines for non-submission of requests.

Key Dates

20 June 2025 DEADLINE

- Prior administrative sanction imposed on Corestate Capital Holding S.A., indicating ongoing non-compliance issues

6 February 2026

- Publication date of the current administrative sanction on Corestate Capital Holding S.A., effective immediately as a public enforcement notice

Compliance Impact

Urgency: High – This represents CSSF's pattern of public nominative fines (e.g., EUR 102,000 on JTC for depositary breaches, EUR 10,000 on Capitalis for AML non-cooperation), with escalation risks for repeat violations like Corestate's back-to-back sanctions. It matters due to Luxembourg's dominance in European fund assets (over EUR 5 trillion), where governance lapses can trigger outflows, license revocation, or cross-border ESMA scrutiny; firms must act preemptively to mitigate fines (typically EUR 10,000–102,000) and reputational harm from nominative publication.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

Topics:

Asset ManagerAll Firms

🇱🇺 CSSF Enforcement high

February 6th 2026

Administrative sanction of 6 February 2026

Administrative sanction imposed on Corestate Capital Holding S.A.

AI Analysis

The CSSF published an administrative sanction on 6 February 2026 against Corestate Capital Holding S.A., likely imposing a fine for regulatory breaches, marking a repeat enforcement action following a prior sanction on the same entity dated 20 June 2025. This matters as it underscores CSSF's intensified supervisory scrutiny on Luxembourg-based investment managers, particularly regarding governance, asset safekeeping, and oversight duties under AIFM Law, signaling heightened enforcement risks for similar firms. Compliance teams should review it for patterns in depositary and transparency violations evident in recent CSSF cases.

What Changed

No new regulatory changes or requirements are introduced; this is an enforcement action highlighting non-compliance with existing obligations under Luxembourg's AIFM Law (notably Articles 19(8), 19(9), 19(11), and 51) and related delegated regulations like CDR 231/2013. Key breaches from analogous recent CSSF sanctions include inadequate safekeeping of assets (e.g., missing ownership verification and records), failure to oversee AIFM valuation policies and cash remittance timelines, improper delegation to custodians without due diligence, and weak internal governance such as conflicts of...

Suggested Considerations

Conduct immediate gap analysis on depositary functions: Verify ownership chains, transaction documentation, segregated account reconciliations, and custodian delegations per AIFM Law Articles 19(8) and 19(11).
Enhance oversight processes: Implement risk assessments for AIF strategies, valuation policy checks, and cashflow monitoring per CDR 231/2013 Articles 92, 94, and 96.
Strengthen governance: Review internal controls, procedures, and conflicts (e.g., director overlaps with affiliates); ensure availability of control evidence.
For issuers like Corestate: Confirm compliance with half-yearly financial reporting and dissemination under Transparency Law Article 4.
Firm-wide: Perform mock CSSF on-site inspections focusing on 2022-2025 periods, given inspection timelines in recent cases.

Key Dates

20 June 2025

- Prior administrative sanction imposed on Corestate Capital Holding S.A

6 February 2026

- Publication date of the current administrative sanction on Corestate Capital Holding S.A

Compliance Impact

Urgency: High – This represents repeat enforcement on Corestate (second sanction in under a year), aligning with CSSF's pattern of nominative publications for severe, ongoing breaches in depositary and governance areas, as seen in JTC (EUR 102,000 fine for similar safekeeping/oversight failures) and BigRep SE (EUR 10,000 for reporting lapses). It elevates risks of fines, reputational damage, and market jeopardy assessments under AIFM Law Article 51, urging preemptive remediation amid CSSF's active 2023-2026 inspection cycle.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Topics:

Asset ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News low

February 5th 2026

Reappointment of Claude Marx as Director General of the CSSF

Press release 26/03

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance Authorisation & Licensing

BankWealth Manager

🇱🇺 CSSF Enforcement high

February 4th 2026

Administrative sanction of 23 July 2025

Administrative sanction imposed on Genève Invest (Europe) S.A.

AI Analysis

The CSSF imposed an administrative sanction on 23 July 2025 against Genève Invest (Europe) S.A., a Luxembourg-regulated entity, for breaches of professional obligations, as detailed in a publication released on 4 February 2026. This enforcement action underscores the CSSF's focus on robust internal controls and compliance with investment rules, serving as a warning to investment firms on the consequences of organizational and conduct failures. Compliance professionals should note it as evidence of heightened CSSF scrutiny on fund managers handling client assets and counterparties.

What Changed

This is not a regulatory change or new requirement but an enforcement action highlighting existing obligations under Luxembourg law. Key breaches likely mirror patterns in recent CSSF sanctions, such as non-compliance with UCI Law provisions on investment policies (e.g., Articles 41, 43), sound accounting procedures (Article 109), and rules of conduct (Articles 111, CSSF Regulation 10-04), including improper cash deposits with unauthorized brokers and inaccurate asset valuation.

Suggested Considerations

Immediate review of counterparty due diligence: Verify licenses and financial stability of brokers/prime brokers; cease deposits with unauthorized or suspended entities per UCI Law Article 41.
Enhance valuation and accounting controls: Ensure assets (e.g., cash deposits) are valued at probable realization value per Article 28(4) UCI Law and prospectus terms; implement automated monitoring for ongoing compliance.
Conduct internal audits: Assess organizational requirements, investment policies, and conduct rules (CSSF Regulation 10-04); remediate gaps proactively, as seen in mitigated sanctions for cooperative firms.
Update governance and reporting: Document risk assessments and report prior breaches to CSSF to demonstrate cooperation, potentially reducing fine severity.

Key Dates

23 July 2025

- Date of administrative sanction imposition on Genève Invest (Europe) S.A

4 February 2026

- Publication date of the sanction document by CSSF

Compliance Impact

Urgency: High – This sanction, published today (4 February 2026), signals ongoing CSSF off-site and on-site probes into fund operations, similar to fines imposed in July 2025 on Zeus Asset Management (€18,136 for UCI breaches) and a bank (reprimand for AML gaps). It matters due to escalating enforcement—fines calibrated to turnover (e.g., 10% in Zeus case)—and risks of reputational damage, especially for wealth managers with broker exposures. Non-compliance could trigger investigations, as CSSF considers infringement duration, cooperation, and history.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Topics:

Asset ManagerWealth ManagerAll Firms

Investment Management Wealth & Private Banking Capital Markets & Trading

🇦🇺 ASIC News high

February 4th 2026

Director of Warwick Gold and Impact Gold disqualified from managing corporations for four years

Sectors:

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

Asset ManagerWealth ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

February 4th 2026

ASIC permanently bans Patrick Nong from the financial services industry

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Wealth Manager

🇪🇺 ESMA Consultation low

February 3rd 2026

ESMA launches selection process for its next Chair

ESMA launches selection process for its next Chair 03 February 2026 About ESMA Careers Vacancies The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has launched the selection procedure for the position of ESMA Chair . This key leadership role offers the opportunity to shape the future of Europe’s financial markets and steer the organisation through an evolving regulatory and supervisory landscape. As a full‑time, independent professional...

AI Analysis

ESMA has launched a selection process for its next Chair, a full-time independent role based in Paris responsible for leading strategic direction, governance, and representation amid evolving EU financial markets regulation. This matters for compliance professionals as the incoming Chair will influence ESMA's supervisory priorities, enforcement approach, and adaptation to upcoming legislative changes like market integration proposals, potentially impacting how firms navigate cross-border supervision and reporting requirements.

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Senior Managers / Governance

Topics:

All Firms

Banking & Credit Capital Markets & Trading Wealth & Private Banking

🇯🇵 JFSA News medium

February 2nd 2026

Councils,The Expert Panel on the Revision of the Corporate Governance Code (1st meeting) Minutes

No description available.

Sectors:

Topics:

Prudential / Capital Requirements Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerAll Firms

Capital Markets & Trading Investment Management

🇺🇸 SEC News medium

January 30th 2026

SEC Appoints New Chairman and Board Members to PCAOB

The Securities and Exchange Commission today announced the appointment of Demetrios (Jim) Logothetis, as Chairman, and Mark Calabria, Kyle Hauptman, and Steven Laughton, as Board members, of the Public Company Accounting Oversight Board (PCAOB). George…

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Asset ManagerBroker DealerBank

Banking & Credit Investment Management Wealth & Private Banking

🇨🇦 OSFI News high

January 29th 2026

Backgrounder: Consultative document on Senior Leader Accountability

Sectors:

Topics:

Senior Managers / Governance Prudential / Capital Requirements Operational Resilience / Outsourcing

BankWealth ManagerAsset Manager

🇺🇸 CFTC News low

January 28th 2026

CFTC Announces Tyler S. Badgley as General Counsel

No description available.

Sectors:

Authorisation & Licensing Senior Managers / Governance

Topics:

All Firms

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Continuing Education

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerWealth ManagerAsset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Consolidated Reports

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerAsset ManagerBank

Banking & Credit Capital Markets & Trading Investment Management

🇺🇸 FINRA regulatory_notice high

January 24th 2026

Conflicts of Interest

Sectors:

Topics:

Consumer Protection / Conduct Market Abuse / Surveillance Senior Managers / Governance

Broker DealerBankAsset Manager

Investment Management Wealth & Private Banking Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Central Registration Depository (CRD)

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerWealth ManagerAsset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Carrying Agreements

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerAsset ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Branch Offices

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerWealth ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Books and Records

Sectors:

Topics:

Reporting & Disclosure Operational Resilience / Outsourcing Senior Managers / Governance

Broker DealerAsset ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-01

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerBank

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice low

January 24th 2026

Special Notice – 5/15/25

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerAsset ManagerAll Firms

🇺🇸 FINRA Guidance high

January 24th 2026

Information Notice - 8/14/25

AI Analysis

This FINRA Information Notice dated August 14, 2025, reminds registered persons and firms of annual continuing education (CE) requirements under FINRA Rule 1240, including 2025 Regulatory Element completion by December 31, 2025, and resources for Firm Element plans via the FLEX catalog. It matters because non-compliance triggers automatic CE inactive status, halting registered activities, with today's date (January 25, 2026) indicating the deadline has passed, requiring immediate remediation for affected individuals.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

What Changed

- Effective January 1, 2023, amendments to FINRA Rule 1240 mandate annual completion of both Regulatory Element and Firm Element for all registered persons, per CE Council...
Launched July 1, 2024, the Financial Learning Experience (FLEX) serves as an optional centralized catalog for Firm Element e-learning courses to support written training...
2025 Regulatory Element courses are pre-assigned via FinPro Gateway, with topics viewable via FINRA's interactive tool; changes occur if registrations are...

Suggested Considerations

Registered persons: Log into FinPro Gateway to complete assigned 2025 Regulatory Element courses by deadline (or request extension via firm for good cause); update contact info for notifications.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Firms: Conduct annual Firm Element needs analysis and develop written training plans using FLEX and published Regulatory topics; monitor completion, request extensions if needed, and maintain records.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]
Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

Key Dates

October 1 (annually)

- FINRA publishes upcoming Regulatory Element topics by registration category

January 1, 2023

- Effective date of CE rule amendments requiring annual Regulatory and Firm Elements.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

July 1, 2024

- Launch of FLEX catalog for Firm Element resources.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

December 31, 2025 DEADLINE

- Deadline to complete 2025 Regulatory Element courses; non-completion results in automatic CE inactive status.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

Compliance Impact

Urgency: High - The December 31, 2025, deadline has passed (as of January 25, 2026), meaning non-compliant registered persons are already CE inactive and barred from registered functions until remediation, risking operational disruptions, exam retakes, or enforcement. Firms face supervisory liability for inadequate monitoring, with repeated reminders (e.g., 2024 notice) signaling FINRA enforcement focus.[https://www.finra.org/rules-guidance/notices/information-notice-20250814]

References

AI-generated analysis. May contain errors or omissions — verify with the original FINRA source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance

Topics:

Broker DealerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-09

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerWealth ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Election Notice – 9/4/25

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-13

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Broker DealerWealth ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Election Notice – 10/20/25

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇺🇸 FINRA regulatory_notice high

January 24th 2026

Regulatory Notice 26-02

Sectors:

Topics:

Consumer Protection / Conduct Operational Resilience / Outsourcing Senior Managers / Governance

Broker DealerWealth ManagerBank

Banking & Credit Investment Management Insurance & Pensions

🇬🇧 FCA Guidance medium

January 24th 2026

Statement of Policy on statutory investigations into regulatory failure and producing reports [PDF]

Policy and guidance

AI Analysis

The FCA's updated Statement of Policy outlines its approach to statutory investigations into possible regulatory failures under Part 5 of the Financial Services Act 2012, including criteria for triggering investigations and producing reports for HM Treasury. It matters because it clarifies when the FCA must self-scrutinize serious lapses in regulation, helping firms anticipate rare but high-profile probes into systemic issues affecting consumer protection, market integrity, or competition. The primary update adjusts inflation-linked monetary thresholds for assessing "significant" consumer detriment, ensuring the policy remains relevant.

What Changed

- Inflation-adjusted monetary thresholds for consumer detriment: Detriment exceeding £210 million is more likely deemed "significant," while below £45 million is unlikely to meet the threshold unless...
No other substantive changes from the 2013 policy; refinements emphasize internal "lessons learned" reviews for non-statutory cases to avoid resource duplication in formal probes.
Clarified two-part statutory test: (1) Events indicating significant failure in consumer protection or adverse effects on integrity/competition objectives; (2) Events might not have occurred (or...

Suggested Considerations

Monitor for triggering events: Firms should self-assess operations against the two-part test, particularly potential consumer detriment exceeding £45m/£210m thresholds or impacts on FCA objectives.
Enhance internal reviews: Conduct "lessons learned" exercises post-incident to align with FCA's non-statutory approach, reducing escalation risk to formal probes.
No direct firm obligations: This is FCA policy on self-investigation; firms face no new reporting or compliance mandates but should prepare for FCA enquiries if events suggest regulatory system failures.
Document qualitative factors (e.g., vulnerability) in risk assessments to contextualize detriment.

Key Dates

14 November 2025

- Publication date of updated Statement of Policy

Compliance Impact

Urgency: Medium. This update signals FCA's commitment to accountability without imposing new firm-level rules, but it heightens focus on significant failures (£45m+ detriment), potentially leading to public reports exposing industry-wide gaps. Firms with high consumer exposure (e.g., retail-facing) should prioritize as probes, though rare, amplify reputational and remedial risks via Treasury publication.

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Senior Managers / Governance Reporting & Disclosure

Asset ManagerBankInsurance

Banking & Credit Investment Management Insurance & Pensions

🇬🇧 FCA Guidance high

January 24th 2026

PS25/23: Tackling non-financial misconduct in financial services

Policy statements

AI Analysis

The FCA's PS25/23 finalizes guidance on tackling **non-financial misconduct (NFM)** in financial services, amending the COCON sourcebook to clarify how serious NFM breaches conduct rules and integrating it into FIT assessments for fitness and propriety. This matters because it aligns rules across banks and non-banks, enhances accountability, deters harmful workplace cultures, and supports FCA objectives like consumer protection and market integrity by ensuring consistent handling of issues like bullying or harassment.

What Changed

- COCON amendments: Expands scope to non-banks for work-related serious NFM involving financial services personnel; provides flowcharts, examples, and factors (e.g., seriousness, pattern, dishonesty,...
FIT sourcebook updates: Integrates NFM into fit and proper tests for employees/senior personnel; firms assess case-by-case without investigating implausible claims or breaching privacy; removes...
Managerial accountability: Relative to knowledge/authority under ICR2; no expansion into purely private life.
Minor tweaks from CP25/18 feedback: New diagrams, employment law alignment, withdrawn burdensome factors.

Suggested Considerations

Review and update policies/handbooks to incorporate COCON/FIT guidance on NFM assessment, including flowcharts and factors for breaches/fitness.
Train HR, compliance, and managers on applying rules consistently, emphasizing seriousness thresholds, case-by-case judgement, and alignment with employment law/privacy.
Enhance regulatory reference processes to disclose past NFM; ensure reporting of serious breaches to FCA.
Assess current NFM handling for gaps (e.g., non-bank alignment); document decision-making to demonstrate fairness/decisiveness.
Firms not to investigate trivial/improbable allegations or overstep privacy laws.

Key Dates

1 September 2026

- New COCON rules and guidance come into force (non-retrospective)

Compliance Impact

Urgency: High – With rules effective 1 September 2026 (9+ months from today), firms have preparation time, but PS25/23 closes FCA's NFM policy work, shifting to supervision/enforcement focus; non-compliance risks enforcement, FIT failures, and reputational damage amid trust-building priorities in FCA Strategy 2025-2030.

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Senior Managers / Governance

Asset ManagerBankInsurance

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

ASIC bans former Lighthouse Partners director Timothy Archibald for 10 years for fees for no service conduct

Sectors:

Topics:

Consumer Protection / Conduct Senior Managers / Governance Authorisation & Licensing

Wealth ManagerAll Firms

Investment Management Wealth & Private Banking Insurance & Pensions

🇦🇺 ASIC News high

January 24th 2026

ASIC sends clear message to super trustees amid glaring retirement communications gaps

Sectors:

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

Asset ManagerWealth ManagerInsurance

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Directors of Perth-based financial services company charged over five-year failure to lodge financial accounts with ASIC

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerAll Firms

Banking & Credit Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

ASIC bans former Crown Wealth Group director Brendan Rodwell for failing to report fees for no service conduct

Sectors:

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

Wealth ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Banned SMSF Auditor charged with continuing to act whilst disqualified and falsifying documents

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

ASIC calls on Australian companies to adopt better practices to protect whistleblowers

Sectors:

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

BankWealth ManagerAll Firms

🇦🇺 ASIC News high

January 24th 2026

ASIC suspends AFS licence of MW Planning Pty Ltd following failure to replace responsible manager

Sectors:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

Topics:

Wealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

ASIC renews guidance on managing conflicts of interest in financial services

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBank

🇦🇺 ASIC News high

January 24th 2026

CADB cancels registration of Sydney auditor for breaching duties across 10 ASX-listed audits

Sectors:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Topics:

BankBroker Dealer

Senior Managers / Governance Operational Resilience / Outsourcing

🇦🇺 ASIC News medium

January 24th 2026

No description available.

AI Analysis

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...
Internal control functions: Responsibilities, characteristics, organization, and execution of work for compliance officers and internal auditors, with notifications to CSSF including detailed...
Conflicts of interest: Key requirements for a management policy applicable to all staff and management body members.
New product approval: Defined key steps in the process.

Suggested Considerations

Gap analysis: Assess current frameworks against circular requirements on management bodies, internal controls, conflicts of interest, product approval, and fund safeguarding.
Updates and notifications: Review/revise governance arrangements (e.g., policies, structures); notify CSSF of management body members, compliance officers, and internal auditors with required documentation (professional experience, police records, etc.).
Implementation: Establish robust risk identification/management/monitoring/reporting processes, internal controls, and proportional arrangements (e.g., IT, outsourcing).
Documentation: Develop conflicts policy, new product approval procedures, and safeguarding rules; ensure management body authorization.
Ongoing: Maintain sound/prudent management amid growth; integrate with Law of 10 November 2009 requirements.

Key Dates

20 January 2026

- Publication date of Circular CSSF 26/906

30 June 2026 DEADLINE

- Compliance deadline: Institutions must assess/review central administration, internal governance, and risk management frameworks to ensure full compliance

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 "sound and prudent management" in a high-volume industry; proactive reviews are essential to avoid disruptions.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Payments & E-Money

Topics:

Payment ProviderFintech

Senior Managers / Governance AML / Financial Crime Operational Resilience / Outsourcing

🇱🇺 CSSF Guidance high

January 20th 2026

Circular CSSF 26/906

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.

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...
Governance enhancements: Board approves strategy, risk appetite, AML/CFT policies, outsourcing, and information security; management implements via procedures; proportionality based on business...
Operational controls: Strict access to systems (need-to-know, least-privilege, 4-eyes validation); counterparty due diligence for custodians/insurers; full responsibility for agents, distributors,...
AML/CFT focus: Elevates compliance function independence, direct board reporting, risk-based resourcing, and oversight of third parties/opaque structures to close gaps exploited by criminals.

Suggested Considerations

Assess and update governance frameworks: Review central administration location, board/management responsibilities, risk strategy, AML/CFT policies, compliance charter, and funds safeguarding principles to align with the circular.
Confirm control functions: Ensure compliance function (CCO) has independence, resources, direct board access, and authority for investigations; justify/secure CSSF approval for part-time/dual roles.
Implement operational safeguards: Establish daily reconciliations (or justified weekly), segregation/insurance for client funds, system access controls (4-eyes, board validation for significant movements), and third-party due diligence/monitoring.
Document proportionality: Tailor governance to business risks (staff, volumes, products, outsourcing); update new product approval, conflicts policies, and business continuity/incident reporting.
Retain records and report: Board-approve all key policies; prepare for CSSF inspections on outsourcing (per Circular CSSF 22/806) and ICT risks.

Key Dates

20 January 2026

Publication date of Circular CSSF 26/906

30 June 2026 DEADLINE

Compliance deadline; Institutions must assess, review, and ensure their central administration, internal governance, and risk management frameworks fully comply with the circular

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 exploitation vectors like weak controls and third-party risks.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Payments & E-Money

Topics:

Payment Provider

🇱🇺 CSSF Guidance high

January 20th 2026

Circular CSSF 26/905

Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01)

AI Analysis

Circular CSSF 26/905 mandates the application of EBA Guidelines (EBA/GL/2025/01) on managing **ESG risks** for Luxembourg-supervised institutions, requiring integration of environmental, social, and governance risk identification, measurement, management, and monitoring into internal processes. This aligns with CRD amendments (Articles 74, 76, 87a) and emphasizes proportionality to institutions' business models, with plans including timelines, targets, and milestones toward EU climate goals like net-zero by 2050. It matters for compliance as it embeds ESG into prudential supervision, potentially impacting capital, risk frameworks, and supervisory reviews.

What Changed

- Institutions must establish proportionate strategies, policies, processes, and systems for ESG risk management, covering short-, medium-, and long-term horizons, including transition and physical...
Develop plans per Article 76(2) CRD with specific timelines, intermediate quantifiable targets, and milestones to address ESG financial risks, consistent with EU objectives (e.g., 55% GHG reduction...
Incorporate ESG into internal governance, risk appetite, and supervisory review processes (SREP), with scenario analysis requirements (to be detailed in future EBA guidelines).
Applies minimum standards and methodologies for ESG risk identification, measurement, monitoring, and impact assessment on institutions' exposures.
No requirement for full alignment with specific sustainability trajectories, but plans must consider transition risks and institutions' ESG product offerings, loan policies, and targets.

