Senior Managers / Governance

What Changed

• - Large associations, associations recognised as being of public utility and foundations are now subject to the accounting regime applicable to “medium‑sized undertakings” under the amended...
• Annual accounts for affected entities must include a non‑abridged balance sheet, a profit and loss account (at least in abridged format), and notes to the accounts containing disclosures required by...
• Affected entities must use statutory LRCS layouts for the balance sheet and profit and loss account and file their annual accounts in classic format with the Luxembourg Trade and Companies Register...
• Large associations, public‑utility associations and foundations remain exempt from the mandatory use of the Standard Chart of Accounts (Plan Comptable Normalisé – PCN) and from eCDF standard data...
• Affected entities may voluntarily adopt the PCN; if they do not adopt PCN, they must maintain an internal chart of accounts and ensure robust, documented mapping between internal accounts and...

Suggested Considerations

• Identify all Luxembourg associations, public‑utility associations and foundations within or related to the group that are impacted by the Law of 7 August 2023 and confirm their size classification (small, medium‑sized, large) and whether they fall under the “medium‑sized undertakings” regime.
• Review existing accounting policies, charts of accounts and annual accounts formats for affected entities to ensure alignment with LRCS statutory layouts, including non‑abridged balance sheet, appropriate profit and loss format, and required notes disclosures.
• Decide at governing‑body level whether each affected entity will voluntarily adopt the PCN or maintain an internal chart of accounts, documenting the rationale, governance approvals and compliance impacts of the chosen option.
• Where PCN is not adopted, design, implement and document a robust mapping from the internal chart of accounts to the statutory LRCS balance sheet and profit and loss layouts, ensuring audit‑ready documentation and traceability.
• Update accounting systems and reporting tools for affected entities to support LRCS statutory layouts, consistent layout adaptations, and classic‑format filing with the RCS, including necessary changes to interfaces and data capture.

Key Dates

References

• [1] cnc.lu/en/publication-of-qa-cnc-26-038/
• [2] linkedin.com/posts/stephane-schirrecker-6b52912_new-qa-cn...
• [3] cssf.lu/en/2026/06/cssf-communique-concerning-certain-cnc...
• [4] cssf.lu/en/
• [5] cnc.lu/en/publication-of-non-financial-information-and-di...
• [6] cssf.lu/wp-content/uploads/cssf18_698eng.pdf
• [7] cssf.lu/en/regulatory-framework-for-investment-fund-manag...
• [8] cssf.lu/en/2023/06/publication-of-qas-by-the-commission-d...

What Changed

• - Large not‑for‑profit associations, associations recognised as being of public utility and foundations are required to prepare annual accounting documents consisting at a minimum of annual accounts...
• These entities fall within the regime applicable to “medium‑sized undertakings”, which drives the required content and level of detail of their annual accounts (balance sheet, profit and loss account...
• The law and the CNC Q&A confirm that large associations, public‑utility associations and foundations are not legally required to use the Standard chart of accounts (Plan comptable normalisé, PCN) or...
• Although exempt from mandatory PCN use and eCDF standard data collection, these entities must still file their annual accounts with the Luxembourg Trade and Companies Register (RCS) using statutory...
• Large associations, public‑utility associations and foundations are exempt from the obligation to file the PCN trial balance (balance générale) via the eCDF platform, even though they may still...

Suggested Considerations

• Identify whether the organisation qualifies as a large association, an association recognised as being of public utility or a foundation under the Law of 7 August 2023, and document the classification decision with reference to Articles 18, 36 and 52 of that law.
• Update internal accounting policies to require annual accounts to be prepared in accordance with the regime for undertakings referred to in Article 47 LRCS, including minimum content (balance sheet, profit and loss account and notes) and disclosure requirements.
• Decide formally whether to adopt the PCN on a voluntary basis or to maintain an internal chart of accounts, and record this decision in accounting governance documents approved by the board or governing body.
• Where PCN is not adopted, design and implement a detailed and documented mapping from internal general ledger accounts to LRCS statutory balance sheet and profit and loss layouts to ensure accurate preparation and filing of annual accounts.
• Review and, where necessary, redesign annual accounts templates to comply with LRCS layouts while making only permitted adaptations (for example, titles and subtotals) that maintain clarity, comparability and consistency over time.

Key Dates

References

• [1] cnc.lu/en/publications/doctrine/qa-cnc-26-038-large-assoc...
• [2] cnc.lu/en/publication-of-qa-cnc-26-038/
• [3] cnc.lu/publications/doctrine/qa-cnc-26-038-grandes-associ...
• [4] cnc.lu/publication-du-qa-cnc-26-038/
• [5] cssf.lu/en/
• [6] linkedin.com/posts/stephane-schirrecker-6b52912_new-qa-cn...
• [7] cssf.lu/en/2026/06/cssf-communique-concerning-certain-cnc...
• [8] cssf.lu/en/publication-data/

What Changed

• - Counterparties whose average aggregate notional amount (AANA) of non-centrally cleared OTC derivatives falls below the EUR 8 billion threshold will no longer be required to exchange initial margin...
• The current framework, under which below-threshold counterparties are exempt from initial margin for new trades but must continue to exchange initial margin for pre-existing “legacy” contracts, will...
• Article 28(1) of Delegated Regulation (EU) 2016/2251 will be amended to explicitly extend the exemption from initial margin requirements to outstanding contracts where one of the two counterparties...
• The RTS introduce a clearer operational framework for entry into and exit from the initial margin regime based on the annual AANA calculation for March–May, including scenarios where one or both...
• Once a counterparty falls below the EUR 8 billion threshold under the revised rules, firms will be permitted to terminate related initial margin processes, including ceasing ongoing calculation,...

Suggested Considerations

• Map all EMIR in-scope entities within the group and identify those whose AANA of non-centrally cleared OTC derivatives is close to or below the EUR 8 billion threshold, to assess which relationships may benefit from the expanded exemption.
• Review current collateral and margin frameworks to identify legacy contracts where initial margin is still being exchanged solely because the regime requires continuation despite the counterparty having fallen below the EUR 8 billion threshold.
• Prepare an internal policy update so that, once the RTS enter into force, initial margin requirements are switched off for counterparties below the EUR 8 billion threshold on both new and existing uncleared OTC derivatives, subject to group risk appetite.
• Update EMIR margin procedures and AANA calculation processes to ensure accurate annual determination of whether each counterparty is above or below the EUR 8 billion threshold, including documentation of the March–May calculation methodology.
• Review and amend collateral agreements, credit support annexes (CSAs) and associated legal documentation to incorporate the revised treatment for below-threshold counterparties, including terms for stopping margin exchange and potentially releasing segregated collateral.

Key Dates

References

• [1] esma.europa.eu/press-news/esma-news/joint-rts-amendments-...
• [2] esma.europa.eu/sites/default/files/library/esas_2019_20_-...
• [3] esma.europa.eu/document/emir-rts-various-amendments-bilat...
• [4] esma.europa.eu/sites/default/files/2026-08/ESA_2026_07_Fi...
• [5] esma.europa.eu/press-news/consultations
• [6] ashurst.com/en/insights/financial-services-speedread-4-au...
• [7] esma.europa.eu/press-news/esma-news/esas-publish-joint-qa...
• [8] sip.lex.pl/komentarze-i-publikacje/poradniki/sprawozdanie...

What Changed

• - The EDMC now has a new Chair (Nicholas Segal) and Deputy Chair (Peter King), replacing Sir William Blair and Philip Marsden whose terms ended in July 2026.
• The appointments are the outcome of an external recruitment process commenced in October 2025, aligned with the EDMC’s governance framework and five‑year renewable term structure.
• The scope of the EDMC’s remit continues to cover contested enforcement decisions across the Bank’s statutory regimes: Prudential Regulation, Financial Market Infrastructures, Resolution,...
• The EDMC Procedures, published in January 2024, remain the operative framework for how contested enforcement cases are handled, including panel constitution, hearing processes, and decision‑making...
• The EDMC continues to operate with functional separation from investigation teams and the Bank’s executive, preserving independence in contested enforcement decisions.