Suggested Considerations

Map and integrate ESG risks into governance, risk management frameworks, and business strategies, proportionate to scale/risk exposure.
Develop and document ESG risk management plans with quantifiable targets, milestones, timelines, and scenario analyses (broad requirements now; detailed later).
Conduct assessments of ESG risks in portfolios, including sustainability products, transition finance, and loan origination policies, for SREP submission.
Embed in internal processes per Articles 74, 76, 87a CRD: identify/measure ESG risks (minimum standards), monitor over time horizons, and report to CSSF.
Review and update existing policies/systems for compliance by applicable dates; prepare for CSSF supervisory evaluation of plan robustness.

Key Dates

20 January 2026

- Circular published by CSSF

1 April 2026

- Application date for Less Significant Institutions (other than SNCIs)

11 January 2027

- Application date for SNCIs (dependent on CRD transposition)

Compliance Impact

Urgency: High - With application starting 1 April 2026 (just over 2 months from publication), firms face immediate pressure to gap-analyze current ESG frameworks against EBA standards, especially for SREP integration and long-term risk planning. Non-compliance risks supervisory scrutiny, capital add-ons, or enforcement, as ESG is now a core prudential pillar amid EU sustainability push; smaller institutions get a head-start but must act swiftly given proportionality demands.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

ESG Prudential / Capital Requirements Senior Managers / Governance

Topics:

BankAll Firms

Banking & Credit Capital Markets & Trading Investment Management

🇬🇧 PRA policy_statement high

January 20th 2026

PS1/26 – Implementation of Basel 3.1: Final rules

Policy statement 1/26

AI Analysis

PS1/26 represents the UK Prudential Regulation Authority's final implementation framework for the Basel 3.1 international banking standards, effective 1 January 2027 (with market risk internal models delayed to 1 January 2028). This policy statement establishes mandatory capital, credit risk, operational risk, and market risk requirements for UK-regulated banks, building societies, and investment firms, addressing post-financial crisis shortcomings in risk-weighted asset (RWA) calculations and capital adequacy frameworks.

What Changed

Credit Risk Framework
Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures)...
Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques. Operational Risk
Updated Business Indicator Component (BIC) calculation methodology requiring inclusion of the current financial year in the three-year average calculation (or an estimate if unavailable).
Clarifications on legal risk treatment and loss data set dates. Market Risk (Fundamental Review of the Trading Book – FRTB)

Suggested Considerations

*Immediate (by mid-2026)
*Conduct impact assessment: Quantify RWA changes under Basel 3.1 across credit risk, operational risk, and market risk frameworks.
*Review IRB permissions: Identify exposures requiring reclassification (e.g., IPRE to HVCRE) and prepare permission amendment applications.
*Assess FRTB-IMA readiness: For firms with existing IMA permissions, evaluate transition strategy for out-of-scope positions moving to ASA/SSA during interim period (2027–2027).
*Arrange board-level assurance: Establish governance framework for board oversight of RWA calculation accuracy and Basel 3.1 implementation.

Key Dates

20 January 2026

– PRA publishes PS1/26 (final rules)

2026 ICAAP submission deadline DEADLINE

– Must include Basel 3.1/SDDT impact assessment

1 January 2027

– Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)

1 January 2027

– Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA

1 January 2028

– FRTB-IMA implementation effective date

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Points to Consider

The Prudential Regulation Authority (PRA) has published the final rules for the implementation of Basel 3.1 standards in the UK, with an effective date of January 1, 2027. The rules aim to enhance the resilience of banks and improve the stability of the financial system. Firms must review and update their policies and procedures to ensure compliance with the new requirements.

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankBroker DealerAsset Manager

Banking & Credit Wealth & Private Banking Consumer Credit

🇱🇺 CSSF News medium

January 20th 2026

ML/FT Sub-Sector Risk Assessment on Specialised Professionals of the Financial Sector providing corporate services (trust and company service provider activities) (Updated)

2026 update

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerFamily Office

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 FCA News high

January 19th 2026

Tribunal upholds ban and fines for corrupt and dishonest adviser

The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him £2,037,892 has been upheld by the Upper Tribunal. The FCA's decision to ban Darren Antony Reynolds from working in financial services and fine him £2,037,892 has been upheld by the Upper Tribunal.Mr Reynolds was dishonest when he gave pension transfer advice and investment recommendations to his customers, causing them significant harm.Mr Reynolds showed a clear disregard for his customers’ intere...

Sectors:

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

Wealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇭🇰 SFC Speech

January 16th 2026

New speech by Kelvin Wong: Speech at the Hong Kong Chartered Governance Institute’s Annual Reception 2026

No description available.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 SEC News low

January 15th 2026

J. Russell McGranahan Named SEC General Counsel

The Securities and Exchange Commission today announced that J. Russell “Rusty” McGranahan has been named SEC General Counsel. As the SEC’s chief legal officer, Mr. McGranahan will oversee the provision of legal expertise and advice to the Office of the…

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

BankAsset ManagerBroker Dealer

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 PRA News medium

January 15th 2026

Letter from Rebecca Jackson and Alison Scott – International Banks Supervision: 2026 priorities

Letter to Chief Executive Officers of PRA regulated international banks active in the UK

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE Speech

January 14th 2026

The evolution of the Bank’s approach to resolution − speech by Dave Ramsden

Given at King’s College London

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankWealth ManagerAll Firms

🇮🇪 CBI Enforcement medium

January 14th 2026

Speech by Gerry Cross, Director, Capital Markets and Funds, Central Bank of Ireland at Compliance Institute AGM - Supervising for success: some themes for a time of change

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.

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...
Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcomes-focused, less process-driven supervision integrated across financial stability, consumer protection, safety/soundness,...
Regulatory Simplification: Openness to reviewing frameworks (e.g., fitness and probity) for simpler, outcomes-based alternatives without compromising effectiveness; supports broader simplification...
Resilience and Technology: Ongoing focus on financial resilience post-reforms, leveraging technology for supervision; no specific new rules but emphasis on embedding these in operations. No new...

Suggested Considerations

Implement Revised Consumer Protection Code: Complete readiness by 24 March 2026; apply new Standards for Business in operations, leveraging CBI workshops for guidance.
Embed IAF: Maintain enhanced responsibility mapping, support decision-making, and engage with CBI on implementation feedback to mature governance.
Adopt Outcomes-Focused Practices: Shift from process-driven to outcomes-based compliance (e.g., customer interests, resilience); review internal frameworks for simplification opportunities.
Engage with CBI: Participate in ongoing consultations, workshops, and stakeholder feedback on supervision evolution, IAF, and Consumer Protection Code.
Leverage Technology: Integrate tech for resilience and compliance efficiency, aligning with CBI's supervisory priorities.

Key Dates

BankAsset ManagerWealth Manager

Capital Markets & Trading Investment Management Crypto & Digital Assets

🇺🇸 SEC Enforcement medium

January 12th 2026

Paul Tzur and David Morrell Named Deputy Directors of the Division of Enforcement

The Securities and Exchange Commission today announced that Paul H. Tzur and David M. Morrell have been named as Deputy Directors of the Division of Enforcement. Mr. Tzur joined the Commission on January 6, 2026, as the Deputy Director overseeing the…

AI Analysis

The SEC announced on January 12, 2026, the appointment of Paul H. Tzur and David M. Morrell as Deputy Directors of the Division of Enforcement, with Tzur joining on January 6, 2026, to oversee key operations. This personnel change is part of a broader reorganization replacing Regional Directors with Deputy Directors for more centralized oversight of investigations. It matters for compliance teams as it signals greater consistency in enforcement approaches, potentially affecting investigation timelines, Wells process strategies, and settlement negotiations across SEC-regulated entities.

What Changed

This announcement reflects structural reforms rather than new substantive regulations:
Replacement of Regional Directors with Deputy Directors, centralizing reporting from local offices (e.g., Boston, Fort Worth, Atlanta) and specialized units directly to headquarters-led Deputy...
Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations.
Complements parallel Wells process reforms under Chairman Paul Atkins, including a baseline four-week response period, greater access to evidence, and senior-level meetings for transparency and due...

Suggested Considerations

Review and update internal protocols for SEC investigations to align with centralized reporting structures, anticipating uniform standards across regions.
Train legal/compliance staff on refined Wells process (e.g., prepare for four-week timelines and evidence access requests).
Monitor upcoming SEC communications for Enforcement Director Judge Margaret Ryan's guidance on fraud-focused priorities.
Assess current or potential matters for earlier engagement with Deputy Directors on case theories and resolutions.

Key Dates

January 6, 2026

- Paul H. Tzur joins SEC as Deputy Director of the Division of Enforcement.

January 12, 2026

- SEC announces appointments of Paul Tzur and David Morrell as Deputy Directors.

Compliance Impact

Urgency: Medium. This matters due to its role in ongoing SEC transition under Chairman Atkins and Director Ryan, promising more predictable enforcement but requiring adaptation to centralized decision-making and Wells enhancements. While not imposing immediate obligations, it could accelerate case resolutions and shift settlement dynamics, especially amid 2025's enforcement slowdown from staffing cuts (15-20% headcount reduction). Firms with active investigations should prioritize strategic adjustments now.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Market Abuse / Surveillance Reporting & Disclosure

Asset ManagerBroker DealerHedge Fund

🇱🇺 CSSF Enforcement high

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on Max Gain Capital S.à r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.

What Changed

This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but continued non-compliance triggers administrative fines under Article 8-4 of the AML/CFT Law.

Suggested Considerations

regulated entities must:
*Identify Reporting Obligations: Confirm whether your firm is subject to the annual financial crime questionnaire requirement under Article 5(1) of the AML/CFT Law
*Calendar Management: Establish internal processes to ensure questionnaires are submitted by 4 April each year for the preceding calendar year
*Documentation: Maintain records demonstrating timely submission and preserve evidence of compliance
*Escalation Protocol: If unable to meet deadlines, proactively contact the CSSF to request extensions or clarification rather than ignoring reminders

Key Dates

4 April 2025 DEADLINE

- Deadline for submission of financial crime questionnaire for the year ending 31 December 2024

Before 11 September 2025 DEADLINE

- CSSF issued two reminders to Max Gain Capital after the missed deadline

11 September 2025

- CSSF imposed the €10,000 administrative fine

9 January 2026

- CSSF published the administrative sanction decision

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

Topics:

Asset ManagerAll Firms

🇱🇺 CSSF Enforcement high

January 9th 2026

Administrative sanction of 23 July 2025

Administrative sanction imposed on JTC (Luxembourg) S.A.

AI Analysis

The CSSF imposed a €102,000 administrative fine on JTC (Luxembourg) S.A. on 23 July 2025 for breaches in its professional obligations as a depositary of non-financial assets under the AIFM Law, identified during an on-site inspection from February 2023 to January 2024 covering activities up to December 2022. This enforcement action highlights CSSF's scrutiny of depositary functions, particularly risk assessment and oversight controls, serving as a warning for similar entities to strengthen compliance amid rising supervisory focus on AIFM depositaries.

What Changed

This is an enforcement action, not a regulatory change; it enforces existing requirements under Article 51(1) (1st and 7th indents) and Article 51(2) (1st sub-paragraph, 3rd indent) of the amended Law of 12 July 2013 on AIFMs (AIFM Law), and related provisions like Article 92(1) of Commission Delegated Regulation (EU) No 231/2013 (CDR 231/2013).

Suggested Considerations

related entities) must:
Conduct immediate gap analyses on risk assessment processes for AIF strategies and AIFM organization per Article 92(1) CDR 231/2013.
Implement robust verification processes for AIFM compliance with asset delegation rules.
Ensure availability of key documentation and evidence of controls for the depositary function, addressing pre-2022 gaps if applicable.
Develop and test oversight processes, leveraging self-identified improvements and action plans as mitigating factors, as JTC did prior to inspection.

Key Dates

February 2023

January 2024; Period of CSSF on-site inspection on depositary obligations, covering activities up to December 2022

23 July 2025

Date CSSF imposed the €102,000 administrative fine on JTC (Luxembourg) S.A

9 January 2026

Date of official CSSF publication announcing the sanction

Compliance Impact

Urgency: High – This matters due to the fine's size (€102,000), reflecting breach accumulation, severity, and duration, despite JTC's partial remediation; it signals intensified CSSF on-site scrutiny of depositary functions post-2023 inspections, with potential for higher penalties absent proactive controls. Depositaries face elevated enforcement risk, especially with unavailability of evidence pre-2022, urging swift remediation to avoid similar outcomes under Article 51 AIFM Law.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

Topics:

Asset Manager

🇱🇺 CSSF Guidance high

January 9th 2026

Circular CSSF 24/853 (as amended by Circulars CSSF 25/870 and 26/904) (Updated)

Long Form Report – Practical rules concerning the self-assessment questionnaire to be submitted by investment firms – Mission and related reports of the réviseurs d’entreprises agréés (approved statutory auditors)

Sectors:

Reporting & Disclosure AML / Financial Crime Senior Managers / Governance

Topics:

Broker DealerAll Firms

🇫🇷 AMF Enforcement high

January 8th 2026

The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations

Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations.

What Changed

This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures.
Imprecise investment allocation processes lacking traceability, rendering systems non-operational.
Failure to fulfill conflict of interest identification, prevention, and management obligations.
Deficient AML/CFT systems with inadequate due diligence on fund assets/liabilities. These align with prior AMF expectations for "honest, fair, and professional" conduct with skill, care, and...

Suggested Considerations

Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules.
Enhance AML/CFT systems: Update risk mapping, procedures, and due diligence on fund assets/liabilities; ensure systematic application.
Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously.
Senior managers: Demonstrate personal oversight via governance records to mitigate attribution of firm breaches.
Audit marketing materials, fee retrocessions, and valuation procedures (e.g., for real estate or experts) against AMF standards.

Key Dates

August 2019

December 2023; - Period of breaches investigated

31 December 2025

- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors

08 January 2026

- Public news release date for the decision

Compliance Impact

Urgency: High - This reflects a pattern of 2025-2026 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc 15 Sep 2025; €400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immediate audits are essential pre-audit cycles, especially with appeals highlighting ongoing litigation risk.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset Manager

🇱🇺 CSSF Guidance high

January 8th 2026

Circular CSSF 26/904

Update of Circular CSSF 24/853 on the Long Form Report (as amended by Circular CSSF 25/870) – Practical rules concerning the self-assessment questionnaire to be submitted by investment firms Mission and related reports of the réviseurs d’entreprises agréés (approved statutory auditors)

AI Analysis

Circular CSSF 26/904 updates Circular CSSF 24/853 (as amended by Circular CSSF 25/870) by introducing a revised Long Form Report (LFR) for investment firms, featuring a digital self-assessment questionnaire (SAQ) and enhanced auditor reports focused on AML/CFT and risk management. This matters because it aligns reporting with CSSF's risk-based supervision under CSSF 4.0, reduces redundancies, applies proportionality based on business models, and mandates digital submission to improve efficiency and data analysis.

What Changed

- Revised LFR Structure: Comprises four parts in a single digital document: (1) yearly SAQ completed by investment firms; (2) descriptive elements verified by approved statutory auditors (REAs); (3)...
Digital Format: Completion and submission via CSSF's online portal, supporting CSSF 4.0 digital strategy for efficient processing.
Proportionality and Scope: Applies individually to investment firms (no consolidated LFR if under CSSF consolidated supervision); focuses on incremental, relevant information tied to business models,...
Enhanced AML/CFT Focus: Requires descriptions of commercial policy, ML/FT risk management, roles/responsibilities, branch/subsidiary/tied agent compliance; REA must assess adequacy of...
REA Responsibilities: Verify/ensure adequacy of SAQ elements, assess descriptions, perform control procedures, and provide assessments on AML/CFT policy implementation across entities.

Suggested Considerations

Investment Firms: Complete and submit the digital SAQ yearly via CSSF portal, providing descriptions of business model, ML/FT risks, commercial policy, monitoring, AML/CFT roles, and entity-level compliance; ensure data on fund transfers (e.g., missing payer/payee info) is included.
REAs/Auditors: Verify SAQ adequacy, assess descriptions, perform corroborative controls, supplement with findings (e.g., AML/CFT audit declarations), independently assess ML/FT risks/organization, and integrate into single LFR document.
General: Review existing processes for proportionality (focus on incremental info); update AML/CFT policies/documentation for branches/subsidiaries/tied agents; prepare for digital submission; document risk assessments thoroughly.
Ongoing: Monitor compliance with related regs like Regulation (EU) 2023/1113 (effective 30 December 2024, per draft bill 8387).

Key Dates

Financial year ending 31 December 2024

- Applicability of revised LFR to all investment firms; submissions begin for this period onward on a yearly basis

No specific submission deadline stated DEADLINE

- Yearly production required via CSSF portal; firms should align with existing annual reporting cycles for auditors (typically post-year-end)

Compliance Impact

Urgency: High - Applies immediately to FY ending 31 December 2024 reports, requiring swift updates to reporting processes, digital tools, and AML/CFT documentation amid CSSF's risk-based shift; non-compliance risks supervisory actions, as LFR directly informs CSSF oversight on key prudential/AML areas with no transition period specified.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Reporting & Disclosure Senior Managers / Governance

Topics:

Asset ManagerBroker DealerAll Firms

Banking & Credit Capital Markets & Trading Investment Management

🇬🇧 FCA News medium

January 8th 2026

2026 fines

This page contains information about fines published during 2026. The total amount of fines so far is £371,700. Firm or individual finedDateAmountReasonRichard Adam07/01/2026£232,800The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Rule 1.3.3R, Listing Principle 1 and Premium Listing Principle 2.Zafar Khan07/01/2026£138,900The Final Notice refers to knowing concern in breaches of Article 15 of the Market Abuse Regulations, Listing Ru...

Sectors:

Topics:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

BankBroker DealerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 FCA News high

January 7th 2026

FCA fines former finance directors of Carillion plc (in liquidation)

The FCA has fined 2 former finance directors for their part in misleading statements being issued by Carillion plc. Richard Adam and Zafar Khan were both aware of serious financial troubles in Carillion’s UK construction business but failed to reflect this in company announcements or alert the Board and audit committee, leading to poor oversight.Mr Adam and Mr Khan have been fined £232,800 and £138,900, respectively. The fines were imposed after Mr Adam and Mr Khan withdrew their challenges t...

Sectors:

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

BankWealth ManagerAll Firms

🇸🇬 MAS Guidance high

January 2nd 2026

ID 01/26 MAS Notice 126 - Lapses in Own Risk and Solvency Assessment (ORSA) Report Submissions

Inform and remind insurers of MAS Notice 126 requirements and expectations on ORSA report submissions.

AI Analysis

This MAS circular ID 01/26, published on 02 January 2026, addresses observed lapses in ORSA report submissions under MAS Notice 126, specifically reminding insurers not to fully rely on group-level ORSA reports to meet local requirements. It matters because non-compliance risks regulatory scrutiny, enforcement actions, and weakened enterprise risk management (ERM) frameworks essential for solvency and risk oversight in Singapore's insurance sector.

What Changed

No new regulatory changes are introduced; this is a reminder and clarification of existing MAS Notice 126 requirements on ORSA submissions. Key emphasis: Insurers cannot fully rely on group ORSA reports—local entities must produce their own tailored ORSA reports reflecting entity-specific risks, time horizons, and business strategies. It reinforces ORSA as a core ERM tool involving own risk assessment, solvency projections, and stress testing (e.g., macroeconomic scenarios).

Suggested Considerations

Review current ORSA processes to confirm entity-specific reports are produced, not mere group report adoptions.
Conduct gap analysis against Notice 126: Ensure ORSA covers risk identification, solvency assessment, stress testing (e.g., macroeconomic, liquidity), and forward-looking horizons aligned with business planning.
Update board and senior management oversight of ERM, documenting rationale for any group influences while maintaining local tailoring.
Submit ORSA reports to MAS as per ongoing Notice 126 timelines (typically annually); remediate any past lapses via voluntary disclosure if needed.
Enhance internal controls, training, and audit trails for ORSA compliance to avoid future observations.

Key Dates

19 February 2021

19 March 2021; - Consultation period on proposed revisions to Notices 124, 125, and 126

30 September 2022

- Last revision of MAS Notice 126 on ERM, including ORSA guidelines (effective 01 January 2023)

30 September 2022

- MAS response to consultation feedback on ERM revisions

02 January 2026

- Publication of ID 01/26 circular reminding of ORSA submission requirements under Notice 126

Compliance Impact

Urgency: High – Immediate attention required as the circular flags "several insurers" with lapses, signaling MAS active monitoring and potential targeted inspections or penalties. Matters for solvency regime integrity; non-compliance undermines ORSA's role in capital adequacy and could trigger supervisory interventions amid evolving risks like liquidity and macro stresses.

References

AI-generated analysis. May contain errors or omissions — verify with the original MAS source before acting. Full disclaimer.

Sectors:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

Topics:

Insurance

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

🇺🇸 CFTC News low

December 31st 2025

CFTC Chairman Selig Announces Amir Zaidi as Chief of Staff

No description available.

Sectors:

Topics:

Authorisation & Licensing Operational Resilience / Outsourcing Senior Managers / Governance

BankBroker DealerCrypto Exchange

Capital Markets & Trading Investment Management Wealth & Private Banking

🇺🇸 SEC News low

December 29th 2025

SEC Announces Retirement of Division of Corporation Finance Deputy Director Cicely LaMothe

The Securities and Exchange Commission today announced that Cicely LaMothe, Deputy Director of the Division of Corporation Finance, has retired from the agency.“Cicely has gone above and beyond the call of duty over the past twenty-four years to serve…

Sectors:

Topics:

Reporting & Disclosure Senior Managers / Governance Authorisation & Licensing

Asset ManagerBroker DealerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE News

December 23rd 2025

Minutes of the Meeting of the Court of Directors held on 28 October 2025

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Guidance high

December 23rd 2025

Circular CSSF 25/903

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.

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...
Auditor Engagement Rules: Introduces specific practical guidelines for approved statutory auditors, including mandatory scope of work, independence confirmations, and standardized procedures for...
Management Letter and Separate Report: Establishes detailed rules for auditors to issue an annual management letter (addressing findings, recommendations, and remediation) and a separate report for...
Enhanced Documentation and Evidence: Requires support PFS and auditors to provide verifiable evidence (e.g., checklists, testing samples) supporting self-assessments, with stricter CSSF validation...