Suggested Considerations

• Map all existing and potential enforcement exposures to the EDMC’s statutory remit, covering prudential regulation, FMI, resolution, securitisation, wholesale cash distribution, critical third parties and notes issuance.
• Review internal enforcement‑response playbooks to ensure they explicitly recognise the EDMC’s independent role and the January 2024 EDMC Procedures, including how contested cases will be heard and decided.
• Update board and senior management briefings on BoE/PRA enforcement to reflect the change in EDMC leadership and likely implications for contested case strategy and settlement versus contest decisions.
• Assess ongoing and anticipated enforcement matters for which the firm might contemplate contesting; incorporate the EDMC’s composition and procedures into litigation and regulatory strategy planning.
• Train Legal, Compliance and relevant business teams on the practical implications of the EDMC Procedures (panel size, hearing processes, written and oral representations, decision timelines) with scenario‑based exercises for contested cases.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] finreg.aoshearman.com/Bank-of-England-Establishes-Enforce...
• [3] 3vb.com/sir-william-blair-appointed-chair-of-bank-of-engl...
• [4] bankofengland.co.uk/about/people/court-of-directors/gover...
• [5] mondovisione.com/media-and-resources/news/bank-of-england...
• [6] elischolar.library.yale.edu/cgi/viewcontent.cgi?article=1...
• [7] talents.studysmarter.co.uk/companies/the-bank-of-england/...
• [8] treasury.govt.nz/sites/default/files/2018-04/rbnz-rev-ban...

What Changed

• - Introduces principles‑based requirements for vertically integrated market structures involving affiliations between derivatives clearing organizations, designated contract markets, swap execution...
• Amends Part 37 to set additional governance, conflict‑management, and structural requirements for swap execution facilities where the SEF is affiliated with an intermediary or trading entity.
• Amends Part 38 to impose enhanced conflict‑of‑interest and self‑regulatory safeguards for designated contract markets that are affiliated with futures commission merchants or proprietary trading...
• Amends Part 39 to clarify and strengthen requirements on derivatives clearing organizations in group structures where the DCO is affiliated with intermediaries or other market participants, including...
• Amends regulation 1.52 (accounts and records; FCM supervisory requirements) to reflect the heightened expectations placed on futures commission merchants that are part of vertically integrated...

Suggested Considerations

• Identify and map all affiliate relationships involving CFTC‑regulated entities within your group (DCO, DCM, SEF, FCM, SD/MSP, trading entities, market makers) and document how roles and control relationships could create actual or perceived conflicts of interest.
• Conduct a gap analysis of existing governance, conflicts‑of‑interest, information‑barrier, and supervision frameworks against the anticipated principles‑based expectations for vertically integrated structures under Parts 37, 38, 39 and regulations 1.52 and 1.55.
• Review and, where necessary, enhance board‑level and committee‑level oversight arrangements for affiliated entities to ensure independent decision‑making on listing, clearing, rule enforcement, membership, and client treatment where affiliates are involved.
• Assess current customer risk disclosures, including those required under regulation 1.55 for FCMs, to determine whether affiliate relationships and related conflicts are adequately described, and prepare draft revisions that could be implemented if the new requirements are finalized.
• Engage legal, compliance, and business stakeholders for each affected entity (DCO, DCM, SEF, FCM, trading entity) to prepare a coordinated comment letter to the CFTC explaining operational impacts, potential unintended consequences, and recommendations on specific rule language.

Key Dates

References

• [1] cftc.gov/PressRoom/PressReleases/9274-26
• [2] reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=30...
• [3] cftc.gov/LawRegulation/DoddFrankAct/Dodd-FrankProposedRul...
• [4] comments.cftc.gov/FederalRegister/Proposed.aspx?Type=List...
• [5] public-inspection.federalregister.gov/2023-28745.pdf
• [6] content.next.westlaw.com/practical-law/document/If6afd4b4...
• [7] public-inspection.federalregister.gov/2012-00935.pdf?1329...
• [8] cftclaw.com

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - Issuers domiciled in Germany with securities admitted to trading on an organised market in Germany must publish an announcement (“Hinweisbekanntmachung”) specifying the exact date and internet...
• The announcement on annual financial information must be published no later than four months after the end of each financial year and must be issued before the first public availability of the...
• Annual financial information must be made publicly available on the internet in addition to its disclosure in the Company Register (Unternehmensregister), and the announcement obligation relates...
• Issuers must publish a half‑yearly financial report no later than three months after the end of each reporting period.
• Failure to publish financial reports or the required announcements, or failure to do so within the prescribed periods, constitutes a contravention of the WpHG and exposes the issuer to administrative...

Suggested Considerations

• Map all WpHG‑related periodic reporting obligations (annual, half‑yearly, and any interim or ad‑hoc requirements) into a documented compliance calendar with responsible owners and system reminders well ahead of statutory deadlines.
• Implement a formal procedure to prepare, approve, and publish “Hinweisbekanntmachungen” that clearly specify the date and internet address of annual financial information, ensuring publication before the first public availability of the annual report and within four months of financial year‑end.
• Establish controls to guarantee that annual financial information is published both in the Company Register and on the issuer’s website, and that these publications are synchronised with the required announcements.
• Design and enforce a process for producing and publishing half‑yearly financial reports within three months after the end of each reporting period, including clear timelines for drafting, audit/review (where relevant), management approval, and technical website publication.
• Conduct a gap analysis of current financial reporting and disclosure procedures against WpHG requirements to identify any missing steps, unclear responsibilities, or weaknesses in escalation mechanisms for imminent deadline breaches.

Key Dates

References

• [1] bafin.de/SharedDocs/Veroeffentlichungen/DE/Massnahmen/40c...
• [2] bafin.de/SharedDocs/Downloads/DE/Angebotsunterlage/Leo_In...
• [3] bafin.de/EN/home_node_en.html
• [4] northdata.com/Leo%20International%20Precision%20Health%20...
• [5] finanznachrichten.de/nachrichten-2026-03/68026196-leo-int...
• [6] globenewswire.com/news-release/2026/05/22/3300302/0/en/le...
• [7] globenewswire.com/news-release/2026/06/12/3311244/0/en/le...

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - Licensed corporations must ensure that firewall protection and network monitoring are implemented and effective across critical infrastructure, including file servers, domain controllers, email...
• Licensed corporations must maintain up‑to‑date operating systems and antivirus software, avoiding end‑of‑life or unpatched environments that materially increase vulnerability to ransomware and other...
• Firms must enforce strong user access and privileged account controls, including robust administration of system admin accounts, least‑privilege access models, periodic reviews of access rights, and...
• Firms must implement secure password management practices, prohibiting the storage of credentials in unencrypted files and enforcing strong password policies and technical controls for credential...
• Remote access must be subject to strict controls, including secure configuration of VPN or other remote access solutions, need‑to‑have access principles, and monitoring for unusual or unauthorized...

Suggested Considerations

• Conduct a comprehensive cybersecurity risk assessment and control gap analysis across all critical systems, including trading platforms, email servers, domain controllers, file servers, and accounting systems.
• Implement and regularly review firewall configurations and network monitoring tools to ensure effective protection and detection capabilities for internal and external network traffic.
• Upgrade all operating systems and antivirus software to supported, fully patched versions and establish formal patch and vulnerability management procedures with defined timelines and testing steps.
• Establish and enforce robust user access management policies, including least‑privilege access, periodic recertification of user and privileged accounts, and logging and monitoring of admin activities.
• Implement secure password management solutions and technical controls, eliminating unencrypted storage of credentials and enforcing strong password complexity, rotation, and multi‑factor authentication where applicable.