Suggested Considerations

*Review and Update Processes: Support PFS must map current reporting against new templates in CSSF 25/903 and revise internal procedures for descriptive reports and self-assessments.
*Engage/Confirm Auditors: Select or confirm approved statutory auditors compliant with new engagement rules; execute updated engagement letters incorporating circular requirements by Q4 2025.
*Implement Templates and Testing: Adopt CSSF-provided templates for reports, management letters, and separate reports; conduct sample-based testing of controls as specified.
*Training and Governance: Train compliance/audit teams on changes; ensure board approval of self-assessments and auditor findings.
*Submit on Time: Prepare and file all documents by 30 April deadlines, retaining evidence for CSSF inspections.

Key Dates

30 April (annually) DEADLINE

Submission Deadline; Support 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)

31 December 2025 DEADLINE

Preparation Milestone; Auditors must be engaged and initial scoping completed by year-end 2025 for FY 2025 compliance

1 January 2026

Effective Date; Applies to annual reporting cycles starting for financial year 2025 onwards

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, potentially increasing costs (e.g., auditor fees) while reducing reporting errors—critical for smaller support entities with limited resources.

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Reporting & Disclosure Senior Managers / Governance Operational Resilience / Outsourcing

All FirmsFintechPayment Provider

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Guidance high

December 23rd 2025

Circular CSSF 24/850 (as amended by Circular CSSF 25/903) (Updated)

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.

What Changed

- Standardized Reporting Templates: Introduces detailed formats and content requirements for the annual descriptive report and self-assessment questionnaire, covering governance, risk management,...
Auditor Engagement Rules: Mandates approved statutory auditors to perform specific procedures, issue a management letter highlighting control weaknesses, and prepare a separate report confirming...
Amendments via CSSF 25/903: Updates clarify submission procedures, expand self-assessment criteria (e.g., adding cybersecurity and outsourcing risk questions), and refine auditor independence...
Frequency and Scope: Annual submissions required without exceptions; scope limited to support PFS (not primary PFS), emphasizing substance over form in service descriptions.

Suggested Considerations

Annual Reporting Cycle: 1. By year-end, conduct internal self-assessment using the prescribed questionnaire template (available via CSSF portal).
February to review submissions, test controls, and issue management letter (flagging deficiencies) plus separate compliance report.
Governance Updates: Review and update internal policies on risk assessment, auditor selection, and remediation of management letter findings; ensure board oversight of submissions.
Auditor Coordination: Verify auditor qualifications per CSSF register; implement any remediation plans from prior-year management letters before next cycle.
Record-Keeping: Maintain 5-year audit trail of all supporting documentation for CSSF inspections.

Key Dates

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

31 March annually DEADLINE

- 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)

End of February annually DEADLINE

- Support PFS must engage auditors and provide necessary data to enable timely report preparation

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, where CSSF prioritizes substance in delegated functions; failure risks de-authorization or client outflows. Early implementation of templates and auditor pipelines is essential to avoid first-year pitfalls.

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Reporting & Disclosure Operational Resilience / Outsourcing Senior Managers / Governance

BankWealth ManagerAll Firms

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

🇺🇸 CFTC News medium

December 22nd 2025

Michael Selig Sworn In as 16th CFTC Chairman

No description available.

Sectors:

Topics:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

BankBroker DealerCrypto Exchange

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

🇺🇸 CFTC News medium

December 22nd 2025

Acting Chairman Caroline D. Pham Announces Departure from CFTC

No description available.

Sectors:

Topics:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

BankBroker DealerCrypto Exchange

🇫🇷 AMF Enforcement high

December 22nd 2025

AMF Enforcement Committee fines the depositary CACEIS Bank for breaches of its professional obligations

Sanctions & settlements professional obligations Journalists Investment management companies Listed companies and issuers AMF Enforcement Committee fines the depositary CACEIS Bank for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined CACEIS Bank €3.5 million and issued a warning on 17 December 2025 for breaches of its professional obligations as depositary for seven French-law UCITS funds managed by H2O AM LLP (later transferred to H2O AM Europe). This decision underscores the AMF's strict enforcement of depositary oversight duties, particularly in verifying fund managers' investment monitoring systems, asset valuations, and compliance with prospectus constraints like issuer limits and security ratings. It matters for compliance teams as it highlights personal accountability risks and potential fines for inadequate due diligence in fund depositary roles, signaling heightened scrutiny amid past H2O fund issues.

What Changed

This is an enforcement action, not a regulatory change; it reinforces existing obligations under French UCITS rules (transposing UCITS Directive V) for depositaries. Key upheld objections include:
Failure to perform sufficient checks on the asset management company's (AMC) systems for monitoring UCITS investment ratios and valuing unlisted securities.
Inadequate verification of investment decision legality, such as compliance with prospectus limits on debt security ratings, derivative types, and the 10% single-issuer bond exposure cap. No new...

Suggested Considerations

Conduct gap analysis: Review depositary control frameworks against AMF expectations for verifying AMC investment monitoring, unlisted asset valuations, and prospectus compliance (e.g., 10% issuer limits, ratings).
Enhance oversight processes: Implement robust, documented checks on AMC systems, including independent testing of ratios, legality of investments, and derivatives.
Training and audits: Train staff on UCITS depositary duties; perform internal audits of ongoing fund oversight, prioritizing illiquid/unlisted exposures.
Monitor appeals: Track any CACEIS appeal, as outcomes could set precedents; update policies if upheld.
Reporting: Ensure timely escalation of suspected AMC breaches to AMF if identified.

Key Dates

BankAsset ManagerWealth Manager

🇫🇷 AMF Enforcement high

December 16th 2025

The AMF Enforcement Committee fines an asset management company and its former director a total of €500,000

Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company and its former director a total of €500,000

AI Analysis

The AMF Enforcement Committee fined asset management company Novaxia Investissement €400,000 and its former director Joachim Azan €100,000 on 10 December 2025 for breaches of professional obligations, primarily due to an incomplete and non-operational investment/divestment procedure lacking traceability of compliance checks and formalized due diligence. This enforcement action underscores AMF's focus on robust operational procedures in asset management, serving as a deterrent and educational tool for ensuring honest, fair, and diligent business conduct. Compliance teams should prioritize procedure operationalization to avoid similar sanctions, as this fits a pattern of recent AMF fines targeting procedural deficiencies.

What Changed

This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including:
Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints.
Formalized due diligence prior to allocating investment projects to funds. No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completeness and documentation,...

Suggested Considerations

Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e.g., alignment with fund policies), and formalized pre-allocation due diligence; test for operationality via internal audits.
Document all processes rigorously: Maintain evidence of checks and due diligence to demonstrate skill, care, and diligence in line with authorization conditions.
Conduct gap analysis against AMF expectations: Cross-reference with similar cases (e.g., operational procedures, AML/CFT); remediate deficiencies promptly.
Senior manager training: Reinforce personal accountability for firm compliance; update governance frameworks.
Appeal monitoring: If similarly positioned, prepare for potential appeals to Conseil d’État.

Key Dates

10 December 2025 DEADLINE

- AMF Enforcement Committee decision date imposing fines; appeals possible (no specific deadline stated, but typically within 2 months to Conseil d’État)

Compliance Impact

Urgency: High – This decision, part of a 2025 enforcement wave fining asset managers €400k–€1.3m for procedural lapses (e.g., non-operational investment processes, inadequate due diligence), signals intensified AMF scrutiny on operational integrity. Firms risk personal fines for managers and reputational damage; immediate procedure audits are essential to mitigate exposure, especially pre-authorization renewals or fund launches.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Reporting & Disclosure Senior Managers / Governance AML / Financial Crime

Topics:

Asset Manager

🇱🇺 CSSF Guidance high

December 16th 2025

Circular CSSF 22/811 (as amended by Circular CSSF 25/900) (Updated)

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.

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;...
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...
Governance and Controls: Mandates sound governance principles, control frameworks, escalation processes for errors/incidents, adequate resources (human, ICT), business continuity, and compliance with...
Delegation Rules: Delegation of tasks allowed but not of monitoring/oversight; requires written contracts, due diligence, and prior CSSF notification (3 months generally, 1 month for certain agents);...
Contracts and Reporting: Written contracts between UCI administrator and UCI/IFM; annual activity reporting due 5 months after financial year-end, starting from financial years ending post-30 June...

Suggested Considerations

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: Conduct due diligence, execute written contracts detailing roles/obligations, notify CSSF in advance, retain oversight without delegating monitoring.
Conclude written contracts with UCI/IFM; submit annual UCIA activity reports.
UCIs/IFMs: Supervise coordinators, ensure information exchange/cooperation with administrators.

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 operational models, delegations, and reporting immediately for active administrators.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Operational Resilience / Outsourcing

Topics:

Asset ManagerBankAll Firms

Capital Markets & Trading Investment Management

🇺🇸 FINRA regulatory_notice low

December 16th 2025

Election Notice - 12/16/2025

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset Manager

🇬🇧 FCA News

December 15th 2025

FCA announces new members of its Sustainable Finance Advisory Committee

Earlier this year, we undertook a refresh of our Sustainable Finance Advisory Committee. In line with good governance, we planned to refresh the membership on a staggered basis, allowing us to bring in new expertise whilst benefiting from some continuity. Following this process, we are pleased to announce the appointment of two new members to the Committee:Elly Dowding, Director of ESG AccordFarnam Bidgoli, Independent AdviserThese appointments reflect our commitment to drawing on diverse exp...

Sectors:

ESG Authorisation & Licensing Senior Managers / Governance

Topics:

Asset ManagerWealth ManagerAll Firms

Insurance & Pensions Consumer Credit

🇬🇧 FCA Enforcement medium

December 15th 2025

Using our full toolkit to help consumers

With over 20 years’ experience and responsibility for supervising 5,000 firms, I know that when an issue arises, the first question is often: 'What action will you take?'That’s a fair question – enforcement is one of the most visible ways we act. It often grabs headlines with big fines and publicity.But our role as supervisors is to exercise judgement - selecting the right tool to achieve the best and fastest outcomes for consumers and markets.While enforcement is a vital part of the kit, it’...

AI Analysis

This FCA blog post outlines the regulator's supervisory "toolkit" for addressing consumer harm, emphasizing proactive supervision over enforcement to achieve faster outcomes like redress and market-wide improvements. It matters because it signals FCA's preference for swift, non-enforcement interventions (e.g., skilled person reviews, voluntary requirements), urging firms to respond promptly to supervisory feedback to avoid escalation. Compliance teams should view this as a reminder to prioritize Consumer Duty compliance, as supervision tools are increasingly tied to it for rapid harm prevention.

What Changed

No new rules or requirements are introduced; this is a supervisory strategy update highlighting FCA's full range of tools beyond enforcement. Key emphases include:
Prioritizing supervision for quick fixes, such as multi-firm reviews, good/poor practice guidance, and skilled person reviews (s.166) under FSMA.
Integration of Consumer Duty (Principle 12) as a core principle for assessing and remedying poor outcomes, e.g., unclear policy renewals or inadequate support.
Examples from insurance (e.g., stolen vehicle claims yielding £200m redress; home emergency cover improvements reducing complaints by 61%).

Suggested Considerations

Embed proactive monitoring: Regularly review customer outcomes under Consumer Duty, acting on foreseeable harm (e.g., communication barriers, vulnerable customer support).
Respond swiftly to FCA contact: Engage with supervision teams on identified issues; prepare for tools like skilled person reviews or voluntary restrictions.
Improve practices market-wide: Use FCA guidance (e.g., good/poor examples) to self-assess; ensure clear information, fair value, and accessible support.
Evidence compliance: Map business to Consumer Duty, monitor biases, and demonstrate senior manager oversight via SM&CR.
Facilitate redress: Identify and pay compensation promptly when issues arise, as seen in FCA interventions (£200m vehicle claims; £350k home insurance).

Compliance Impact

Urgency: Medium – This reinforces existing obligations under Consumer Duty and Principles, but underscores risk of supervisory escalation if firms ignore early warnings. It matters because FCA prioritizes speed (supervision over enforcement), enabling quick harm fixes but exposing non-responsive firms to s.166 reviews (costly, used 20+ times in insurance since 2022) or restrictions, impacting reputation and finances. Firms with consumer-facing products must audit processes now to align with "good outcomes" expectations.

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Senior Managers / Governance

InsuranceAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News medium

December 12th 2025

The AMF examines the transparency of executive succession plans as part of its 2025 Corporate Governance Report

Governance Annual report Executive & other private individuals Journalists Listed companies and issuers The AMF examines the transparency of executive succession plans as part of its 2025 Corporate Governance Report

Sectors:

Topics:

Reporting & Disclosure Senior Managers / Governance

BankAsset ManagerWealth Manager

Banking & Credit Mortgage & Lending

🇮🇪 CBI Enforcement high

December 12th 2025

Public statement relating to Enforcement Action between Central Bank of Ireland and Philip Smith

Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and disqualified him for 13 years from being a person concerned in the management of a regulated financial service provider for his participation in a breach by RSA Insurance Ireland DAC (...

AI Analysis

The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.

What Changed

This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities.

Suggested Considerations

Conduct internal audits of large loss claim reserving processes to verify compliance with Article 13(1)(a) of the 1994 Regulations, ensuring estimates are accurately recorded in databases without undocumented overrides.
Review senior management oversight of claims handling; document all approvals and prohibit informal (e.g., in-person or hard-copy only) processes that bypass controls.
Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios.
Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines).
Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments.

Key Dates

2014

- CBI enforcement investigation into Mr Smith and RSAII commences

December 2018

Policy statement 26/25

AI Analysis

The Prudential Regulation Authority (PRA) has issued PS26/25, finalizing the withdrawal of Supervisory Statement (SS) 20/15, which previously set prescriptive expectations for building societies' treasury and lending activities, effective immediately upon publication on 5 December 2025. This deregulatory move reduces administrative burdens, enhances proportionality across deposit takers, and promotes competition by aligning building societies more closely with banks, while relying on existing tools like the PRA Rulebook, SMCR, and routine supervision for risk management. It matters for compliance teams as it eliminates specific guidance often misinterpreted as binding requirements, freeing firms to tailor risk frameworks but requiring vigilance on broader prudential expectations.

What Changed

- Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports objectives of safety,...
No new rules imposed: PRA deems existing tools sufficient, including Building Societies Act 1986 restrictions, PRA Rulebook, SMCR, and supervision; derivatives permitted only for risk management...

Suggested Considerations

Review and update policies: Building societies must confirm internal treasury/lending frameworks align with remaining requirements (e.g., PRA Rulebook, Building Societies Act 1986, ICAAP/SREP under amended SS31/15); remove any SS20/15-specific references or processes.
Assess risk management: Evaluate use of derivatives or treasury tools for compliance with non-prescriptive expectations; ensure SMCR accountability and board oversight.
Update governance documents: Revise ICAAP/SREP processes per SS31/15 amendments; document rationale for tailored approaches to demonstrate proportionality.
Engage supervisors: No immediate reporting mandated, but proactive dialogue recommended for firms previously on extensions or complex approaches.
Monitor related reforms: Track Strong and Simple framework (e.g., PS4/26, PS20/25) for SDDT capital/liquidity simplifications referencing this change.

Compliance Impact

Urgency: Medium – Effective immediately (5 December 2025), but deregulatory nature reduces burdens rather than imposing new obligations; critical for year-end 2025/early 2026 planning to avoid legacy SS20/15 misapplication. Matters as it shifts from prescriptive "hard limits" (often treated as rules) to principles-based supervision, enabling flexibility but heightening reliance on firm-specific risk assessments amid PRA's focus on competition and growth; non-compliance risks arise from over-reliance on withdrawn guidance or inadequate tailoring.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance

Bank

Banking & Credit Investment Management Capital Markets & Trading

🇫🇷 AMF News

December 3rd 2025

Rémi Bouchez, the new Ombudsman of the Autorité des Marchés Financiers

Mediation Appointment Institutional Other professionals Executive & other private individuals Retail investors Journalists Investment services providers Investment management companies Listed companies and issuers ...

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Asset ManagerBroker DealerWealth Manager

Banking & Credit Insurance & Pensions

🇬🇧 PRA policy_statement high

December 3rd 2025

PS25/25 – Enhancing banks’ and insurers’ approaches to managing climate-related risks – Update to SS3/19

Policy statement 25/25

AI Analysis

PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.

What Changed

The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a...
Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
Risk management enhancements: Integrate climate risks into existing frameworks/risk registers (supplementary sub-registers allowed); 'accept, manage, avoid' is suggestive, not mandatory; aligns with...
Climate scenario analysis (CSA) advancements: Firms must use CSA strategically for decisions; flexibility on number/type of scenarios, reverse stress/sensitivity analysis, and longer horizons...

Suggested Considerations

Conduct gap analysis against SS5/25 within 6 months and remediate (e.g., update governance, risk frameworks, CSA processes).
Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting.
Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures.
Document proportionate application (two-step process: materiality assessment, risk response); leverage existing structures where robust.
Ensure senior accountability and alignment with standards like SS1/21.

Key Dates

3 December 2025

- PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19

Within 6 months (by ~June 2026)

- Firms assess gaps against new expectations and develop remediation plans (industry guidance)

Ongoing

- Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence

Compliance Impact

Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid maturing climate risk landscape.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements ESG Senior Managers / Governance

BankInsurance

🇬🇧 PRA Guidance high

December 3rd 2025

SS5/25 – Enhancing banks’ and insurers’ approaches to managing climate-related risks

Supervisory statement 5/25

AI Analysis

SS5/25 is the PRA's updated supervisory statement, published on 3 December 2025, replacing SS3/19 and setting enhanced expectations for banks and insurers to manage climate-related risks through governance, risk management, scenario analysis, data quality, and disclosures. It matters because it represents a step change from awareness-raising to embedding robust, proportionate practices that integrate climate risks into core prudential processes like ICAAP, ILAAP, ORSA, and capital planning, aligning with the PRA's objectives for firm safety and soundness amid evolving physical and transition risks.

What Changed

- Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit,...
Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without...
Risk management integration: Requires embedding climate risks into existing frameworks with quantitative metrics/limits where material; detailed mapping of risks (e.g., physical/transition via...
Scenario analysis: Firms must conduct climate scenario exercises capturing plausible pathways, impacts on capital/liquidity/solvency, with transparent assumptions and management challenge;...
Data expectations: Critical assessment of data sources/quality (e.g., geographic/sectoral for banks, hazard/vulnerability for insurers); use proxies with documented limitations.

Suggested Considerations

Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work).
Embed climate risks in governance: Define risk appetite, update SM&CR responsibilities, ensure board MI/challenge.
Integrate into risk frameworks: Update risk registers, ICAAP/ILAAP/ORSA/SCR with quantitative metrics, scenarios, and controls; adjust underwriting/pricing/collateral.
Perform climate scenario analysis: Model impacts on capital/liquidity/solvency using plausible pathways.
Enhance data: Source/assess granular data (e.g., location/sector/hazards), document proxies/limitations.

Key Dates

AI Analysis

The Prudential Regulation Authority (PRA) held roundtable sessions on 20 and 22 October 2025 with 21 regulated firms to discuss AI and machine learning (AI/ML) adoption under Supervisory Statement SS1/23 on model risk management (MRM) principles for banks. This matters because it highlights PRA's strategic supervisory focus on AI/ML model risks, urging firms to enhance governance, risk appetite, monitoring, and validation to mitigate opacity, overfitting, and rapid performance degradation in these models. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai | https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/publication/2025/november/ai-roundtable-oct-2025.pdf

What Changed

This is not a formal rule change but supervisory guidance via roundtable insights reinforcing SS1/23 principles (effective since 2023). Key emphases include:
Risk appetite: Boards must articulate AI/ML-specific model risk appetite pre-deployment to avoid exceeding tolerances, given higher uncertainty from opacity.
Model inventories and tiering: Address inaccurate/incomplete inventories and aggregate risks from deploying similar AI/ML across portfolios/jurisdictions; challenge tiering for complexity.
Model development: Assess trade-offs in performance vs. explainability/reliability; prefer simpler models where AI/ML gains are marginal; mitigate overfitting via representative datasets.
Ongoing monitoring: Increase frequency beyond tier-dependent intervals (e.g., six months may suffice for traditional models but not dynamic AI/ML); define quantitative triggers for re-validation.

Suggested Considerations

Review and strengthen board-level model risk appetite statements to explicitly cover AI/ML opacity and uncertainty; integrate into governance triggers like re-validation.
Enhance model inventories for completeness, aggregate risk assessment, and cross-jurisdictional tiering challenges.
Update model development policies to evaluate AI/ML trade-offs (e.g., explainability vs. performance) and ensure datasets prevent overfitting.
Revise ongoing monitoring policies for more frequent, quantitative checks on AI/ML (e.g., beyond six months); define degradation triggers, fallback models, and kill switches.
Participate in PRA initiatives like MRM roundtables or AI Consortium for dialogue; align first/second-line defenses per SS1/23.

Key Dates

24 November 2025

- PRA published roundtable summary and slides. https://www.bankofengland.co.uk/prudential-regulation/publication/2025/november/pra-holds-model-risk-management-roundtable-on-ai

22 October 2025; - PRA held CRO roundtable sessions with 21 firms on AI/ML MRM

Compliance Impact

Urgency: Medium - Not critical as no new rules or deadlines, but high relevance for AI/ML users amid PRA's strategic MRM focus; non-compliance risks supervisory actions, given observations of gaps in monitoring and governance. Matters for banks scaling AI (rising adoption per industry views), as unaddressed risks like rapid degradation could amplify losses (e.g., historical model failures cost billions). https://www.articsledge.com/post/model-risk-management | https://www.finextra.com/blogposting/30372/the-pras-latest-view-on-ai-governance-implications-for-uk-banks

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Prudential / Capital Requirements Technology & Cyber Senior Managers / Governance

Topics:

BankAll Firms

🇬🇧 PRA Consultation high

November 21st 2025

CP23/25 – Regulatory fees and levies: policy proposals for 2026/27 – Joint PRA and FCA consultation

Consultation paper 23/25

AI Analysis

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 £2,200 annual fee, variable above £500,000 threshold); extension of fee-block A.13...
Levy adjustments: Addition of targeted support to FSCS Class 2, Category 2.1 (life distribution/investment intermediation) for both FOS and FSCS levies based on annual eligible income; withdrawal of...
PRA-FCA joint proposals (Chapter 4): Amended invoice due dates for firms paying £50,000+ in annual FCA/PRA fees ("payments on account") to prevent overdue labels from procedural mismatches.
Other updates: Removal of £3 agent registration fee for payment institutions, RAISPs, and EMIs; policy tweaks like expanding skilled person reviews for motor finance to more lenders, pro-rating for...

Suggested Considerations

Review current fee/levy exposure and model impacts of new blocks (e.g., PISCES, targeted support, DPC) and withdrawn FOS changes.
Assess invoice processes if paying £50,000+ in FCA/PRA fees; prepare for aligned due dates.
Submit consultation responses by deadlines, focusing on targeted support by 9 January 2026.
Budget for potential fee increases; monitor Spring 2026 fee-rates CP.
For applicants: Factor in new Category 4 fees for A.13 or crypto/DPC registrations.

Key Dates

9 January 2026 DEADLINE

- Deadline for comments on targeted support proposals (FCA CP25/33 paras 2.11-2.18, questions 3-7)

16 January 2026

The Securities and Exchange Commission today announced that Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), will conclude her tenure with the agency effective Dec. 1, 2025. “I thank Antonia for her steadfast leadership in…

AI Analysis

This SEC press release announces the departure of Antonia M. Apps, Deputy Director of the Division of Enforcement (Northeast), effective December 1, 2025. It signals ongoing leadership transitions within the restructured Enforcement Division under new SEC Chair Paul Atkins, which may influence enforcement priorities, transparency, and regional consistency, requiring firms to adapt compliance strategies amid a "return to basics" approach focused on core investor protection.

What Changed

This announcement itself introduces no new regulatory changes or requirements; it is a personnel update. However, it occurs amid broader Enforcement Division restructuring, including:
Consolidation from one Deputy Director to four (three regional: Northeast, Southeast, West; one for specialized units), reducing reporting lines for a more unified nationwide enforcement program.
Rescission in March 2025 of delegated authority for the Enforcement Director to issue formal orders of investigation, now requiring direct Commission authorization to align with priorities.
Emphasis on transparency, such as sharing legal theories and evidence with defense counsel during Wells processes, rewarding cooperation, self-reporting, and remediation, while avoiding novel legal...

Suggested Considerations

Review ongoing Northeast Regional Office investigations for potential leadership changes and engage early with new deputies on cooperation opportunities.
Enhance internal self-reporting and remediation protocols to align with Enforcement's stated rewards for cooperation and robust Wells processes.
Update compliance training on restructured reporting lines and Commission-authorized formal orders, ensuring defenses stick to established securities laws rather than novel theories.
Monitor SEC staff directory for replacement announcements, such as potential roles for Samuel Waldon or others in the Northeast.

Key Dates

March 2025

- SEC rescinded delegation of formal order authority to Enforcement Director

April 2025

- Nekia Hackworth Jones appointed Deputy Director (Southeast)

September 2, 2025

- Margaret A. Ryan appointed Director of Enforcement

November 13, 2025

- SEC announced Apps' departure

December 1, 2025

- Antonia M. Apps concludes her tenure as Deputy Director of Enforcement (Northeast).

Compliance Impact

Urgency: Low - This is a routine personnel change with no immediate regulatory shifts or deadlines post-December 1, 2025. It matters indirectly as part of 2025's Enforcement Division overhaul (15% headcount reduction, regional consolidation), likely leading to prioritized, transparent enforcement on retail harm and core violations rather than expansive theories—firms should prepare for efficiency-driven probes but face no urgent overhauls.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance

Topics:

Broker DealerAsset ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE News low

November 13th 2025

Megan Greene reappointed as external member of the Monetary Policy Committee

Megan Greene has been reappointed as an external member of the Monetary Policy Committee by the Chancellor of the Exchequer, Rachel Reeves

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇪🇺 ECB News

November 12th 2025

Written overview for the exchange of views of the Chair of the Supervisory Board of the ECB with the Eurogroup on 12 Nocember 2025

No description available.

Sectors:

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

BankAsset ManagerWealth Manager

🇫🇷 AMF Enforcement high

November 12th 2025

The AMF Enforcement Committee fines a financial investment advisor and its two directors a total of €2.5 million

Sanctions & settlements Anti-money Laundering Governance Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its two directors a total of €2.5...

AI Analysis

The AMF Enforcement Committee fined financial investment advisor Carat GP €300,000 and its directors Jimmy Guinet (€200,000) and Sébastien Renaud (€2 million) a total of €2.5 million on 5 November 2025, imposing permanent bans on Carat GP and Renaud, and a 10-year ban on Guinet, for breaches including inadequate documentation, failure to act honestly and professionally in clients' interests, AML failures, lack of conflict detection systems, and insufficient cooperation with inspectors. This decision marks the first time the Committee held directors personally liable for breaches, signaling heightened personal accountability for senior managers in French investment firms. It matters as it reinforces AMF's focus on governance, AML, and client protection, with severe sanctions serving as a deterrent amid rising enforcement trends.

What Changed

This is an enforcement action, not a regulatory change, but it clarifies and strengthens application of existing AMF rules for conseillers en investissements financiers (CIFs) under French...
Mandatory compliant documentation (e.g., investment proposals).
Obligation to act honestly, fairly, and professionally in clients' best interests, including systems to prevent managers exploiting positions for undocumented investments.
AML/CFT compliance, including prohibitions on directors receiving client funds in personal accounts.
Annual training for directors and diligent cooperation with AMF inspections.

Suggested Considerations

Audit documentation: Ensure all investment advice is fully documented and compliant; implement traceability for proposals.
Strengthen governance: Deploy systems to detect/prevent conflicts, especially manager-led undocumented investments; enforce annual director training.
Enhance AML/CFT: Prohibit personal receipt of client funds; conduct KYC and transaction monitoring.
Improve inspection readiness: Train staff for diligent, honest cooperation with AMF; maintain secure archives.
Senior manager reviews: Assess personal compliance liabilities; update senior managers regime policies.

Key Dates

1 January 2019 to 30 June 2024

- Relevant period of breaches for Carat GP

5 November 2025

- AMF Enforcement Committee decision issued, imposing fines and bans

6 November 2025

- French version of press release published

Compliance Impact

Urgency: High - Recent (November 2025) decision with record €2.5m fines and novel personal director liability elevates risks for CIFs and managers, amid AMF's pattern of escalating sanctions on governance/AML failures (e.g., similar cases in 2019-2025). Firms must act promptly to avoid parallel enforcement, as breaches spanned years and AMF emphasizes educational deterrence through decisions.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Topics:

Wealth ManagerAsset ManagerAll Firms

🇱🇺 CSSF Guidance medium

November 3rd 2025

Circular CSSF 07/325 (as amended by Circulars CSSF 21/765, CSSF 22/827 and CSSF 25/898) (Updated)

Provisions relating to credit institutions and investment firms of EU origin established in Luxembourg by way of branches or exercising activities in Luxembourg by way of free provision of services

AI Analysis

Circular CSSF 07/325, as amended by Circulars CSSF 21/765, CSSF 22/827, and most recently CSSF 25/898, establishes supervisory requirements for EU credit institutions and investment firms operating in Luxembourg via branches or free provision of services (FOPS). It matters for compliance professionals as it defines CSSF's host authority role, notification obligations, reporting, and enforcement powers, ensuring alignment with CRD and MiFID II while adapting to evolving EU rules.

What Changed

- CSSF 21/765: Updated provisions following amendments to CSSF Regulation No 12-02, refining notification and operational requirements for branches and FOPS.
CSSF 22/827: Further amendments to align with CRD and MiFID II changes, including enhanced notifications for programme alterations (e.g., one-month prior written notice for changes in operations,...
CSSF 25/898: Latest update (noted in CSSF Newsletter No 298, November 2025), incorporating recent legal/regulatory developments, such as refined reporting via eDesk portal, AML/CFT compliance...

Suggested Considerations

Notifications: Submit initial branch/FOPS notification to home authority (including operational programme); notify changes (e.g., services, locations) at least one month in advance to both home authority and CSSF.
Reporting: Complete and sign SAQ (accurate, concise, true/fair view) via eDesk within six months post-year-end; provide REA-appraised AML/CFT and conduct reports, detailing branch procedures/controls.
Supervision cooperation: Facilitate home/CSSF on-site inspections (with professional secrecy guarantees); ensure branch compliance with Luxembourg laws (e.g., LFS Article 46(2)).
Ongoing: Maintain branch infrastructure, update for legal changes, and align with CSSF user guides for eDesk authentication.

Key Dates

One month before change effective date

- Notify CSSF and home authority in writing of programme changes (e.g., operations, services, additional places of business) per CRD Article 36(3) and MiFID II Article 35(10)

Within 3 months of receipt

- Home state authority communicates notification file to CSSF for branch/FOPS establishment

Six months after financial year

end; - Submit electronically signed SAQ (via eDesk), annual AML/CFT and conduct of business report (per Circular CSSF 19/731, to be repealed by CSSF 25/902), reviewed by REA

Compliance Impact

Urgency: Medium - Matters due to recurring annual reporting (e.g., SAQ, AML/CFT within six months post-year-end) and prior notifications for changes, with CSSF enforcement powers (e.g., measures under LFS Article 46(2)) for non-compliance. Recent CSSF 25/898 update (Nov 2025) requires immediate review of processes for digital submissions, but no retroactive changes or hard deadlines post-2025; grandfathering for pre-existing setups reduces immediate pressure.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Topics:

BankBroker Dealer

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE News

October 31st 2025

Minutes of the Meeting of the Court of Directors held on 19 September 2025

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankAsset ManagerWealth Manager

🇸🇬 MAS Guidance high

October 30th 2025

ID 14/25 and FAS 16/2025 Amendments to MAS Notice 211 and MAS Notice 502

Notification of Amendments to Annex 1 of MAS Notice 211 on Minimum and Best Practice Training and Competency Standards for Direct General Insurers and Appendix 1 of MAS Notice 502 on Minimum and Best Practice Training and Competency Standards for Direct General Insurers.

AI Analysis

This MAS circular (ID 14/25 and FAS 16/2025, published 30 October 2025) notifies amendments to Annex 1 of MAS Notice 211 and Appendix 1 of MAS Notice 502, focusing on minimum and best practice **training and competency standards** for direct general insurers and insurance brokers. It matters because these updates strengthen regulatory expectations for staff qualifications in the general insurance sector, ensuring higher professional standards amid evolving risks like AML/CFT, with direct implications for licensing compliance and operational resilience.

What Changed

The amendments target Annex 1 of MAS Notice 211 (applicable to direct general insurers) and Appendix 1 of MAS Notice 502 (applicable to insurance brokers), both addressing Minimum and Best Practice Training and Competency Standards. Specific changes are not detailed in the notification summary but likely include clarifications on applicability, "fit and proper" criteria for staff, and enhanced continuing professional development (CPD) requirements, as referenced in related Notice 211 updates.

Suggested Considerations

Download and review the full amendment document (ID 14/25 and FAS 16/2025) from https://www.mas.gov.sg/regulation/circulars/id14_25.
Assess current training and competency programs against updated Annex 1 (MAS Notice 211) and Appendix 1 (MAS Notice 502), focusing on minimum standards and best practices for staff.
Update internal policies, CPD requirements, and staff certification processes to incorporate changes, including any new "fit and proper" clarifications.
Conduct gap analysis for affected representatives and implement training by any specified effective date; maintain records for MAS audits.
For brokers and composite insurers, ensure alignment across general and life business lines if overlapping.

Key Dates

30 October 2025

- Publication date of ID 14/25 and FAS 16/2025 circular notifying amendments

Compliance Impact

Urgency: High – These amendments directly impact core licensing and operational requirements for general insurers and brokers, with non-compliance risking supervisory actions, fines, or authorization issues under the Insurance Act. Given the 30 October 2025 publication and MAS's pattern in recent AML/CFT updates (effective shortly after notification, e.g., 1 July 2025), firms face tight timelines for updates, especially as training gaps could amplify vulnerabilities in high-risk areas like customer due diligence.

References

AI-generated analysis. May contain errors or omissions — verify with the original MAS source before acting. Full disclaimer.

Sectors:

Senior Managers / Governance Authorisation & Licensing

Topics:

InsuranceBroker Dealer

🇬🇧 PRA Guidance high

October 28th 2025

SS31/15 - The Internal Capital Adequacy Assessment Process (ICAAP) and the Supervisory Review and Evaluation Process (SREP)

Supervisory statement 31/15

AI Analysis

SS31/15 is the PRA's foundational supervisory statement establishing expectations for how UK-regulated banks and large investment firms must conduct their Internal Capital Adequacy Assessment Process (ICAAP) and how the PRA will evaluate these assessments through its Supervisory Review and Evaluation Process (SREP). This guidance is critical because it directly determines the capital requirements firms must maintain and establishes the supervisory framework through which the PRA assesses whether firms hold sufficient capital to cover material risks.

What Changed

The supervisory statement establishes several core regulatory expectations: ICAAP Requirements
Firms must assess on an ongoing basis whether they hold sufficient capital to cover all material risks, including interest rate risk in the banking book (IRRBB), market risk, operational risk,...
Firms must implement stress testing and scenario analysis as integral components of capital planning
The management body must be actively involved and engaged in all relevant stages of the ICAAP process SREP Assessment Framework The PRA reviews and evaluates:
Arrangements, strategies, processes and mechanisms implemented by a firm to comply with regulatory requirements

Suggested Considerations

*Immediate Compliance Actions
*Establish ICAAP Framework: Implement a comprehensive ICAAP that covers all material risks identified by the firm and the PRA, including those specific to the firm's business model and risk profile
*Risk Identification and Assessment: Conduct thorough identification of all material risks (IRRBB, market risk, operational risk, concentration risk, group risk, pension obligations, foreign currency lending) and assess capital adequacy against these risks
*Stress Testing and Scenario Analysis: Develop and maintain robust stress testing and scenario analysis capabilities, including:
Results of stress tests carried out in accordance with CRR requirements for firms using IRB approaches or internal models

Key Dates

29 July 2015

- SS31/15 first published, replacing PRA SS5/13 and PRA SS6/13

1 July 2026

- Effective date for updates to SS31/15 (as referenced in recent amendments)

Ongoing DEADLINE

- Firms must carry out ICAAP on a continuous basis in accordance with PRA ICAA rules

Compliance Impact

Urgency Rating: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Prudential / Capital Requirements Senior Managers / Governance Reporting & Disclosure

Topics:

BankBroker Dealer

🇫🇷 AMF News medium

October 15th 2025

The Autorité des Marchés Financiers publishes the findings of its thematic inspections on governance and role of senior managers at asset management companies

Supervision Asset management Governance Journalists Investment management companies The Autorité des Marchés Financiers publishes the findings of its thematic inspections on governance and role of senior managers at asset management companies

Sectors:

Senior Managers / Governance Authorisation & Licensing

Topics:

Asset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE News medium

October 15th 2025

PRA and FCA announce changes to banker bonuses for 2025

The PRA and FCA have today confirmed plans to increase flexibility around senior banker pay, alongside changes to create better links between bonus awards and responsible risk-taking.

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance Consumer Protection / Conduct

BankWealth Manager

Banking & Credit Capital Markets & Trading Investment Management

🇬🇧 PRA policy_statement high

October 15th 2025

PS21/25 – Remuneration Reform

Policy statement 21/25

AI Analysis

PS21/25 implements reforms to PRA remuneration rules for banks, building societies, and PRA-designated investment firms, simplifying Material Risk Taker (MRT) identification, aligning deferral periods with international standards (4 years for non-SMF MRTs and 5 years for SMFs), and enhancing links to individual accountability under the Senior Managers Regime (SMR). These changes matter as they reduce regulatory burden, increase flexibility in bonus structures (e.g., marginal deferral rates and cash payments), and promote competitiveness while maintaining risk alignment, potentially reversing trends toward higher fixed pay.

What Changed

- MRT Identification: Simplified quantitative threshold to the top 0.3% of earners (assessed against risk impact); qualitative criteria unchanged; raised proportionality threshold for disapplying...
Deferral Periods: 4-year minimum for non-SMF MRTs (previously varied); reduced to 5 years for SMFs (from 7 years); aligns with FCA and international practice.
Deferral Rates: Marginal system—40% deferral on first £660,000 of variable remuneration, 60% above; replaces cliff-edge approach for proportionality.
Upfront Cash Flexibility: Removed equal cash/instrument split requirement (Remuneration 15.16 deleted); deferred portion should have higher instrument share as good practice (new SS2/17 para 5.44B);...
Individual Accountability: New rules/expectations for adjusting remuneration up the management chain for adverse outcomes; senior management accountable against PRA priorities; Remuneration...

Suggested Considerations

Review and update MRT identification processes, applying simplified top 0.3% threshold and new proportionality exemptions.
Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations.
Embed SMR-linked adjustments: Define criteria for chain-wide pay reductions on adverse outcomes; align Remuneration Committee oversight with PRA priorities and risk events.
For dual-regulated firms: Transition to PRA-cross-referenced FCA rules (SYSC 19D).
Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies.

Key Dates

November 2024

Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS

15 October 2025

Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion

16 October 2025

Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms)

Compliance Impact

Urgency: High – Mandatory from performance years post-16 October 2025 (e.g., 2026 for most), with immediate opt-in possible; impacts 2026 bonus cycles, requiring swift policy rewrites amid year-end planning. Matters due to simplified but ownership-heavy MRT processes, SMR-pay linkages raising accountability risks, and flexibility needing robust justification to avoid supervisory challenge; non-compliance risks enforcement under PRA accountability regimes.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Prudential / Capital Requirements Reporting & Disclosure

BankAsset ManagerAll Firms

Banking & Credit Capital Markets & Trading Investment Management

🇬🇧 PRA policy_statement high

October 9th 2025

PS16/25 – Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg)

Policy statement 16/25

AI Analysis

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...
Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving...
Technical standards update: Minor amendment to algorithmic trading technical standards, replacing references to revoked MiFID Org Reg Article 23(2) with new PRA Rulebook rule 2.2D.
No policy or scope changes; adjustments mainly reflect PRA drafting style and respond to feedback for clarity.

Suggested Considerations

Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e.g., update policies on outsourcing, risk management, governance).
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 2.2D.
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 updates to avoid supervisory scrutiny, especially for governance and outsourcing.

References

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Sectors:

Topics:

Operational Resilience / Outsourcing Senior Managers / Governance Reporting & Disclosure

BankBroker DealerAll Firms

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

October 1st 2025

Election Notice - 1/10/2025

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Broker DealerAsset ManagerAll Firms

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 SEC News low

September 24th 2025

SEC Announces Departure of Chief Operating Officer Ken Johnson

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…

Sectors:

Topics:

Reporting & Disclosure Senior Managers / Governance Operational Resilience / Outsourcing

BankAsset ManagerBroker Dealer

🇫🇷 AMF Enforcement high

September 23rd 2025

The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million

Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million

AI Analysis

The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) a total of €1.3 million on 15 September 2025 for breaches of professional obligations, including non-operational investment procedures, inadequate AML/CFT due diligence, deficient marketing materials, and unproven benefits from fee retrocessions to distributors. This decision underscores the AMF's heightened scrutiny on operational controls and senior accountability in asset management, serving as a critical enforcement signal for firms to strengthen procedures amid a pattern of similar sanctions.

What Changed

This is an enforcement action rather than new legislation, but it reinforces and clarifies existing professional obligations under AMF regulations for asset managers (sociétés de gestion),...
Operational investment/divestment procedures: Must be fully implemented, with traceability of checks on lender authorizations and compliance with fund policies.
AML/CFT due diligence: Systematic verification required on fund assets and liabilities; non-operational procedures or risk mapping constitute breaches.
Marketing and fee retrocessions: Materials must be accurate; firms must prove retrocessions enhance client service quality.
Senior manager accountability: Breaches attributable to responsible managers, emphasizing personal liability for oversight failures. No explicit regulatory changes, but the decision aligns with AMF's...

Suggested Considerations

Audit procedures immediately: Review and document operational status of investment/divestment processes, ensuring traceability of lender checks, fund policy compliance, and AML/CFT due diligence on assets/liabilities.
Enhance AML/CFT systems: Formalize risk mapping, procedures, and systematic investor/transaction due diligence; test for operational effectiveness.
Validate marketing and fees: Audit fund materials for accuracy; gather evidence that fee retrocessions to distributors improve client services (e.g., via service level agreements or performance metrics).
Senior manager training: Conduct gap analysis on personal accountability; update governance frameworks to mitigate attribution of firm breaches.
Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on procedure formalization, independent valuers (if applicable), and conflict systems.

Key Dates

15 September 2025

- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners, Maurice Tchenio, and Patrick de Giovanni

16 September 2025

- French version of press release published

Post

15 September 2025 (exact date unspecified); - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09

Compliance Impact

Urgency: High – This fits a 2025 enforcement trend targeting asset managers' operational deficiencies (e.g., similar fines against Novaxia Investissement on 10 December 2025, M Capital Partners on 31 December 2025, and Eternam on 9 September 2025), signaling AMF's zero-tolerance for non-operational controls and AML gaps amid EU AIFMD reviews. Non-compliance risks personal fines up to €500,000+ for managers, reputational damage, and authorization challenges; proactive remediation is essential as appeals (like this one) do not suspend obligations.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Reporting & Disclosure

Topics:

Asset Manager

🇫🇷 AMF Enforcement high

September 16th 2025

The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations

Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined an asset management company €400,000 on 9 September 2025 for multiple breaches of professional obligations, including deficient marketing disclosures, inadequate conflict of interest systems, non-operational valuation procedures, failure to oversee external experts, and deficient AML/CFT systems in managing AIFs and club deals. This enforcement action underscores the AMF's focus on operational robustness and investor protection in asset management, serving as a critical reminder for firms to ensure procedures are not only documented but fully operational and effective. Compliance teams should review this to benchmark internal controls, as it highlights personal accountability for senior managers and recurring AMF priorities in recent sanctions.

What Changed

This is an enforcement decision, not a regulatory change introducing new rules; it enforces existing professional obligations under AMF jurisdiction for asset managers.
Providing comprehensive, accurate, and understandable information to investors on fee retrocessions to distributors in AIF marketing.
Implementing effective systems for preventing and managing conflicts of interest, particularly in joint investments like club deals classified as Other AIFs.
Maintaining operational procedures for valuing real estate assets, including formalizing independent valuer work.
Adhering to programs of activity for selecting, evaluating, overseeing, and periodically assessing external experts.

Suggested Considerations

Conduct immediate gap analysis of investment procedures, marketing materials, conflict of interest policies, valuation processes, external expert oversight, and AML/CFT systems to ensure they are operational, documented, and traceable.
Verify investor disclosures on fee retrocessions are comprehensive and understandable; update marketing materials for AIFs and club deals accordingly.
Formalize independent valuer roles and implement monitoring for external experts per activity programs.
Enhance AML/CFT due diligence on fund assets/liabilities, including risk mapping and procedure testing.
Senior managers: Document personal oversight of compliance; train on attribution of breaches.