Key Dates

References

• [1] apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announce...
• [2] fxnewsgroup.com/tag/luk-fook/
• [3] apps.sfc.hk/edistributionWeb/api/circular/list-content/ci...
• [4] charltonslaw.com/legal/newsletters/574/sfc-enforcement-ac...
• [5] davispolk.com/insights/client-update/hong-kong-sfc-calls-...
• [6] apps.sfc.hk/edistributionWeb/gateway/EN/circular/intermed...
• [7] sfc.hk/-/media/EN/files/IS/publications/Cybersecurity-the...
• [8] reuters.com/legal/litigation/hong-kong-securities-regulat...

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - The AMF’s decision reinforces that asset managers must maintain continuous compliance with their authorisation conditions, but isolated overreach by a person not listed as an executive officer was...
• Firms must have procedures that identify and manage conflicts of interest, including conflicts arising from links with a parent company and from the overlapping functions of directors and financial...
• Asset managers must ensure continuity of human resources and align remuneration practices for financial managers with the applicable regulations, the approved programme of activity, and internal...
• Firms must disclose to investors management-fee retrocessions paid to distributors and must be able to justify any claimed enhancement of the service provided.
• Information provided to investors and prospects must be clear, accurate, and not misleading, including in marketing materials.

Suggested Considerations

• Review the firm’s authorisation file, governance map, and executive-officer appointments to confirm that actual decision-making powers match the AMF-approved organisational structure.
• Update conflicts-of-interest procedures to capture conflicts arising from parent-company relationships, cross-directorships, and shared finance leadership roles.
• Test whether staffing levels and succession arrangements ensure continuity of human resources for control functions and key operational roles.
• Reassess remuneration arrangements for financial managers to verify consistency with the firm’s programme of activity, internal procedures, and regulatory requirements.
• Verify that all distributor retrocessions are fully disclosed to investors and that any claim of enhanced service is documented with evidence.

Key Dates

References

• [1] amf-france.org/en/news-publications/news-releases/enforce...
• [2] amf-france.org/sites/institutionnel/files/pdf/77659/en/Th...
• [3] finascope.fr/english/reglementation/la-commission-des-san...
• [4] kroll.com/en/publications/financial-compliance-regulation...
• [5] kroll.com/en/insights/publications/financial-compliance-r...
• [6] amf-france.org/en/news-publications/news-releases/enforce...
• [7] opalesque.com/712766/AMF_ruling_underscores_personal_acco...
• [8] navacelle.law/historical-sanctions-financial-markets-auth...

What Changed

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

Suggested Considerations

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

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - The SEC has formally announced that Principal Deputy Director of the Division of Enforcement Sam Waldon will leave the agency effective 31 July 2026, ending more than 14 years of service at the SEC.
• The Enforcement Division will have a new Principal Deputy Director (named in the release), who will assume responsibility for overseeing day‑to‑day enforcement operations, supervision of regional and...
• Waldon’s departure follows his recent tenure as Acting Director and Principal Deputy Director during a period of strategic restructuring of the Enforcement Division, including creation of multiple...
• The transition occurs against the backdrop of earlier Commission decisions to rescind delegation of formal order authority to the Enforcement Director, returning formal order approvals to the...
• Under Waldon’s leadership, the Division emphasized “quality over quantity” cases, focusing on traditional “core” areas (insider trading, accounting and disclosure fraud, market manipulation,...

Suggested Considerations

• Review and update enforcement‑risk assessments to reflect the forthcoming change in SEC Enforcement Division Principal Deputy Director, with particular focus on core fraud, insider trading, and accounting‑related risks.
• Re‑evaluate internal investigation, Wells process, and SEC engagement protocols to ensure they align with current Enforcement Manual practices and anticipate any refinements under the new Principal Deputy Director.
• Brief senior management, boards, and audit committees on the SEC enforcement leadership transition and its implications for prioritization of accounting, disclosure, and gatekeeper cases, particularly in light of the SOX‑focused enforcement unit.
• Reassess crypto and digital asset exposure, including ongoing or threatened SEC matters, to account for potential shifts in enforcement posture under new leadership while maintaining preparedness for fraud‑focused actions involving retail investors.
• Reinforce insider trading surveillance, market‑abuse monitoring, and controls around material non‑public information, reflecting the Enforcement Division’s continued emphasis on traditional trading‑related misconduct.

Key Dates

References

• [1] bloomberg.com/news/articles/2026-03-20/sec-lays-out-polic...
• [2] sec.gov/newsroom/press-releases/2024-162
• [3] angelinvestorsnetwork.com/regulatory-compliance/sec-enfor...
• [4] sec.gov/newsroom/press-releases/2026-27-sec-announces-enf...
• [5] reuters.com/world/us/sec-focus-traditional-cases-under-ne...
• [6] hklaw.com/en/insights/publications/2026/04/sec-speaks-are...
• [7] morganlewis.com/pubs/2026/04/securities-enforcement-round...
• [8] ainvest.com/news/sec-enforcement-inflection-point-directo...

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - The PRA proposes a more detailed, codified description of the end‑to‑end Part VIII process for friendly society amalgamations and transfers, organised into stages such as planning and preparation,...
• The PRA intends to update and integrate its Statement of Policy on insurance business transfers to explicitly cover friendly society amalgamations and transfers under the Friendly Societies Act 1992,...
• For transfers, the PRA sets out circumstances in which it may exercise its statutory discretion to dispense with the requirement for the transferee friendly society to hold a member vote, subject to...
• The PRA proposes to clarify when it may direct the transferor and/or transferee to appoint an independent actuary to report on the proposed transfer’s effects on members and policyholders, including...
• Firms undertaking a Part VIII transfer will be expected to provide robust actuarial analysis and supporting evidence demonstrating that statutory preclusion grounds are not met and that the transfer...

Suggested Considerations

• Map all current and planned amalgamations or transfers involving friendly societies against the proposed five‑part process (planning, analysis, member engagement and votes, application/notifications/representations, confirmation meetings) and identify procedural and evidential gaps.
• Review internal policies, governance frameworks, and transaction playbooks for friendly society restructurings to ensure they reflect the PRA’s codified expectations under Part VIII of the Friendly Societies Act 1992, including early regulatory engagement and documentation standards.
• Develop or enhance internal guidance for actuaries and finance teams on the required actuarial analysis for Part VIII transfers, ensuring the ability to evidence that preclusion grounds are not met and that the transaction is in the interests of members and policyholders.
• Implement procedures to identify all classes of members and policyholders affected by proposed amalgamations or transfers, assess whether their existing terms and conditions are preserved or materially changed, and document the implications for benefit levels and distribution.
• For partial transfers, establish a formal framework to assess and document how the interests of members remaining with the transferor society are considered, including any continuing obligations, capital support, and benefit expectations.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/202...
• [2] prarulebook.co.uk/guidance/statements-of-policy/the-pras-...
• [3] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [4] milliman.com/en/insight/PRA-policy-statement-insurance-bu...
• [5] skadden.com/insights/publications/2026/04/pra-proposes-fu...
• [6] pwc.co.uk/financial-services/assets/pdf/pra-finalises-new...
• [7] regulationtomorrow.com/2026/05/pra-cp8-26-funded-reinsura...
• [8] cliffordchance.com/insights/resources/blogs/insurance-ins...

What Changed

• - ESMA is explicitly positioned as the central supervisory authority for selected capital‑markets activities, with national competent authorities (NCAs) expected to operate within a more formalised...
• Supervisory objectives are reframed towards risk‑based and adaptive supervision, meaning firms should expect more differentiated supervisory intensity based on risk profile, business model, and...
• The paper supports proportionate and transparent funding for ESMA, indicating a future where firms may be subject to EU‑level supervisory levies or fee structures in addition to national regimes,...
• AFM and AMF call for independent, transparent, and accountable EU‑level supervisory governance, foreshadowing changes to ESMA’s decision‑making bodies, oversight processes, and accountability...
• Data centralisation is identified as a core enabler, implying a stronger move towards EU‑wide data hubs, harmonised reporting formats, and central access for ESMA to transaction, position, and...