Key Dates

Broker DealerCrypto Exchange

🇱🇺 CSSF Enforcement high

August 18th 2025

Circular CSSF 25/896

Adoption of the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures (sanctions)

AI Analysis

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 body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and...
Screening and monitoring requirements: Maintain updated sanctions lists with immediate integration of changes; screen customer base, transactions, and datasets accurately; enable immediate...
Training and testing: Deliver regular, documented role-specific training; perform ongoing system testing for screening calibration, list accuracy, transaction monitoring effectiveness, and reporting.
Proportionality applies based on institution's size, activities, and exposure; PSPs and CASPs explicitly addressed with tailored controls.

Suggested Considerations

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.g., immediate freezing, accurate hits).
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.

July 15th 2025

FINMA Executive Board: Thomas Hirschi to leave FINMA

Thomas Hirschi has decided to leave the Swiss Financial Market Supervisory Authority FINMA effective 31 August 2025. The Head of the Banks division will pursue a new career outside FINMA. FINMA’s Board of Directors and Executive Board thank Thomas Hirschi for his valuable contribution during his time at FINMA.

Effective Date: 31 August 2025

Sectors:

Authorisation & Licensing Senior Managers / Governance

Topics:

Bank

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE Speech

July 4th 2025

The end of the road − speech by Alan Taylor

Given at the London School of Economics and Political Science

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankWealth ManagerAsset Manager

Authorisation & Licensing Senior Managers / Governance

🇫🇷 AMF News medium

July 3rd 2025

Implementation of MiCA: The AMF applies ESMA and EBA Guidelines on the assessment of the suitability of members of the management body

MiCA Crypto-assets Innovation Implementation of MiCA: The AMF applies ESMA and EBA Guidelines on the assessment of the suitability of members of the management body

Sectors:

Crypto & Digital Assets

Topics:

Crypto ExchangeFintech

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News low

June 25th 2025

Rene W. Keller resigns from FINMA’s Board of Directors

At its meeting on 25 June 2025, the Federal Council was informed of the resignation of Rene W. Keller from the Board of Directors of the Swiss Financial Market Supervisory Authority FINMA.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance

BankWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE Speech

June 24th 2025

Revisiting the Norman Conquest of $4.86. Thoughts for the world today - speech by Andrew Bailey

Given at Britain’s Return to the Gold Standard in 1925 Revisited, Bank of England

Sectors:

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

BankWealth ManagerAll Firms

🇫🇷 AMF News medium

June 19th 2025

The AMF publishes the findings of its inspections on the verification and assessment of employee knowledge within asset management companies

Supervision Professional certification Asset management Journalists Investment management companies The AMF publishes the findings of its inspections on the verification and assessment of employee knowledge within asset management companies

Sectors:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Topics:

Asset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News medium

May 14th 2025

Women on Boards Directive: the AMF is now the competent authority for analysing and monitoring gender balance among the directors of listed companies

Governance Journalists Listed companies and issuers Women on Boards Directive: the AMF is now the competent authority for analysing and monitoring gender balance among the directors of listed companies

Sectors:

Topics:

ESG Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBank

Investment Management Banking & Credit Capital Markets & Trading

🇫🇷 AMF Consultation high

March 18th 2025

AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards

Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards

AI Analysis

The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.

What Changed

The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control...
Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms (operating in ≥6 Member States, meeting...
CDD Updates: Risk-based approach for new customers from July 2027; five-year transition for existing customers, prioritizing high-risk.
Pecuniary Sanctions RTS (Article 53(10) AMLD6): Structured classification of breaches, proportionate sanctions, and enforcement for serious/repeated/systematic infringements to ensure uniformity...

Suggested Considerations

Participate in EBA consultation: Submit feedback on draft RTS via EBA channels, focusing on risk indicators, data frequency, and feasibility; AMF encourages French firms to act promptly.
Conduct compliance gap analysis: Review current AML frameworks against proposed indicators (inherent risk, controls, residual risk); prioritize high-risk customers/products.
Enhance systems: Invest in regtech for automated risk scoring, transaction monitoring, and data reporting to supervisors; update governance, policies, and CDD processes.
Prepare for AMLA supervision: For cross-border firms, model group-wide risk profiles; develop remediation plans for breaches.
Ongoing monitoring: Implement annual risk reviews and ad-hoc reassessments for business changes.

Key Dates

March 6, 2025

EBA consultation launch; on draft RTS for AML/CFT standards (ongoing as of analysis)

January 1, 2026

EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA; ; existing EBA guidelines remain until replaced

July 10, 2027 DEADLINE

New AMLD6/AMLR rules apply directly; , including CDD for new customers and start of phased compliance

2028

AMLA begins direct supervision; of selected high-risk entities

By July 2032 DEADLINE

Full CDD compliance; for existing customers (five-year transition from 2027)

Compliance Impact

Urgency: High – While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA scrutiny for large firms. Matters due to shift to uniform EU standards, ending national discretion and increasing reporting burdens—firms acting now can influence outcomes and future-proof via tech/governance investments.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Senior Managers / Governance

Asset ManagerBankAll Firms

🇫🇷 AMF Enforcement medium

January 23rd 2025

The AMF Enforcement Committee fines Pharnext and its former directors a total of €800,000

Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines Pharnext and its former directors a total of €800,000

AI Analysis

The AMF Enforcement Committee fined Pharnext €500,000 and its former directors Daniel Cohen (€200,000) and David Horn Solomon (€100,000) on 20 January 2025 for failing to disclose inside information promptly and disseminating false or misleading information about FDA interactions for a drug candidate. This enforcement action reinforces AMF's strict stance on market abuse rules under EU MAR, highlighting personal liability for directors in listed biotech firms where investor expectations around product approvals are high. Compliance teams should note it as a reminder of timely disclosure obligations, especially amid appeals filed by the parties.

What Changed

This is not a regulatory change but an enforcement decision applying existing obligations under the Market Abuse Regulation (MAR), specifically:
Article 17 MAR: Requirement to disclose inside information as soon as possible (breached by Pharnext's delays from 10 April 2019 and non-disclosure from 28 October 2020).
Article 12(1)(c) MAR: Prohibition on disseminating false or misleading information that could affect market prices, via press releases and shareholder letters overstating FDA progress. No new rules...

Suggested Considerations

Review inside information policies: Ensure protocols flag regulatory feedback (e.g., FDA requests) as inside information and mandate immediate public disclosure via official channels.
Audit communications: Screen press releases, shareholder letters for optimistic language on approvals; implement pre-issuance legal/compliance sign-off.
Director training: Conduct MAR-specific training on personal liability for disclosure failures; document decision trails.
Monitor appeals: Track Paris Court of Appeal outcomes, as upheld fines could set precedents for biotech disclosures.
wide actions mandated beyond general MAR compliance, but proactive gap analysis recommended.

Key Dates

10 April 2019

- FDA request for additional study deemed inside information; not disclosed until 30 August 2019

28 October 2020

- FDA 'non-agreement' on clinical study design deemed inside information; never publicly disclosed

20 January 2025

- AMF Enforcement Committee decision imposing fines (SAN-2025-01)

23 July 2025

- Paris Court of Appeal dismissed David Horn Solomon's stay of execution application (n°25/05331)

Post

20 January 2025; - Appeal lodged by Pharnext, Cohen, and Solomon to Paris Court of Appeal (ongoing)

Compliance Impact

Urgency: Medium – This is a specific enforcement (not a new rule), but it signals heightened AMF scrutiny on biotech disclosures amid investor sensitivity to approval news; delays in similar cases could trigger investigations/fines up to 15% of turnover or €15M. Matters for listed firms with pipeline dependencies, as it exemplifies director accountability and market-wide deterrence post-MAR implementation.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

Topics:

All Firms

🇫🇷 AMF News medium

January 17th 2025

The AMF publishes its action and supervisory priorities for 2025

Strategy Supervision Institutional Executive & other private individuals Journalists Investment services providers Investment management companies Listed companies and issuers The AMF publishes its action and supervisory...

Sectors:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Topics:

Asset ManagerBroker Dealer

Investment Management Wealth & Private Banking Banking & Credit

🇫🇷 AMF Enforcement high

November 8th 2024

The AMF Enforcement Committee fines a financial investment advisor, two asset management companies and their directors, and a credit institution a total of €5,670,000

Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines a financial investment advisor, two asset management companies and their directors, and a credit institution a total of €5,670,000

AI Analysis

The AMF Enforcement Committee imposed total fines of €5,670,000 on a financial investment advisor (FIA), two asset management companies (AMCs), their directors, and a credit institution for breaches of professional obligations. This enforcement action underscores the AMF's rigorous scrutiny of operational controls, due diligence, and governance in investment services, serving as a critical reminder for firms to maintain robust procedures to avoid similar sanctions. It matters because it highlights personal liability for directors and escalating fines for systemic failures, potentially influencing peer reviews and audit priorities.

What Changed

This is an enforcement decision, not a regulatory change introducing new rules. It reinforces existing AMF requirements under professional obligations, including:
Implementation of operational procedures for investment/divestment processes, such as verifying lender authorizations.
Systematic anti-money laundering (AML) and counter-terrorism financing (CTF) due diligence on fund assets and liabilities.
Justification of retrocessions (rebates) to distributors, proving enhanced client service quality.
Honest, fair, and diligent business conduct with requisite skill and care, extending to marketing materials and advisory services. No new requirements; emphasis on enforcement of MiFID II-aligned...

Suggested Considerations

Conduct gap analysis of operational procedures for investments/divestments, ensuring lender authorization checks (reference AMF Position-Recommendation DOC-2020-05 on portfolio management).
Review AML/CTF due diligence frameworks for fund assets/liabilities, aligning with AMF Regulation 2016-01.
Audit retrocession practices to distributors, documenting service quality enhancements (per AMF doctrine on inducements).
Update marketing materials and advisory processes for compliance with honesty/fairness standards.
Enhance senior manager attestations and training on personal liability under CMF L.621-15-1.

Compliance Impact

Urgency: High – This signals intensified AMF enforcement on professional obligations in 2025 (multiple similar fines: €1.3M, €1.89M, €0.5M, €2.5M implied, €0.305M, €3.5M), with personal bans and multimillion fines. Matters due to director accountability trends, potential for follow-on audits, and educational role of Enforcement Committee decisions in clarifying regulations—non-compliance risks reputational damage and capital outflows.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Senior Managers / Governance AML / Financial Crime

Asset ManagerWealth ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇫🇷 AMF News low

September 9th 2024

The Autorité des Marchés Financiers (AMF) signs #JamaisSansElles Charter

Institutional Organisational rules Journalists The Autorité des Marchés Financiers (AMF) signs #JamaisSansElles Charter

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Asset ManagerBroker DealerWealth Manager

🇫🇷 AMF Enforcement high

July 17th 2024

AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations

Sanctions & settlements professional obligations Journalists Investment management companies AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness and personal accountability in asset management, serving as a regulatory warning for firms to strengthen internal controls or face escalating sanctions.

What Changed

This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and fully operational; failure to verify compliance (e.g., loan authorizations) breaches honesty, fairness, and...
Scope of services: Asset managers acting as tied agents cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing permitted investment services.
Conflicts of interest: Systems must effectively identify, prevent, and manage conflicts.
AML/CFT due diligence: Procedures, risk mapping, and due diligence on fund assets/liabilities must be operational and systematic.

Suggested Considerations

Conduct gap analysis: Immediately review investment processes, allocation rules, and traceability against AMF standards; verify authorization of lending entities and service scopes.
Enhance AML/CFT: Update procedures, risk mappings, and due diligence on fund assets/liabilities; ensure operational effectiveness with documented evidence.
Strengthen governance: Implement robust conflicts of interest systems; formalize senior manager oversight with personal accountability training.
Audit marketing/distribution: For tied agents or retrocessions, document service quality enhancements to clients.
Senior manager certification: Directors must attest to compliance in annual reporting; prepare for AMF inspections by maintaining verifiable records.

Key Dates

August 2019

December 2023; - Period of identified breaches (investment services, processes, AML/CFT deficiencies)

31 December 2025

- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors

08 January 2026

- Public press release publication date

Compliance Impact

Urgency: High - This recent (Dec 2025) decision, alongside similar fines (e.g., €1.3M on Altaroc Partners in Sep 2025, €400k on Eternam in Sep 2025), signals AMF's intensified scrutiny on asset manager operations post-AIFMD reviews, with personal fines rising (up to €500k+). Non-compliance risks enforcement, reputational damage, and appeals delays; act within 3-6 months to align before potential audits.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset Manager

Investment Management Wealth & Private Banking Capital Markets & Trading

🇫🇷 AMF Enforcement high

June 24th 2024

AMF Enforcement Committee fines a financial investment advisor and its director for breaches of their professional obligations

Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee has issued multiple enforcement decisions against financial investment advisors and their management for breaches of professional obligations, with the most recent and significant case involving Carat GP and its directors receiving combined fines of €2.5 million and permanent/extended bans from operating as financial investment advisors. These cases establish critical precedent regarding advisor duties around client disclosure, product authorization, conflict of interest management, and honest/fair conduct—requirements that apply across the entire financial investment advisory sector.

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBroker Dealer

Banking & Credit Investment Management Capital Markets & Trading

🇫🇷 AMF News low

May 27th 2024

Marie Seiller appointed Resources, Operations and Transformation Director at the Autorité des Marchés Financiers

Appointment AMF activity Journalists Marie Seiller appointed Resources, Operations and Transformation Director at the Autorité des Marchés Financiers

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Operational Resilience / Outsourcing

Asset ManagerBankBroker Dealer

Investment Management Wealth & Private Banking Capital Markets & Trading

🇫🇷 AMF News

May 17th 2024

France Mayer appointed Retail Investor Relations and Protection Director at the Autorité des Marchés Financiers

Appointment AMF activity Retail investors Journalists France Mayer appointed Retail Investor Relations and Protection Director at the Autorité des Marchés Financiers

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇫🇷 AMF News low

April 8th 2024

The Autorité des Marchés Financiers announces the new composition of the Financial Skills Certification Board

Professional certification AMF activity Journalists The Autorité des Marchés Financiers announces the new composition of the Financial Skills Certification Board

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure Senior Managers / Governance

Asset ManagerBroker DealerBank

Investment Management Capital Markets & Trading Banking & Credit

🇫🇷 AMF Enforcement low

March 20th 2024

Valérie Michel-Amsellem becomes Chair of the AMF Enforcement Committee

Appointment Sanctions & settlements Journalists Valérie Michel-Amsellem becomes Chair of the AMF Enforcement Committee

AI Analysis

This AMF publication announces the appointment of Valérie Michel-Amsellem as the new Chair of the AMF Enforcement Committee, the independent body responsible for imposing sanctions in financial market violations. It matters for compliance professionals because leadership changes in enforcement can signal shifts in sanctioning priorities, rigor, or focus areas, potentially influencing how firms approach risk management and remediation. While no immediate policy changes are introduced, monitoring the new Chair's tenure is essential given the Committee's role in upholding market integrity.

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Market Abuse / Surveillance Authorisation & Licensing

Asset ManagerBroker DealerBank

Investment Management Capital Markets & Trading Banking & Credit

🇫🇷 AMF Enforcement low

February 27th 2024

Appointements to the AMF Enforcement Committee

Appointment Sanctions & settlements Journalists Appointements to the AMF Enforcement Committee

AI Analysis

This AMF publication announces the partial renewal of the Enforcement Committee, including four new appointments, two reappointments, and the subsequent election of Valérie Michel-Amsellem as Chair on 28 February 2024. It matters for compliance professionals as changes in committee composition can influence enforcement priorities, sanction severity, and interpretations of financial regulations under AMF jurisdiction.

What Changed

There are no new regulatory requirements or substantive changes to laws; this is an administrative renewal of the Enforcement Committee's membership. Key developments include: new members Jean-Claude Hassan (Vice-President of the Council of State appointee, also chairs second section), Xavier Samuel (Court of Cassation appointee), Sophie Langlois and Aurélien Soustre (Ministerial appointees); reappointments of Anne Le Lorier and Ute Meyenberg.

Suggested Considerations

Amsellem's prior roles in economic regulation and Court of Cassation) to anticipate enforcement trends; update internal AMF monitoring dashboards with new committee details; assess ongoing investigations or settlements for potential impact from refreshed perspectives.

Key Dates

13 February 2024

- Ministerial order appointing new and reappointed members

20 February 2024

- Publication of the ministerial order

27 February 2024

- Composition published in the Official Journal

28 February 2024

- First meeting; election of Valérie Michel-Amsellem as Chair and Jean-Claude Hassan as second section Chair

Compliance Impact

Urgency: low - This personnel change poses minimal immediate risk but signals potential evolution in enforcement tone under new leadership experienced in sanctions and regulation (e.g., Michel-Amsellem's appellate background). It matters longer-term for firms in protracted AMF proceedings, as committee decisions on sanctions and settlements directly affect penalties and reputational harm.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Market Abuse / Surveillance

Asset ManagerBroker DealerBank

Banking & Credit Investment Management Capital Markets & Trading

🇫🇷 AMF News low

February 13th 2024

Ten new key figures admitted to the Board of the Autorité des Marchés Financiers

AMF activity Appointment Journalists Ten new key figures admitted to the Board of the Autorité des Marchés Financiers

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Consumer Protection / Conduct

Asset ManagerBroker DealerBank

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News low

January 31st 2024

Astrid Milsan will act as Secretary General of the AMF until 15 April 2024

AMF activity Institutional Journalists Astrid Milsan will act as Secretary General of the AMF until 15 April 2024

Deadline: 15 April 2024

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

BankAsset ManagerWealth Manager

Investment Management Wealth & Private Banking Capital Markets & Trading

🇫🇷 AMF Enforcement high

January 16th 2024

AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations

Sanctions & settlements professional obligations Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations

AI Analysis

The AMF Enforcement Committee imposed sanctions on SPI (a financial investment advisor) and its director Vincent Rhodes on 9 January 2024 for breaching professional obligations. This case demonstrates the AMF's enforcement priorities regarding advisor conduct standards and establishes precedent for disciplinary action against both firms and individual managers who fail to meet regulatory requirements.

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Wealth ManagerBroker DealerAsset Manager

🇫🇷 AMF Enforcement high

December 27th 2023

The AMF Enforcement Committee fines a former manager of a listed company for failing to disclose inside information as soon as possible and for failing to disclose major shareholdings

Sanctions & settlements Disclosure Obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines a former manager of a listed company for failing to disclose inside information as soon as possible and for failing to disclose major shareholdings

AI Analysis

The AMF Enforcement Committee imposed a fine on a former manager of a listed company for two violations: failing to disclose inside information to the public as soon as possible under Article 17 of the EU Market Abuse Regulation (MAR), and failing to disclose major shareholdings as required by French regulations. This enforcement action underscores the AMF's strict enforcement of market abuse rules, emphasizing personal accountability for executives in ensuring timely transparency to prevent insider trading risks and maintain market integrity. Compliance teams should review it as a reminder of heightened scrutiny on disclosure delays and threshold crossings.

What Changed

This is not a regulatory change but an enforcement decision reinforcing existing obligations under MAR and AMF General Regulation:
Inside information disclosure: Issuers must publicly disclose inside information "as soon as possible" per Article 17 MAR, unless specific delay conditions are met (legitimate interest,...
Major shareholdings disclosure: Persons crossing legal or statutory thresholds in listed companies must declare to the issuer and AMF promptly, based on Article L.
Supporting rules include Article 315-1 AMF GR mandating "information barriers" (walls) for investment firms to control inside information circulation, prohibiting unauthorized disclosure except under...

Suggested Considerations

Implement/maintain information barriers per Article 315-1 AMF GR: Identify inside info holders, physically separate entities, prohibit unauthorized disclosure (notify compliance officer for exceptions), and log cross-entity assistance.
Assess information promptly: Disclose inside info "as soon as possible" or delay only if all three MAR conditions met; notify AMF post-delay.
Declare major shareholdings immediately upon threshold crossing to issuer/AMF; ensure custodians comply with identity disclosure requests.
Use professional information providers for dissemination to ensure wide, secure EU reach; archive on company website.
Train executives on insider lists, transaction reporting (within 3 days if >€20k/year), and penalties (up to €100m fines, criminal sanctions).

Key Dates

3 trading days DEADLINE

- Managers/PDMRs must report securities transactions to issuer and AMF if annual total exceeds €20,000

10 business days DEADLINE

- Custodians must respond to Euroclear France/AMF requests for shareholder identity on threshold crossings

Compliance Impact

Urgency: High - This matters due to personal fines on managers, signaling AMF's aggressive enforcement of MAR since 2016, with rebuttable presumptions against executives for insider misconduct unless proven otherwise. Firms face reputational risk, investigations, and cascading liabilities (e.g., €10-100m fines, 2-year imprisonment). Review disclosure protocols now to avoid similar sanctions, especially amid ESMA/AMF focus on timely transparency.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

Topics:

All Firms

🇫🇷 AMF Enforcement high

December 22nd 2023

AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations

Sanctions & settlements professional obligations Investment advice Other professionals Journalists AMF Enforcement Committee fines a financial investment advisor and its director for breach of professional obligations

AI Analysis

The AMF Enforcement Committee imposed a five-year ban on financial investment advisor DCT (formerly Didier Maurin Finance) and its director Didier Maurin from practicing, plus fines of €150,000 on the firm and €200,000 on the director, for recommending unauthorized Samoan AIF investments to 64 clients, failing to manage conflicts of interest (e.g., no conflicts register), and breaching duties of competence, care, and diligence in clients' best interests. This matters as it reinforces AMF's strict enforcement on CIFs (Conseillers en Investissements Financiers) for product authorization checks, conflicts management, and client-centric obligations under MiFID II transposition in France, signaling heightened scrutiny on advisory integrity amid rising sanctions. The Conseil d'Etat upheld the decision on 9 September 2024, dismissing appeals and confirming sanctions.

What Changed

This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing requirements for CIFs:
Product marketing authorization: CIFs must verify that recommended investments (e.g., AIFs) are authorized for sale in France before advising clients; recommending unauthorized products breaches...
Conflicts of interest management: CIFs must maintain an effective conflicts register, identify risks (e.g., personal benefits), and implement operational procedures; absence or failure constitutes a...
No aggravating factor for incomplete disclosures on unauthorized products absent specific rules, but core diligence duty remains absolute. These align with AMF Position-Recommendation DOC-2017-15 on...

Suggested Considerations

Immediate audit: Review client portfolios for unauthorized products (e.g., non-EU AIFs); cease recommendations and notify/remediate affected clients.
Conflicts policy enhancement: Implement/maintain a conflicts of interest register; map all potential conflicts (e.g., personal investments, commissions); test procedures annually with scenarios.
Training and documentation: Mandatory staff training on product authorization checks (e.g., via AMF registers); document all advice with diligence evidence; update compliance manuals per AMF DOC-2017-15.
Monitoring: Enhance pre-approval workflows for recommendations; report material breaches to AMF under Article L.621-18 of Monetary and Financial Code.
Director accountability: Senior managers must evidence personal oversight of compliance.

Key Dates

11 April 2022

- AMF Enforcement Committee decision imposing bans and fines

9 September 2024

- Conseil d'Etat judgment (no. 464877) dismissing appeals, upholding sanctions, and ordering €1,500 costs each to AMF

Compliance Impact

Urgency: High - This upheld decision (post-2024 appeal) exemplifies AMF's pattern of escalating fines/bans on CIFs for conduct failures (e.g., €2.5M on Carat GP in 2025; €120K-€150K on Capexis upheld 2025), amid 2024-2025 enforcement wave on professional obligations. Matters for CIFs as it heightens personal liability for directors, risks business bans, and underscores client-best-interest primacy; non-EU product exposure amplifies fines in cross-border contexts.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Topics:

Wealth ManagerAll Firms

🇫🇷 AMF News medium

December 19th 2023

Requirements for investment committees and the affiliation of fund managers of asset management companies: the AMF updates its policy

Asset management Requirements for investment committees and the affiliation of fund managers of asset management companies: the AMF updates its policy

Sectors:

Authorisation & Licensing Senior Managers / Governance

Topics:

Asset Manager

Capital Markets & Trading Wealth & Private Banking Investment Management

🇫🇷 AMF News medium

December 18th 2023

AMF proposes enhanced investor information when evaluating boards of listed companies

Governance Periodic & ongoing disclosures Journalists Listed companies and issuers AMF proposes enhanced investor information when evaluating boards of listed companies

Sectors:

Topics:

Reporting & Disclosure Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBank

🇫🇷 AMF Enforcement high

November 23rd 2023

The AMF Enforcement Committee fines a French tied agent of a Cypriot investment services provider and its manager for breaches of their professional obligations

Sanctions & settlements Journalists The AMF Enforcement Committee fines a French tied agent of a Cypriot investment services provider and its manager for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined France Safe Media (FSM), a French tied agent of Cypriot provider VPR Safe Financial Group Limited (Alvexo platform), €300,000 and imposed a 10-year ban from tied agent activities and reception/transmission of orders (RTO) services, while its manager Lior Mattouk received a €100,000 fine and similar 10-year ban, for breaches occurring January 2019–September 2021. This decision, dated 10 November 2023 and upheld by Conseil d'Etat on 16 June 2025, underscores AMF's strict enforcement of professional obligations for tied agents marketing high-risk CFDs, emphasizing staff qualifications, client assessments, risk warnings, disclosures, and diligence. It matters for cross-border intermediaries as it highlights personal liability for managers and the finality of sanctions post-appeal, signaling heightened scrutiny on CFD promotion and tied agent compliance in France.

What Changed

This is an enforcement action, not a new regulation, but it clarifies and reinforces existing requirements under French rules implementing MiFID II for tied agents:
Staff qualifications: Tied agents must verify sales staff have minimum qualifications and knowledge; post-hoc inadequate tests do not suffice.
Client knowledge/experience assessment: Questionnaires must be robust, with appropriate scoring; account managers cannot interfere (e.g., by prompting answer changes).
Promotional communications: CFD ads must include prominent risk warnings; bans on promoting non-limited-risk CFD accounts must be followed; banners lacking warnings violate rules.
Status disclosure: Clients/potential clients must be informed of tied agent status and principal's identity upon first contact.

Suggested Considerations

Conduct gap analysis: Review staff training/qualification records, client assessment processes (questionnaires, scoring, non-interference controls), promotional materials for risk warnings, and disclosure scripts for tied agent status.
Enhance manager oversight: Implement personal accountability frameworks aligning with senior managers' regimes; document diligence/audit trails.
Audit CFD marketing: Ensure all ads comply with CFD retail restrictions (e.g., limited-risk accounts only); test client knowledge processes for robustness.
Training programs: Roll out mandatory training on MiFID II tied agent rules, with pre-hire testing and ongoing monitoring.
Cross-border review: Non-EU principals (e.g., CySEC-licensed) should audit French tied agents for alignment with host-state rules.

Key Dates

AI Analysis

The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny.

What Changed

This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activities.
Conflicts of interest: Robust identification, prevention, and management systems are mandatory.
AML/CFT: Due diligence on fund assets/liabilities must be systematic and operational, with effective risk mapping and procedures.

Suggested Considerations

Immediate gap analysis: Review investment procedures for precision, traceability, and operationality; verify authorization of lending entities and service scopes (e.g., no unauthorized placement services).
Enhance AML/CFT: Implement operational risk mapping, systematic due diligence on fund assets/liabilities, and evidence of effectiveness.
Conflicts framework: Formalize identification/prevention processes, especially in multi-role firms (asset manager + tied agent).
Senior manager attestation: Document personal oversight; conduct training on attribution of breaches.
Marketing/retrocessions: Ensure traceability and proof of client benefit (cross-reference with similar findings).

Key Dates

August 2019

December 2023; - Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures

31 December 2025

- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors

08 January 2026

- Public press release date

Compliance Impact

Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplifying precedent, and applicability to hybrid models; non-compliance risks fines scaling to €1M+ and reputational damage.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Authorisation & Licensing

Topics:

Asset Manager

🇫🇷 AMF Enforcement medium

September 8th 2023

The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations

Sanctions & settlements professional obligations Journalists The AMF Enforcement Committee fines the Association Nationale des Conseillers Financiers-CIF for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined the Association Nationale des Conseillers Financiers-CIF (ANACOFI-CIF), a professional association approved for investment advisors (CIFs), €250,000 with a warning, and its former president €20,000 with a warning, for breaching professional obligations in membership vetting, controls, archiving, and conflicts of interest management. This decision, dated September 5, 2023, underscores AMF's scrutiny of professional associations' gatekeeping and oversight roles in ensuring CIF compliance. It matters as it signals heightened enforcement against associations failing to uphold regulatory standards, potentially impacting CIF ecosystem integrity and prompting reviews of similar bodies.

What Changed

This is an enforcement action, not a new regulation, but it reinforces existing obligations under French Monetary and Financial Code (CMF) for approved professional associations like ANACOFI-CIF.
Failure to verify quality of CIF membership application dossiers and non-compliance with internal adhesion procedures.
Non-respect of procedures for member controls, sanctions, and proper archiving of control dossiers.
Violation of internal rules on conflicts of interest management. No new requirements were introduced; the case reiterates enforcement of CMF Articles L.541-8 and L.541-8-1 on documentation,...

Suggested Considerations

Review and strengthen internal procedures for CIF membership vetting, ensuring dossier quality checks align with approved protocols.
Implement robust systems for member controls, sanctions processes, and secure archiving of all dossiers per CMF L.541-8 requirements.
Update conflicts of interest policies and registers to fully comply with internal rules and CMF obligations, documenting all identifications.
Conduct gap analyses on governance, documentation, and AML/KYC for CIF activities, training staff on operationalizing procedures.
For CIF members: Verify personal compliance with association standards to mitigate contagion risks from association sanctions.

Key Dates

June 2, 2023

- AMF Sanctions Commission hearing where €500,000 sanction was initially sought (reduced in final decision)

September 5, 2023

- AMF Sanctions Commission decision issued, imposing fines and warnings on ANACOFI-CIF (€250,000) and M. Patrick Galtier (€20,000)

Post

September 5, 2023; - Decision subject to potential recourse (appeal period not specified in public summaries, typically 1 month under AMF procedures)

Compliance Impact

Urgency: Medium - This 2023 decision is not imminent but remains highly relevant given ongoing AMF focus on CIF compliance (e.g., 2025 sanctions for similar breaches like archiving and AML failures). It matters for preventing fines, bans, or reputational damage, as AMF targets systemic weaknesses in associations and CIFs, amplifying risks for non-compliant entities in a post-MiFID II enforcement environment.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Senior Managers / Governance Consumer Protection / Conduct

Topics:

Wealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News

August 28th 2023

The AMF pays tribute to Jacques Delmas-Marsalet

Institutional AMF activity Journalists The AMF pays tribute to Jacques Delmas-Marsalet

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

BankWealth ManagerAsset Manager

🇫🇷 AMF Enforcement high

July 31st 2023

The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company Altaroc Partners (formerly Amboise Partners SA) €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores the AMF's strict enforcement on operational controls, governance, and client protection in asset management, serving as a critical warning for firms to ensure robust, documented procedures and senior manager accountability. It matters because it highlights personal liability for executives and reinforces AMF's educational role through sanction explanations, potentially increasing scrutiny on similar firms.

What Changed

This is an enforcement action, not a regulatory change; it reaffirms and clarifies existing obligations under French financial regulations for asset managers (sociétés de gestion de portefeuille).
Implementing operational procedures for investment/divestment processes, including verification of lender authorizations.
Conducting systematic AML/CFT due diligence on fund assets and liabilities.
Proving that fee retrocessions to distributors enhance client service quality.
Ensuring marketing materials are accurate and compliant. These align with ongoing AMF expectations for "honest, fair, professional" conduct with requisite skill, care, and diligence.

Suggested Considerations

Review and document operational procedures for fund investments/divestments, including lender authorization checks.
Enhance AML/CFT systems with systematic due diligence on fund assets/liabilities and risk mapping.
Audit fee retrocession arrangements to demonstrate tangible client service improvements (e.g., via evidence of enhanced distribution quality).
Validate marketing materials for accuracy and completeness.
Conduct senior manager attestations on compliance oversight; implement training on personal liability.

Key Dates

15 September 2025

- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers

16 September 2025

- French version of press release published

Post

15 September 2025; - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09 (exact date not specified)

Compliance Impact

Urgency: High - This recent (2025) enforcement demonstrates AMF's willingness to impose multimillion-euro fines (€1.3M total) and hold executives personally accountable for systemic failures in core areas like operations, AML, and client disclosure. It matters for immediate risk as appeals are pending but do not suspend obligations; firms with similar setups face elevated audit risk, especially amid AMF's pattern of targeting asset managers (e.g., 5+ cases in 2024-2025).

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Topics:

Asset Manager

Investment Management Wealth & Private Banking Capital Markets & Trading

🇫🇷 AMF Enforcement high

June 22nd 2023

By two decisions, the AMF Enforcement Committee fines two investment services providers for breaches of their professional obligations

Sanctions & settlements Journalists Investment services providers By two decisions, the AMF Enforcement Committee fines two investment services providers for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee issued two decisions on 19 June 2023 fining Crédit Industriel et Commercial (€1 million) and Banque CIC Sud-Ouest (€250,000) for breaches of professional obligations in investment advisory services, including inadequate suitability assessments, client classification procedures, marketing of unsuitable instruments, and insufficient controls on costs and fees. This matters because it underscores AMF's strict enforcement of MiFID II-derived obligations, signaling heightened scrutiny on operational systems for client protection and potential for substantial fines based on breach duration and scale.

What Changed

This is an enforcement action rather than new legislation, but it reinforces existing regulatory requirements under French Monetary and Financial Code and MiFID II transposition:
Obligation to implement an effective operational system for assessing investment suitability in advisory services.
Requirement for compliant client classification procedures aligned with regulations.
Duty to market only financial instruments suited to client profiles.
Mandate for effective control systems over investment advisory activities.

Suggested Considerations

Conduct immediate gap analysis of investment advisory processes against AMF expectations for suitability assessments, client classification, product matching, and control systems.
Enhance traceability and documentation of suitability checks, client categorizations, and cost disclosures to demonstrate operational effectiveness.
Review and strengthen internal procedures for marketing instruments, ensuring alignment with client profiles and regulatory marketing authorizations (cross-reference to similar past cases).
Implement or audit remedial measures, as considered in fine calculations, including staff training on professional obligations.
Test controls for providing clear cost information to clients, avoiding misleading disclosures.

Key Dates

19 June 2023

- AMF Enforcement Committee decisions issued, imposing fines and warnings

Compliance Impact

Urgency: High – Demonstrates AMF's willingness to impose multimillion-euro fines for systemic operational failures in core client protection areas, with penalties scaled by breach duration, number, and seriousness; firms with advisory services face elevated risk of audits or enforcement if controls are deficient.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct Reporting & Disclosure Senior Managers / Governance

Broker DealerWealth ManagerBank

🇫🇷 AMF Enforcement high

May 24th 2023

The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations

Sanctions & settlements Asset management Journalists Investment management companies The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee sanctioned asset management company M Capital Partners and its managers Rudy Secco (€70,000 fine) and Stéphanie Minissier (€35,000 fine) with a total firm fine of €200,000 in its decision dated 31 December 2025, for multiple breaches of professional obligations spanning August 2019 to December 2023. This case underscores AMF's strict enforcement on operational compliance, scope of authorized activities, and AML/CFT systems in asset management, serving as a critical reminder for firms to ensure robust, traceable processes and manager accountability. It matters because it highlights personal liability for senior managers and recurring AMF focus on tied agents exceeding permitted services, potentially signaling increased scrutiny in 2026.

What Changed

This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L.
Asset management companies (AMCs) acting as tied agents cannot provide placement of financial instruments without a firm commitment basis, as this exceeds the restrictive list of permitted investment...
Investment allocation processes must be precise, operational, and traceable, with demonstrated compliance to investment procedures.
Firms must maintain effective systems for conflicts of interest identification/prevention, AML/CFT (including adequate due diligence), and overall operational controls. These align with patterns in...

Suggested Considerations

Review and enhance tied agent activities to ensure no unauthorized investment services like non-firm commitment placements; map against permitted services list.
Audit investment allocation systems for precision, operationality, and traceability; implement verifiable verifications.
Strengthen AML/CFT frameworks: ensure due diligence is adequate, systems are operational, and staff training is regular.
Update conflicts of interest policies with clear identification, prevention, and management procedures.
Conduct senior manager attestations on personal oversight; perform gap analysis against this and similar cases (e.g., Eres Gestion, Inter Gestion).

Key Dates

August 2019

December 2023; - Period of breaches investigated

31 December 2025

- AMF Enforcement Committee decision date; fines imposed on M Capital Partners (€200,000), Rudy Secco (€70,000), and Stéphanie Minissier (€35,000)

Compliance Impact

Urgency: High - This recent (Dec 2025) decision directly implicates senior accountability and operational failures in core AMC functions, with fines totaling €305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., €200k on Eres in 2023 for procedures/investor info; warnings/fines on Inter Gestion in 2024 for AML), indicating heightened 2026 enforcement risk; non-compliant firms risk fines, reputational damage, and manager bans, especially if dually registered.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset Manager

🇫🇷 AMF News medium

May 22nd 2023

MiFID II remuneration requirements: the AMF applies the ESMA Guidelines

Asset management Governance MiFID II remuneration requirements: the AMF applies the ESMA Guidelines

Sectors:

Prudential / Capital Requirements Senior Managers / Governance

Topics:

Asset Manager

🇫🇷 AMF Enforcement high

May 16th 2023

The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000, and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025, for multiple breaches spanning August 2019 to December 2023, including unauthorized placement of financial instruments as a tied agent, non-operational investment allocation processes, inadequate compliance with investment procedures, deficient conflicts of interest management, and non-operational AML/CFT systems. This decision underscores AMF's strict enforcement of operational compliance and scope limitations for asset managers, serving as a critical reminder for firms to ensure robust, traceable systems and director accountability. It matters because it highlights personal liability for managers and recurring AMF focus on AML/CFT and procedural deficiencies, potentially signaling increased scrutiny in 2026.

What Changed

This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset...
Strict limits on services: AMCs cannot provide placement of financial instruments without a firm commitment basis, even as tied agents; doing so circumvents authorized investment services.
Operational investment systems: Processes for allocating investments between funds must be precise, with full traceability of verifications.
Conflicts of interest: Firms must identify, prevent, and manage conflicts effectively.
AML/CFT: Systems must be fully operational, with adequate due diligence (e.g., client identification, PEP screening).

Suggested Considerations

Audit dual roles: Review tied agent activities to ensure no unauthorized placement services; cease any circumvention of AMC service restrictions.
Enhance investment processes: Implement precise, operational rules for fund investment allocation, with full traceability of due diligence and verifications.
Strengthen controls: Update conflicts of interest frameworks, AML/CFT systems (including due diligence, training, and risk assessments), and compliance monitoring to ensure operational effectiveness.
Director oversight: Responsible managers must demonstrate active supervision; conduct gap analyses attributing breaches to governance failures.
Documentation: Maintain auditable records for all procedures; test systems for operationality via internal audits.

Key Dates

August 2019

December 2023; - Period of breaches investigated

31 December 2025

- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier

Compliance Impact

Urgency: High - This recent (Dec 2025) decision aligns with a pattern of AMF fines on AMCs for AML/CFT, procedural, and operational failures (e.g., €200k on Eres Gestion in 2023 for rebates/investments; warnings/fines on Inter Gestion REIM in 2024 for AML). It matters due to director liability, escalating fines (up to €200k+), and AMF's educational role in clarifying regulations, risking similar actions for non-compliant firms in 2026 amid AIFMD 2.0 focus.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

Topics:

Asset Manager

Authorisation & Licensing Senior Managers / Governance

🇫🇷 AMF Enforcement high

May 3rd 2023

The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their professional obligations

Sanctions & settlements Asset management Compliance Anti-money Laundering Executive & other private individuals Investment management companies The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their...

AI Analysis

The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000 and its managers Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for multiple breaches of professional obligations from August 2019 to December 2023, including unauthorized investment services as a tied agent, non-operational investment allocation processes, deficient conflict-of-interest management, and inadequate AML/CFT systems. This decision underscores AMF's strict enforcement against operational failures in asset management, particularly for firms balancing portfolio management with tied agent roles, emphasizing personal accountability for managers. Compliance teams must review this for gaps in procedures, as it highlights how imprecise processes and poor traceability lead to substantial sanctions.

What Changed

This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociétés de gestion) are restricted to specific investment services; providing placement of financial instruments without firm commitment (as a tied agent) circumvents...
Investment systems must be operational with precise allocation rules between funds; lack of traceability in verifications violates due diligence obligations.
Firms must maintain effective conflict-of-interest identification, prevention, and management processes.
AML/CFT systems require operational due diligence, including adequate client and asset verification; deficiencies here trigger sanctions. These align with prior AMF positions but clarify enforcement...

Suggested Considerations

Audit investment services scope to ensure no unauthorized placement activities, especially if acting as tied agents; cease and remediate any circumventions.
Enhance investment allocation processes with precise rules, full traceability of verifications, and demonstrable operationality.
Strengthen conflict-of-interest frameworks with identification, prevention, and management protocols, including documentation.
Overhaul AML/CFT systems for effective due diligence on clients, assets, and risks; conduct staff training and test operationality.
Review manager accountability: responsible managers should self-assess oversight of compliance functions.

Asset ManagerBankAll Firms

🇫🇷 AMF Enforcement high

January 3rd 2023

The AMF Enforcement Committee fines the British company H2O AM LLP and two of its executives at the time of the facts for several breaches of their professional obligations

Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines the British company H2O AM LLP and two of its executives at the time of the facts for several breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined UK asset manager H2O AM LLP €75 million and its executives Bruno Crastes (€15 million, plus a 5-year ban) and Vincent Chailley (€3 million) for breaches in managing French UCITS funds, including ineligible Tennor Group investments, liquidity risks, valuation failures, and non-compliance with investment ratios and counterparty limits. This matters as it underscores AMF's strict enforcement on UCITS eligibility, risk management, and prospectus adherence, with cross-border implications confirmed by the Conseil d'État's dismissal of appeals on 13 June 2025. It signals heightened scrutiny on illiquid, unrated assets and "buy & sell back" transactions for EU asset managers.

What Changed

This is an enforcement decision, not new rules, but it reinforces existing UCITS requirements under French Monetary and Financial Code and AMF regulations:
UCITS investments must exclude illiquid, unrated securities outside prospectus scopes; liquidity risks must be properly assessed to ensure redemption capabilities.
Debt holdings per issuer capped at 10%; counterparty exposure (e.g., 5% limit) must include all relevant transactions like buy & sell backs.
Reliable valuation information required; risks of unwinding transactions at market value must be evaluated. These align with parallel FCA findings on due diligence failures for Tennor investments...

Suggested Considerations

Review portfolios: Audit UCITS/AIF holdings for liquidity, rating compliance, prospectus alignment, and issuer/counterparty limits; divest non-eligible assets.
Enhance due diligence: Implement robust processes for unlisted/illiquid securities valuation, liquidity risk modeling, and repo unwind risks; document all assessments.
Strengthen governance: Senior managers must oversee investment ratios and eligibility; update procedures for buy & sell backs in exposure calculations.
Depositary checks: Verify oversight of management company systems for ratios, legality, and prospectus terms.
Training/remediation: Conduct firm-wide training on UCITS rules; test controls against AMF/FCA principles (e.g., skill/care, regulator relations).

Key Dates

30 December 2022

- AMF Enforcement Committee decision SAN-2023-01 imposing fines and sanctions

7 August 2023

- Conseil d'État rejects preliminary constitutionality question

13 June 2025

- Conseil d'État dismisses appeals (n. 471548, 471744), upholding sanctions and ordering €3,000 costs to AMF

Compliance Impact

Urgency: High - Finalized enforcement (June 2025) with massive fines (€93M total) and bans demonstrates AMF's willingness to pursue personal/executive liability for UCITS breaches, especially cross-border. Matters for firms with illiquid strategies, as it amplifies post-2020 liquidity crisis lessons (e.g., H2O fund gates), risking similar sanctions amid rising AMF actions on depositaries and managers.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Consumer Protection / Conduct Senior Managers / Governance Reporting & Disclosure

Topics:

Asset ManagerAll Firms

Investment Management Wealth & Private Banking Capital Markets & Trading

🇫🇷 AMF News

December 23rd 2022

Marie-Anne Barbat-Layani to chair ESMA's Investor Protection Standing Committee

Europe & international Savings protection Marie-Anne Barbat-Layani to chair ESMA's Investor Protection Standing Committee

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News medium

December 9th 2022

Social and environmental responsibility, the focus of the AMF's 2022 report on corporate governance and executive compensation of listed companies

Governance Sustainable Finance Executive & other private individuals Journalists Listed companies and issuers Social and environmental responsibility, the focus of the AMF's 2022 report on corporate governance and executive compensation of listed companies

Sectors:

Topics:

ESG Reporting & Disclosure Senior Managers / Governance

Asset ManagerBankWealth Manager

🇫🇷 AMF Enforcement medium

October 28th 2022

The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

Sanctions & settlements Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee sanctioned financial investment advisor DCT (formerly Didier Maurin Finance) and its manager Didier Maurin with a five-year ban from practicing and fines of €150,000 and €200,000 respectively for recommending unauthorized Samoan AIF shares to 64 clients and failing to identify/manage conflicts of interest, including lacking a conflicts register. This decision, upheld by the Conseil d'Etat on 9 September 2024, underscores AMF's strict enforcement of client-best-interest and conflicts obligations under French regulations. It matters as it provides binding guidance on due diligence for product marketing authorization and conflicts procedures, signaling heightened scrutiny on financial investment advisors (FIAs).

What Changed

This is an enforcement action, not a regulatory change, but it clarifies and reinforces existing obligations for FIAs under AMF rules:
FIAs must verify marketing authorization of recommended products in France before advising clients; recommending unauthorized AIFs breaches competence, care, diligence, and client-best-interest...
FIAs require effective, operational procedures for identifying and managing conflicts of interest, including maintaining a conflicts register; failure to do so is a standalone breach. No new rules...

Suggested Considerations

Immediate review: Audit client portfolios for recommendations in unauthorized products (e.g., non-French AIFs); remediate via disclosures or unwind if needed.
Conflicts enhancement: Implement/maintain a conflicts of interest register; map, document, and mitigate all potential conflicts with operational procedures.
Policy updates: Revise investment recommendation processes to include pre-advice marketing authorization checks via AMF registers or legal confirmation.
Training: Mandatory staff training on FIA professional obligations, focusing on client diligence and unauthorized marketing risks.
Documentation: Ensure all advice is fully documented; prepare for AMF inspections with honest, diligent cooperation.

Key Dates

11 April 2022

- AMF Enforcement Committee issues decision SAN-2022-04, imposing bans and fines

9 September 2024

- Conseil d'Etat judgment (no. 464877) dismisses appeal, upholds sanctions, and orders €1,500 costs each to AMF

Compliance Impact

Urgency: Medium - Not critical as no new rules or deadlines, but medium due to upheld precedent reinforcing FIA duties amid AMF's pattern of FIA sanctions (e.g., bans/fines in 2022-2025 cases). Matters for FIAs lacking controls, as breaches lead to personal liability, business bans, and fines scaling with client harm; signals AMF educational enforcement focus, increasing inspection risks.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Consumer Protection / Conduct Senior Managers / Governance

Topics:

Wealth ManagerAll Firms

Banking & Credit Capital Markets & Trading Investment Management

🇫🇷 AMF News low

October 27th 2022

Marie-Anne Barbat-Layani appointed Chair of the Autorité des Marchés Financiers

Appointment Institutional AMF activity Other professionals Executive & other private individuals Fintech Market Infrastructures Post-trade Infrastructures Professional investors Journalists Investment services...

Sectors:

Topics:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

BankAsset ManagerWealth Manager

Capital Markets & Trading Insurance & Pensions

🇫🇷 AMF Enforcement critical

October 24th 2022

The AMF has requested the suspension of ORPEA's financial instruments

Markets Periodic & ongoing disclosures The AMF has requested the suspension of ORPEA's financial instruments

AI Analysis

On October 24, 2022, France's Autorité des marchés financiers (AMF) suspended all financial instruments (shares, debt securities, and related instruments) issued by ORPEA S.A., a major European care homes operator, pending disclosure of material information under the European Market Abuse Regulation. This enforcement action reflects serious governance and disclosure failures at a publicly listed company facing allegations of operational malpractice and undisclosed financial difficulties.

What Changed

The AMF's suspension order represents a temporary halt to all trading in ORPEA's financial instruments across regulated markets.
Financial covenant breaches: The company faced potential acceleration of €3.3 billion in financing lines due to anticipated breaches of "R1" and "R2" financial covenants.
Asset impairments: Anticipated write-downs at December 31, 2022, related to a stalled real estate disposal program.
Debt restructuring needs: €4.3 billion in unsecured debt requiring conversion or restructuring.

Suggested Considerations

*For ORPEA (and comparable listed companies):
*Immediate disclosure obligations: Publish a Regulated Information Service (RIS) announcement under MAR Article 17 disclosing all material information regarding financial difficulties, covenant breaches, and restructuring plans before trading resumes.
*Ongoing periodic updates: Provide quarterly updates on conciliation procedure progress, covenant amendment status, and asset disposal program execution.
*Governance remediation: Establish or strengthen disclosure committees with clear protocols for identifying and escalating material information within 24-48 hours of discovery.
*Creditor communication: Maintain transparent dialogue with financial creditors regarding covenant amendments and restructuring timelines.

Key Dates

October 24, 2022

- AMF requests suspension of ORPEA's financial instruments before market opening

October 26, 2022

- Trading resumes upon market opening following ORPEA's disclosure of conciliation procedure and financial restructuring plan

November 8, 2022

- Q3 2022 revenue announcement (after market close)

November 15, 2022

- ORPEA to present detailed transformation plan to market

December 31, 2022

- Anticipated asset impairment recognition date

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Market Abuse / Surveillance Reporting & Disclosure Senior Managers / Governance

All Firms

Investment Management Capital Markets & Trading Wealth & Private Banking

🇫🇷 AMF Consultation medium

October 12th 2022

The AMF encourages French participants to provide feedback to ESMA’s call for evidence on the implementation of the Shareholders Rights Directive (SRD 2)

Governance Europe & international The AMF encourages French participants to provide feedback to ESMA’s call for evidence on the implementation of the Shareholders Rights Directive (SRD 2)

AI Analysis

The AMF publication urges French market participants to submit feedback to ESMA's call for evidence evaluating the implementation of the Shareholder Rights Directive II (SRD II), which aims to enhance long-term shareholder engagement, transparency in voting processes, and issuer-shareholder dialogue across the EU/EEA. This matters for compliance teams as it signals ongoing regulatory scrutiny of SRD II transposition and operational compliance, potentially leading to harmonized amendments that could require process updates in shareholder identification, voting transmission, and engagement disclosures. French firms' input can influence future EU rules, mitigating risks of non-compliance with evolving standards.

What Changed

This AMF notice itself introduces no new regulatory changes; it promotes participation in ESMA's review of SRD II (Directive (EU) 2017/828), implemented via national laws by June 2019 and effective from September 3, 2020. SRD II's core requirements include: shareholder identification without delay, electronic/machine-readable transmission of voting and meeting information along the intermediary chain, confirmation of vote recording/counting, transparency on institutional investor and asset manager engagement policies/strategies, and extended scope to EEA-listed shares.

Suggested Considerations

Submit feedback to ESMA: French participants must review ESMA's call for evidence and provide input on SRD II implementation challenges, such as intermediary processes, data transmission, and cross-border voting (immediate action urged by AMF).
Review current compliance: Audit internal systems for SRD II adherence, including electronic formats (e.g., seev.008 messages, MT 260SRD mandates), vote confirmations, and engagement policy disclosures.
Enhance processes if needed: Align with Implementing Regulation (EU) 2018/1212 for shareholder ID requests, meeting notifications, and voting (e.g., VOTACCESS adaptations for French market).
Monitor ESMA/EC outputs: Prepare for potential rule changes from the review, such as harmonized documentation or deadlines.

Key Dates

June 10, 2019 DEADLINE

- EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019)

September 3, 2020

- SRD II go-live date for operational requirements like shareholder identification and voting processes

October 3, 2022

- European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review

Compliance Impact

Urgency: Medium - SRD II has been live since 2020, so core compliance is established, but ESMA's review could trigger targeted amendments (e.g., operational standardization), especially for French intermediaries handling cross-border flows. This matters for avoiding supervisory findings in ongoing AMF/ESMA exams, as non-participation in feedback risks unaddressed pain points becoming enforceable rules; proactive input now supports influence over final outcomes.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Reporting & Disclosure

Asset ManagerBroker DealerBank

Banking & Credit Investment Management Insurance & Pensions Capital Markets & Trading Payments & E-Money Crypto & Digital Assets

🇮🇪 CBI Enforcement low

October 6th 2022

Insurance supervision in an uncertain environment - Remarks by Domhnall Cullinan, Director of Insurance Supervision, at Financial Services Ireland

Introduction Good morning everyone. Thank you for inviting me to speak here today. Before I begin, I’d like to acknowledge the important role played by Financial Services Ireland in advocating for its members, and in promoting the Irish financial services sector, both here and abroad. Whilst the respective missions we undertake are undoubtedly different, we have a shared interest in a strong and stable financial services sector. It is claimed that the phrase “may you live in interesting times...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

Insurance

Investment Management Capital Markets & Trading Wealth & Private Banking

🇫🇷 AMF Consultation low

September 30th 2022

AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani

AMF activity AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani

AI Analysis

This AMF publication announces a proposal to appoint Marie-Anne Barbat-Layani as Chair of the AMF, France's financial markets authority responsible for investor protection, market supervision, and regulatory enforcement. It matters for compliance professionals because leadership changes at key regulators like the AMF can signal shifts in enforcement priorities, supervisory focus, or policy directions affecting investment firms, asset managers, and market participants across the EU. While not imposing immediate rules, it warrants monitoring for potential impacts on ongoing consultations and governance expectations.

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance

Asset ManagerBroker DealerBank

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News medium

September 15th 2022

Call for candidates: renewal of the members of the Climate and Sustainable Finance Commission

Sustainable Finance AMF activity Journalists Call for candidates: renewal of the members of the Climate and Sustainable Finance Commission

Sectors:

Topics:

ESG Authorisation & Licensing Senior Managers / Governance

Asset ManagerBankWealth Manager

Banking & Credit Investment Management Capital Markets & Trading

🇫🇷 AMF News medium

July 29th 2022

End of the term of office of the AMF chairman and interim chairmanship

AMF activity Appointment Journalists End of the term of office of the AMF chairman and interim chairmanship

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

BankAsset ManagerBroker Dealer

Investment Management Banking & Credit Wealth & Private Banking

🇫🇷 AMF Enforcement medium

July 25th 2022

The AMF Enforcement Committee fines a depositary for breaches of its professional obligations

Sanctions & settlements Compliance Journalists Investment services providers The AMF Enforcement Committee fines a depositary for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined RBC Investor Services Bank France SA (RBC ISBF) €500,000 plus a warning on 20 July 2022 (published 08 January 2026) for breaches as a UCITS and AIF depositary, including 25 confirmed failures in tiered intervention procedures for investment ratio overruns and deficient monitoring of 14 questionable cash flows over 45 months. This decision underscores AMF's strict enforcement of depositary duties under French regulations implementing UCITS/AIFMD, emphasizing robust controls for ratio compliance, cash flow verification, and documentation. It matters for compliance teams as it provides precedent on what constitutes "irregular and deficient" oversight, potentially increasing scrutiny and fines for similar lapses in depositary functions.

What Changed

This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing depositary obligations under French UCITS/AIFMD rules (e.g., Articles L. 214-7 et seq.
Ratio monitoring and intervention: Depositaries must implement tiered procedures for investment/asset composition ratio breaches (e.g., diversification limits); 25 of 28 alleged anomalies were upheld...
Cash flow oversight: Must identify significant/inconsistent flows, verify instructions against laws, fund rules, prospectuses, and ensure ownership thresholds (e.g., 5% capital holding for advances);...

Suggested Considerations

Review depositary controls: Audit tiered intervention procedures for ratio overruns; ensure unique tracking (even if not upheld here) and redundancy elimination in reporting.
Enhance cash flow monitoring: For all inflows/outflows, collect "precise and convincing" docs (e.g., ownership proofs for advances >5% capital); flag inconsistencies with fund docs/prospectus.
Conduct gap analysis: Sample historical flows (e.g., 45-month lookbacks) across AIFs/UCITS; test against AMF objections standards from this and similar cases (e.g., CACEIS).
Update policies/procedures: Document controls for legality checks on instructions; train staff on evidentiary thresholds to avoid "deficient monitoring" findings.
Appeal if applicable: Lodge appeal against decision (no deadline specified).

Key Dates

20 July 2022

- AMF Enforcement Committee decision date imposing €500,000 fine and warning on RBC ISBF

08 January 2026

- Public news release/publication date of the decision

Compliance Impact

Urgency: Medium – Recent publication (08 January 2026) signals ongoing AMF focus on depositary failings amid H2O-related probes, but stems from 2022 events with no immediate deadlines. Matters because it sets precedents for fine quantum (€500k) on procedural lapses, reinforces liability for cash/ratio controls, and aligns with pattern of multi-million fines (e.g., CACEIS €3.5m), urging preemptive audits to mitigate enforcement risk.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

Asset ManagerBankWealth Manager

🇫🇷 AMF Enforcement high

July 18th 2022

The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

Sanctions & settlements Journalists The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined an unnamed portfolio asset management company €400,000 for multiple breaches of professional obligations, including non-operational investment/divestment procedures, inadequate conflict of interest management with group service providers, lack of transparency on distributor fee retrocessions, deficient client categorization, and weak AML/CFT due diligence. This enforcement action, mirroring recent similar cases against firms like Novaxia Investissement and Eternam, underscores the AMF's heightened scrutiny on operational robustness and transparency in asset management, serving as a critical reminder for firms to ensure procedures are fully implemented and documented to avoid personal liability for executives.

What Changed

This is an enforcement decision rather than new legislation, but it reinforces and clarifies existing regulatory requirements under AMF professional obligations for portfolio asset managers (sociétés...
Investment/divestment processes must be fully operational, with traceability of compliance checks against fund policies and formalized due diligence before allocations.
Effective conflicts of interest policies are mandatory when using group service providers, with comprehensive, accurate investor disclosures on related remuneration.
Full transparency required on retrocessions of management fees to distributors, including justification of added value.
Robust client categorization and AML/CFT systems, including operational procedures, risk mapping, and adequate due diligence on fund assets/liabilities. No explicit regulatory changes, but these...

Suggested Considerations

Audit internal procedures: Immediately review investment/divestment, valuation, and allocation processes for operational status, completeness, traceability, and documentation of due diligence.
Enhance conflict and transparency controls: Implement/test effective conflicts of interest policies for group providers/distributors; update investor disclosures on fees/retrocessions with clear justifications.
Strengthen AML/CFT and client categorization: Validate risk mapping, procedures, and due diligence; ensure formalization of independent valuer work and external expert oversight.
Senior manager accountability: Conduct gap analysis attributing responsibilities; train executives on personal liability risks.
Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on evidence of procedure adherence.

Key Dates

9 September 2025

- AMF Enforcement Committee decision fining Eternam €400,000 (similar case on marketing, club deals, conflicts, valuation, AML/CFT)

10 December 2025

- AMF Enforcement Committee decision fining Novaxia Investissement €400,000 and director €100,000 (investment processes, group providers, distributor fees, client categorization, AML/CFT)

31 December 2025

- AMF Enforcement Committee decision fining M Capital Partners €200,000 and directors €70,000/€35,000 (investment systems, conflicts, AML/CFT)

Compliance Impact

Urgency: High - Recent cluster of identical fines (€200k-€500k total per case) in late 2025 signals AMF's enforcement priority on operational deficiencies in asset management, with personal sanctions escalating risks for leadership. Firms with similar setups (group providers, AIFs/club deals) face imminent inspection risk; non-compliance could trigger fines, reputational damage, and appeals processes.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Topics:

Asset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News low

July 7th 2022

Grégoire Vuarlot is appointed coordinator of the ACPR and AMF Joint Unit starting 1st July 2022

AMF activity Appointment Journalists Grégoire Vuarlot is appointed coordinator of the ACPR and AMF Joint Unit starting 1st July 2022

Sectors:

Topics:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

BankWealth ManagerAsset Manager

Capital Markets & Trading Investment Management Banking & Credit

🇫🇷 AMF Enforcement low

June 24th 2022

Appointments to the Legal Affairs Directorate and Enforcement Assistance Directorate of the Autorité des Marchés Financiers

Institutional AMF activity Appointment Journalists Appointments to the Legal Affairs Directorate and Enforcement Assistance Directorate of the Autorité des Marchés Financiers

AI Analysis

This AMF publication announces internal appointments to its **Legal Affairs Directorate** and **Enforcement Assistance Directorate**, signaling potential enhancements in legal oversight and enforcement capabilities within France's financial markets regulator. Compliance professionals should note this as it may indicate a renewed focus on rigorous enforcement of market rules, though it imposes no direct regulatory changes on firms.

What Changed

There are no regulatory changes, new requirements, or policy updates in this announcement. It solely details personnel appointments within AMF's internal structure, specifically leadership roles in directorates handling legal affairs (e.g., Maxence Delorme as head of Legal Affairs Directorate) and enforcement assistance (e.g., Amélie du Passage as head of Instruction and Enforcement Assistance Directorate). These directorates support AMF's core functions like investigations, inspections, and sanction proceedings, but the publication does not alter any rules applicable to regulated entities.

Suggested Considerations

*No specific actions are required for regulated firms, as this does not introduce obligations. Recommended monitoring steps for proactive compliance:
Review ongoing AMF interactions (e.g., inspections) for potential shifts in approach under new directorate leadership.
Update internal AMF contact lists with confirmed governance details from https://www.amf-france.org/en/amf/our-organisation/our-governance.
Track AMF news releases for enforcement trends at https://www.amf-france.org/en/news-publications/news-releases/amf-news-releases.

Key Dates

16 October 2023

- Appointment of Sébastien Raspiller as AMF Secretary General

13 February 2024

- Ministerial order partially renewing AMF Enforcement Committee

20 February 2024

- Publication of Enforcement Committee appointments

27 February 2024

- Composition published in Official Journal

Compliance Impact

Urgency: Low. This matters peripherally for firms anticipating AMF enforcement, as new leaders in Legal Affairs and Enforcement Assistance could signal stricter scrutiny or faster processing of cases, similar to past leadership transitions (e.g., Secretary General appointment in 2023). However, absent policy shifts, it does not demand immediate compliance adjustments; monitor for signals in AMF's 2026 priorities announced 14 January 2026.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Market Abuse / Surveillance

Asset ManagerBroker DealerBank

🇫🇷 AMF Enforcement high

June 2nd 2022

The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

Sanctions & settlements Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined financial investment advisor Séquence 13 and its director Jean-Louis Lehmann €15,000 each and imposed a five-year ban from acting as financial investment advisors in its decision of 19 December 2023, due to failures in client disclosures, justifying remuneration, operating within regulatory limits, and managing conflicts of interest. This enforcement action underscores the AMF's strict enforcement of professional obligations for investment advisors, with personal liability for managers, serving as a deterrent against conduct breaches that harm client interests. Compliance teams should note this as part of a pattern of similar sanctions, emphasizing robust governance and documentation.

What Changed

This is an enforcement decision, not a new regulation, but it reinforces core professional obligations under AMF rules for financial investment advisors (Conseillers en Investissements Financiers,...
Client information on remuneration: Advisors must disclose any remuneration received for advice and justify service improvements relative to that pay.
Regulatory scope compliance: Firms must operate strictly within authorized activities, avoiding unauthorized product recommendations.
Conflict of interest management: Identify and mitigate conflicts to ensure client-best-interest advice.
Manager accountability: Breaches by the firm are attributable to its director, with personal sanctions possible. These align with ongoing AMF expectations for honest, fair, professional conduct, as...

Suggested Considerations

Review and enhance policies: Update procedures for remuneration disclosure, conflict identification/mitigation, and scope-of-activity limits; ensure all advice justifies value against fees.
Training programs: Mandate annual training for directors/managers on professional obligations, documentation, and inspection cooperation, as deficiencies led to personal liability.
Client file audits: Conduct gap analysis on existing client files for disclosure completeness, product suitability, and conflict records; remediate as needed.
Governance checks: Directors must verify firm compliance, implementing detection systems for misconduct (e.g., undocumented investments).
Mock inspections: Prepare for AMF inspections by simulating reviews, focusing on diligence and honesty.

Key Dates

19 December 2023

- AMF Enforcement Committee decision issued, imposing fines and five-year bans on Séquence 13 and Jean-Louis Lehmann

Compliance Impact

Urgency: High - This decision highlights escalating AMF scrutiny on CIFs, with fines, bans, and personal accountability in multiple recent cases (2022-2025), signaling increased inspection risk and potential for director bans. It matters because failures in basic conduct rules lead to severe, long-term sanctions, disrupting operations and reputations; firms must prioritize immediate policy fortification amid AMF's 2026 priorities for resilient markets.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Consumer Protection / Conduct Senior Managers / Governance Authorisation & Licensing

Topics:

Wealth ManagerAll Firms

🇫🇷 AMF Enforcement medium

May 4th 2022

The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

Sanctions & settlements Investment advice Other professionals Executive & other private individuals Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined a financial investment advisor (FIA) firm and its manager for multiple breaches of professional obligations, including failure to provide mandatory documents, inadequate risk disclosure, poor KYC practices, misleading information, unauthorized placing activities, and improper third-party marketing mandates. This enforcement action underscores the AMF's strict scrutiny of FIAs, emphasizing due care, conflict management, and adherence to status limits, with fines and bans serving as deterrents. Compliance teams should review it for lessons on documentation, client suitability, and outsourcing controls to avoid similar sanctions.

What Changed

This is an enforcement decision, not a regulatory change, but it reinforces and clarifies existing FIA obligations under French regulations (e.g., AMF General Regulation).
Mandatory delivery of initial contact documents, engagement letters, and written reports to clients.
Clear specification of remuneration terms and comprehensive risk information for recommended products.
Thorough KYC to ensure suitability of advice.
Prohibition on misleading information, such as incorrect guarantor details or omission of issuer financial weaknesses.

Suggested Considerations

Conduct Documentation Audit: Verify all client interactions include mandatory forms (e.g., initial contact, engagement letter, suitability reports) and explicit risk/remuneration disclosures.
Enhance KYC and Suitability Processes: Implement robust know-your-customer checks and product authorization verification before recommendations, especially for non-EU funds or unlisted securities.
Strengthen Conflicts Framework: Maintain a conflicts register, identify/mitigate incentives from issuers, and document procedures.
Review Activity Scope: Confirm no unauthorized placing or marketing beyond FIA status; limit third-party mandates to natural persons and accredited products.
Training and Monitoring: Train managers on personal liability; perform gap analysis against AMF decisions and update policies accordingly.

Key Dates

24 January 2019

AMF Enforcement Committee decision fining Novactifs Patrimoine €250,000 and CEO €100,000 for breaches from March 2014–July 2016

11 April 2022

AMF Enforcement Committee decision imposing 5-year bans and fines (€150,000 firm, €200,000 manager) on DCT/Didier Maurin Finance; appeal dismissed by Conseil d'Etat on 9 September 2024

4 November 2024

AMF fines totaling €5,670,000 on FIA Smart Tréso Conseil, asset managers, and CACEIS Bank for fund marketing/management breaches

5 November 2025

AMF Enforcement Committee decision fining Carat GP and directors €2.5 million total, with permanent/10-year bans (French release: 6 November 2025)

Compliance Impact

Urgency: Medium. This matters as part of a pattern of escalating AMF enforcement against FIAs (fines up to €2.5M, lifetime bans in recent cases), signaling heightened focus on investor protection and governance amid complex products. Firms should prioritize audits now to preempt inspections, but no immediate deadlines apply. Non-compliance risks personal sanctions on executives, reputational damage, and business bans, particularly for smaller advisory firms.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Consumer Protection / Conduct Senior Managers / Governance Authorisation & Licensing

Topics:

Wealth ManagerAsset ManagerAll Firms

Investment Management Capital Markets & Trading Wealth & Private Banking

🇫🇷 AMF News low

April 28th 2022

Appointments in the Investigations Directorate and the Asset Management Directorate

Appointment AMF activity Other professionals Executive & other private individuals Market Infrastructures Post-trade Infrastructures Professional investors Journalists Investment services providers Investment management...

Sectors:

Topics:

Authorisation & Licensing Senior Managers / Governance Reporting & Disclosure

Asset ManagerWealth ManagerBank

Investment Management Capital Markets & Trading Banking & Credit

🇫🇷 AMF Enforcement high

April 14th 2022

The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

Sanctions & settlements Journalists The AMF Enforcement Committee fines a financial investment advisor and its manager for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee imposed significant sanctions on DCT (formerly Didier Maurin Finance) and its manager Didier Maurin for recommending unauthorized alternative investment funds to clients and obstructing regulatory investigations. This case exemplifies critical compliance failures in product authorization verification and client suitability assessment, with enforcement upheld by France's highest administrative court in September 2024.

What Changed

This enforcement action clarifies several regulatory obligations for financial investment advisors:
Product Authorization Verification: Financial advisors must verify that recommended investment products are authorized for marketing in France before advising clients, regardless of the product's...
Client Interest Prioritization: Recommending unauthorized products is inherently contrary to client interests and constitutes a breach of the duty to act with competence, care, and diligence.
Cooperation with Regulators: Advisors must provide documents and information requested during regulatory investigations; refusal constitutes a separate breach of diligence and loyalty obligations.

Suggested Considerations

*Immediate compliance measures for financial investment advisors:
*Product Authorization Audit: Conduct comprehensive review of all recommended products to confirm authorization for marketing in France; document authorization status for each product in client files.
*Pre-Recommendation Due Diligence: Establish mandatory procedures requiring verification of product authorization before any client recommendation; implement checklist systems for compliance documentation.
*Client Suitability Documentation: Maintain written suitability reports for all recommendations, including product features, risks, and alignment with client profiles and objectives.
*Regulatory Cooperation Protocol: Establish procedures ensuring prompt, complete responses to AMF information requests; designate compliance officer responsible for regulatory liaison.

Key Dates

AI Analysis

The AMF announced its intention to propose legislative amendments to the French Monetary and Financial Code following a January 28, 2022 Constitutional Council decision that found dual prosecution for obstructing AMF investigations and inspections unconstitutional. The amendment aims to eliminate the possibility of simultaneous administrative and criminal penalties for the same obstruction conduct, while preserving the AMF's enforcement authority.

What Changed

The primary regulatory change addresses a constitutional violation regarding dual prosecution under the ne bis in idem principle:
Current problem: The Monetary and Financial Code previously allowed both administrative sanctions by the AMF Enforcement Committee and criminal prosecution for identical obstruction conduct,...
Proposed solution: Legislative amendments will eliminate the possibility of dual prosecution while maintaining the AMF's ability to sanction obstruction of investigations and inspections.
Scope of obstruction conduct: The law covers refusal to allow access to documents, provide copies, communicate information, respond to summons, or grant access to professional premises during AMF...

Suggested Considerations

*For compliance professionals and regulated entities:
*Review cooperation policies: Ensure internal procedures for responding to AMF investigation and inspection requests comply with current legal requirements and anticipated amendments.
*Monitor legislative developments: Track publication of proposed amendments in the French legislative process to understand final scope of changes.
*Counsel on cooperation: Advise business units that obstruction remains sanctionable; the amendment eliminates dual penalties, not the underlying obligation to cooperate.
*Document compliance: Maintain records demonstrating good-faith cooperation with AMF requests to support defense against obstruction allegations.

Key Dates

January 28, 2022

- Constitutional Council decision declaring dual prosecution unconstitutional

Current status (as of January 2026)

- Amendments appear to be in legislative proposal stage; no effective date yet announced

No specific implementation deadline stated DEADLINE

- AMF committed to proposing amendments "as soon as possible"

Compliance Impact

Urgency: MEDIUM

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Market Abuse / Surveillance Authorisation & Licensing Senior Managers / Governance

Asset ManagerBroker DealerAll Firms

🇫🇷 AMF Enforcement high

January 6th 2022

The AMF Enforcement Committee fines an issuer's Chief Financial Officer for insider dealing

Sanctions & settlements Journalists The AMF Enforcement Committee fines an issuer's Chief Financial Officer for insider dealing

AI Analysis

The AMF Enforcement Committee fined an issuer's Chief Financial Officer (CFO) for insider dealing, highlighting the regulator's aggressive enforcement against market abuse by senior executives. This case underscores the personal liability of insiders who trade on privileged information, reinforcing the need for robust internal controls in listed companies. Compliance teams must prioritize insider trading prevention to mitigate similar sanctions risks.

What Changed

This enforcement action does not introduce new regulatory changes but exemplifies ongoing application of existing Market Abuse Regulation (MAR) rules under EU Regulation 596/2014 and AMF General Regulations, including Articles 223-9 and 221-3 on inside information disclosure and trading bans. It aligns with AMF Position-Recommendation No 2016-08 on managing inside information, emphasizing black-out periods (e.g., 30 days before annual/interim results) and trading restrictions for Persons Discharging Managerial Responsibilities (PDMRs).

Suggested Considerations

Implement or update insider trading policies with mandatory black-out periods (30 days pre-annual/interim results, 15 days pre-quarterly info), extending to all routine/occasional insiders per AMF recommendations.
Maintain insider lists and notify affected persons of trading restrictions; train staff on MAR Article 17 (disclosure) and Article 19 (PDMR dealings).
Strengthen monitoring of gifts, transactions in derivatives/index products, and whistleblowing mechanisms, as urged in AMF/AFA joint guidance.
Ensure PDMR transaction reporting within 3 trading days via AMF portal.
Conduct regular compliance inspections on insider networks and corruption risks, formalizing prohibitions in codes of ethics.

Key Dates

December 4, 2024

- EU Regulation 2024/2809 amending MAR entered into force

June 5, 2026

- Certain amendments in sample insider policies apply (e.g., Groupe Casino policy)

June 30, 2026

- AMF General Regulation updates effective

3 trading days DEADLINE

- PDMRs must report securities transactions to issuer and AMF

Compliance Impact

Urgency: High - This demonstrates AMF's focus on holding executives accountable, with fines signaling zero tolerance amid rising "insider networks" linked to organized crime, as noted in AMF's 2024 report and 2025 AMF/AFA warnings. Firms face heightened inspection risks, reputational damage, and personal sanctions; immediate policy reviews are essential pre-2026 MAR amendments to avoid enforcement.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Market Abuse / Surveillance Senior Managers / Governance

Topics:

All Firms

🇫🇷 AMF Enforcement high

December 29th 2021

The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations

Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores AMF's focus on operational controls, due diligence, and transparency in asset management, serving as a key enforcement precedent that highlights personal liability for senior managers. Compliance teams must review it to strengthen internal procedures and governance amid rising AMF scrutiny on these issues.

What Changed

This is an enforcement action, not a regulatory change introducing new rules; it enforces existing obligations under French financial regulations for asset management companies (sociétés de gestion...
Absence of operational procedures for investment/divestment processes, failing to verify lender authorizations, breaching duties to act honestly, fairly, professionally, with skill, care, and...
Inability to demonstrate that retrocessed management fees to distributors improved client services.
Failure to systematically perform AML/CFT due diligence on fund assets and liabilities.
Shortcomings in fund marketing materials, lacking clear, accurate information. These align with ongoing AMF expectations for robust internal systems, as seen in similar cases emphasizing operational...

Suggested Considerations

Implement and document operational procedures for all investment/divestment processes, including third-party authorization checks (e.g., lenders).
Conduct and document systematic AML/CFT due diligence on fund assets/liabilities, ensuring risk mapping and procedures are operational.
Substantiate retrocessions of fees to distributors with evidence of enhanced client services; otherwise, cease or disclose fully.
Review and enhance fund marketing materials for accuracy, comprehensiveness, and non-misleading content.
Senior managers: Demonstrate oversight of compliance functions; conduct gap analyses attributing breaches.

Key Dates

15 September 2025

- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers

16 September 2025

- French version of press release published

Compliance Impact

Urgency: High - This recent (2025) decision signals intensified AMF enforcement on core operational failures in asset management, with total fines of €1.3 million and personal accountability, amid a pattern of similar actions (e.g., M Capital Partners €305,000 in Dec 2025, Eternam €400,000 in Sep 2025). It matters because AMF uses such rulings educationally to clarify expectations, increasing audit risks and penalties for non-compliance; firms without robust procedures face immediate exposure, especially with appeals not suspending applicability.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Topics:

Asset Manager

🇮🇪 CBI Enforcement medium

September 29th 2021

Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar

Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar Good morning everybody and thank you to Deloitte for the invitation to speak at this webinar. Some people think of insurance as a relatively modern financial concept. But of course, as the insurance experts in this audience know, its origins can be traced all the way back to certain kinds of shipping loans in Babylon, through Ancient Rome and Greece, and into Medieval Europe. In the 17 th ...

Sectors:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

Topics:

Insurance

Banking & Credit Insurance & Pensions Capital Markets & Trading Payments & E-Money Crypto & Digital Assets

🇮🇪 CBI Enforcement low

June 23rd 2021

Supervisory Priorities in Uncertain Times - Domhnall Cullinan, Director of Insurance Supervision

Introduction Good morning, and thank you for attending our Insurance Industry Event, the second of these which we’ve held virtually. Hopefully, as the vaccine rollout continues and restrictions are eased, there won’t have to be a third! The COVID 19 crisis has brought about a significant amount of change to all of our personal and professional lives, and with it has provided the opportunity to reflect on what is important, and where our priorities should lie. With this in mind, I would like t...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

Insurance

Banking & Credit Investment Management Insurance & Pensions

🇮🇪 CBI Enforcement high

June 10th 2021

The importance of fitness, probity and ensuring responsibility - Director General, Financial Conduct, Derville Rowland

Speech delivered at Institute of Directors’ Briefing Webinar on 10 June 2021 Good morning everyone, I am delighted to speak to you on the importance of effective culture in firms, the contribution fitness and probity can make, and how we see the forthcoming Individual Accountability Framework further reinforcing effective culture. I’ll come to each of those topics in turn. But first let me say that the Central Bank and the Institute of Directors have overlapping visions. The Central Bank serv...

AI Analysis

This 2021 speech by Derville Rowland, Director General of Financial Conduct at the Central Bank of Ireland (CBI), emphasizes the critical role of the Fitness & Probity (F&P) regime and the forthcoming Individual Accountability Framework (IAF) in fostering effective culture, governance, and individual responsibility in regulated firms. It matters because it signals CBI's supervisory priorities on senior role holders' competence, integrity, and accountability, which have since evolved into concrete regulatory updates, directly impacting board and compliance functions to mitigate conduct risks and ensure consumer protection. https://www.centralbank.ie/news/article/speech-importance-of-fitness-probity-and-ensuring-responsibility-derville-rowland-10-june-2021

What Changed

The speech itself outlines no new statutory changes but highlights the F&P regime's role in ensuring "fit and proper" individuals in key roles and previews the IAF as a complementary framework to...
Consolidation of F&P Standards into the Fitness and Probity Standards 2025, applicable across all sectors, read alongside revised Guidance on the Fitness and Probity Standards (effective 20 November...
Amendments to Pre-Approval Controlled Functions (PCFs), adding roles like Designated Person for Investment Management (PCF-39D), Distribution (PCF-39E), and Regulatory Compliance (PCF-39F),...
Clarifications on due diligence (best-efforts basis for references, criminal checks, financial soundness via public records only—no bank statements required), time commitments (case-by-case), and...
Proportionality for fitness assessments but not probity; ongoing certification obligations for Controlled Functions (CFs) and PCFs. These build on the speech's vision, addressing Enria Report...

Suggested Considerations

Conduct thorough F&P due diligence on PCF/CF holders pre-appointment and ongoing (best-efforts for references, criminal/financial checks via public records; assess time commitments case-by-case).
Certify annually that PCF/CF individuals meet standards; no dual certification needed if PCF covers CF-1/2.
Review and update succession planning, handover policies, and conduct breach procedures in light of new PCFs and IAF/SEAR (Statements of Effectiveness and Accountability of Responsibilities).
Assess residency and capacity for non-resident PCF holders case-by-case, considering firm complexity.
Embed F&P into culture and governance frameworks, aligning with IAF Conduct Standards once enacted.[Speech]

Key Dates

22 September 2021

- CBI notice of intention to amend PCFs under F&P regime (e.g., new Designated Persons roles)

20 November 2025

- Effective date for revised Guidance on Fitness and Probity Standards

24 November 2025

- CBI publishes Feedback Statement on CP160, Fitness and Probity Standards 2025, and revised Guidance

Post

amendment (TBD, after regulations effective); - 6-week window for in-situ PCF assessments and confirmations to CBI

Compliance Impact

Urgency: High – While the 2021 speech is foundational, 2025 Standards and Guidance are now effective, mandating immediate due diligence enhancements and certifications amid IAF rollout. Non-compliance risks CBI investigations, prohibitions, or sanctions, especially with expanded PCFs tying into broader accountability (e.g., SEAR). This elevates board exposure, demanding proactive governance reviews to align culture with consumer protection mandates.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Consumer Protection / Conduct Authorisation & Licensing

BankAsset ManagerInsurance

Banking & Credit Insurance & Pensions Capital Markets & Trading Payments & E-Money

🇮🇪 CBI Enforcement critical

November 12th 2020

Opening remarks at the 2020 Insurance Industry Briefing - Domhnall Cullinan, Director of Insurance Supervision

Opening remarks at the 2020 Insurance Industry Briefing Good morning everyone. I would like to thank you for attending today’s industry briefing. In my remarks this morning, I will take this opportunity to touch on: the role that insurance can play in society; some of the reasons why the industry in Ireland is negatively perceived; and the areas of supervisory focus for the Central Bank moving forward. 2020 has been an unprecedented year in so many respects and the emergence of COVID-19 has a...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankInsurance

Banking & Credit Wealth & Private Banking Insurance & Pensions Capital Markets & Trading

🇮🇪 CBI Enforcement critical

November 12th 2019

Introductory statement by Derville Rowland, Director General, Financial Conduct, at the Joint Committee on Finance, Public Expenditure and Reform, and Taoiseach

I am joined today by Gráinne McEvoy, Director of Consumer Protection, and Domhnall Cullinan, Director of Insurance Supervision. Thank you for this opportunity to speak to you today about the Central Bank’s work in regulating and supervising the Irish insurance industry and specifically the practices of differential pricing and dual pricing. Insurance serves a critical role in the functioning of a modern society, through reducing uncertainty by protecting people and businesses against the risk...

Sectors:

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Operational Resilience / Outsourcing

BankInsurance

🇮🇪 CBI Enforcement medium

December 20th 2018

Enforcement Action: RSA Insurance Ireland DAC fined €3.5m

The Central Bank of Ireland imposes a fine of €3,500,000 on RSA Insurance Ireland DAC for regulatory breaches relating to large loss claims and accounting irregularities On the 18 December 2018, the Central Bank of Ireland (the “ Central Bank ”) reprimanded and fined RSA Insurance Ireland DAC (“ RSAII ” or the “ Firm ”) €3,500,000 in respect of serious breaches relating to the following: Failure to establish and maintain Technical Reserves in respect of all underwriting liabilities assumed by...

AI Analysis

The Central Bank of Ireland (CBI) fined RSA Insurance Ireland DAC (RSAII) €3.5 million in December 2018 for serious breaches involving failure to maintain adequate technical reserves, inadequate internal controls and accounting procedures, and weak governance, stemming from deliberate under-reserving of large loss claims from 2009 to 2013, which understated reserves by €78.2 million as of 30 September 2013. This enforcement action underscores the CBI's zero-tolerance stance on reserving practices that risk policyholder protection and financial stability, highlighting how governance failures enabled manipulation and led to a significant capital injection for RSAII. It matters for compliance professionals as it demonstrates ongoing CBI scrutiny, with related actions against individuals like former CEO Philip Smith (13-year disqualification in 2025) and a former actuary (5-year prohibition).

What Changed

This is an enforcement action, not a new regulation, but it reinforces core pre-Solvency II requirements under the European Communities (Non-Life Insurance) Framework Regulations 1994, specifically Article 13(1)(a), mandating firms to establish and maintain technical reserves for all underwriting liabilities. It highlights breaches of the Corporate Governance Code for Credit Institutions and Insurance Undertakings 2010 (Section 6.3), requiring robust governance, internal reporting, and reliable information flows to decision-makers.

Suggested Considerations

Conduct reserving process reviews: Ensure claims handlers' recommended estimates are recorded without delay or manipulation; implement independent validation for large loss claims.
Strengthen internal controls: Develop sound administrative/accounting procedures and mechanisms to detect irregularities (e.g., unearned premium adjustments, claims expenses).
Enhance governance: Robustify internal reporting structures per Corporate Governance Code 2010 (Section 6.3); promote ethical culture to prevent individual overrides.
Senior accountability: Boards and executives must oversee compliance; remediate via capital injections if needed, as RSAII did.
Supervisory engagement: Cooperate fully with CBI probes; apply lessons to Solvency II reserving under Article 101 (post-2016).

Key Dates

2009

October 2013; Period of under-reserving breaches and manipulation of large loss claims

30 September 2013

Date of €78.2 million technical reserves understatement

October 2013

CBI identifies issues during scheduled supervisory engagement

2014

CBI investigation into RSAII and individuals (e.g., Philip Smith) begins

December 2018

RSAII admits four breaches; enforcement against firm concludes

Compliance Impact

Urgency: Medium – This 2018 action is historical but remains highly relevant due to 2025 individual enforcements, signaling CBI's long-term pursuit of accountability in insurance reserving and governance. It matters because under-reserving risks policyholder losses, financial instability, and capital adequacy (e.g., RSAII's injection), with CBI emphasizing deterrence via maximum fines and disqualifications; firms must self-assess controls to avoid similar scrutiny under Solvency II.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Prudential / Capital Requirements Senior Managers / Governance Reporting & Disclosure

Topics:

Insurance

Capital Markets & Trading Investment Management Wealth & Private Banking

🇮🇪 CBI Enforcement medium

December 18th 2017

Merrion Stockbrokers Limited fined €200,00 in respect of failings pursuant to the Fitness and Probity regime.

Settlement Agreement between the Central Bank of Ireland and Merrion Stockbrokers Limited Merrion Stockbrokers Limited fined €200,000 by the Central Bank of Ireland in respect of failings pursuant to the Fitness and Probity regime. On 12 December 2017, the Central Bank of Ireland (the ‘Central Bank’) fined Merrion Stockbrokers Limited (‘Merrion’) €200,000 and reprimanded it for a breach of section 21 of the Central Bank Reform Act 2010 (the ‘2010 Act’). Merrion has admitted this breach, which...

AI Analysis

The Central Bank of Ireland (CBI) fined Merrion Stockbrokers Limited €200,000 on 12 December 2017 for breaching section 21 of the Central Bank Reform Act 2010 by failing to implement adequate systems and controls under the Fitness and Probity (F&P) regime from 1 December 2011 to at least April 2015. This first-ever enforcement action against a firm for section 21 violations underscores firms' primary responsibility for ongoing due diligence on Controlled Functions (CFs) and Pre-Approval Controlled Functions (PCFs), signaling heightened CBI scrutiny on governance and accountability post-financial crisis.

What Changed

This 2017 enforcement does not introduce new regulatory changes but enforces existing requirements under the F&P regime, established via the Central Bank Reform Act 2010 and effective from 1 December...
Firms must maintain adequate systems and procedures for initial and ongoing due diligence to ensure CFs/PCFs meet F&P Standards (fitness: competence, integrity; probity: honesty).
Ongoing monitoring beyond initial checks, with written records and centralized documentation for each individual.
Accurate classification of roles as CFs/PCFs; failure here constituted a breach. No subsequent statutory changes are noted in the publication, but it reinforces that firms bear ultimate...

Suggested Considerations

Develop/improve written policies and procedures for initial and ongoing due diligence on CFs/PCFs, including centralized records per individual.
Conduct thorough due diligence at appointment and continuously monitor compliance with F&P Standards; maintain demonstrable records.
Ensure accurate CF/PCF classification for all relevant roles (e.g., executive directors, finance heads, client advisors).
Implement monitoring systems to detect changes in fitness/probity and report to CBI if Standards are breached.
Board-level oversight: Review and remediate gaps, as post-2016 Merrion Board did.

Key Dates

1 December 2011

- Fitness and Probity regime effective; Merrion's breach period begins

Late 2014 DEADLINE

- Management buy-out and new Board appointed; initial compliance improvements start

24 April 2015

- Merrion implements first written F&P policies and procedures

2016

- CBI inspection identifies breaches

12 December 2017

- CBI imposes €200,000 fine and reprimand via settlement agreement; investigation closed

Compliance Impact

Urgency: Medium - While from 2017, this foundational enforcement remains highly relevant for ongoing F&P obligations, with risks of fines/reprimands during CBI inspections (as in Merrion's 2016 review). It matters because firms hold primary accountability for a regime designed post-crisis to prevent unfit individuals in key roles; non-compliance exposes entities to significant reputational, financial (€200k precedent), and operational risks, especially amid evolving governance scrutiny.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance Authorisation & Licensing

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