Suggested Considerations

• Review and update the firm’s supervisory engagement strategy to include structured, proactive engagement with ESMA (not just NCAs), anticipating more direct interactions, thematic reviews, and data requests at EU level.
• Assess current risk‑assessment and risk‑reporting frameworks to ensure they are compatible with a risk‑based and adaptive supervisory approach, including the ability to demonstrate how your firm identifies, measures, and mitigates emerging risks and new business models.
• Conduct a gap analysis of data architecture and regulatory reporting, focusing on data quality, standardisation, and ability to feed into centralised EU data hubs; plan upgrades to systems, controls, and data governance to support ESMA‑level data centralisation.
• Prepare for potential changes in supervisory levies and funding, by modelling the impact of EU‑level ESMA fees in addition to national contributions and incorporating them into medium‑term budgeting and pricing strategies.
• Review governance arrangements, including board oversight, senior management responsibilities, and internal escalation processes, to ensure they can meet higher expectations of independent, transparent, and accountable governance under an ESMA‑centric model.

Key Dates

References

• [1] afm.nl/en/sector/themas/over-het-toezicht-en-beleid-van-d...
• [2] amf-france.org/sites/institutionnel/files/private/2025-01...
• [3] amf-france.org/sites/institutionnel/files/private/2025-01...
• [4] afm.nl/~/profmedia/files/publicaties/2021/position-paper-...
• [5] amf-france.org/en/news-publications/amfs-eu-positions/fre...
• [6] loyensloeff.com/insights/news--events/news/looking-ahead-...
• [7] elibrary.imf.org/downloadpdf/view/journals/002/2011/204/a...
• [8] regulationtomorrow.com/2026/01/afm-publishes-supervisory-...

What Changed

• As the 21 July 2026 CSSF notice is an enforcement publication (not a new rule), it does not introduce new regulatory requirements; it applies existing Transparency Law obligations.
• Issuers with Luxembourg as home Member State under the Transparency Law must publish annual financial reports within the statutory deadline, typically within four months of financial year-end, and...
• Failure to publish periodic financial information within the required time limits can result in administrative fines imposed by the CSSF under Article 25(2) of the Transparency Law.
• The CSSF will publicly disclose administrative fines imposed on issuers, including naming the issuer and the amount, in line with Article 26b of the Transparency Law.
• Issuers retain the right to challenge CSSF decisions before the Luxembourg Administrative Court within the period set by Article 27 of the Transparency Law (three months from notification), but...

Suggested Considerations

• Map all Transparency Law obligations applicable to your entity, including periodic (annual and half‑yearly) reporting and ongoing disclosure of regulated information, and document them in a compliance obligations register.
• Review and, where necessary, strengthen internal processes to ensure annual and half‑yearly financial reports are prepared, approved, and published within statutory deadlines for issuers with Luxembourg as home Member State.
• Implement a formal disclosure governance framework assigning clear responsibilities to senior management and the board for oversight of regulated information, including escalation procedures where delays or issues arise.
• Establish a calendar of regulatory reporting and publication deadlines, including internal cut‑off dates and contingency plans, and ensure it is monitored by compliance and finance functions.
• Conduct a gap analysis of prior disclosures (financial reports, major holdings notifications, inside information) to confirm that all items required under the Transparency Law have been published correctly and on time; remediate any deficiencies promptly.

Key Dates

References

• [1] offshorealert.com/transnet-soc-ltd-e15k-fine/
• [2] opensanctions.org/entities/NK-YGvBVghMpKt3CGHYCGfn2N/
• [3] cssf.lu/wp-content/uploads/S_31_TRA_151121_en.pdf
• [4] iol.co.za/news/south-africa/2026-07-09-transnet-blacklist...
• [5] cssf.lu/wp-content/uploads/S_17_PSF_SP_JTC-Luxembourg-S.A...
• [6] siu.org.za/special-tribunal-freezes-r20-3-million-in-asse...
• [7] centralbank.ie/regulation/how-we-regulate/international-f...
• [8] cssf.lu/wp-content/uploads/FAQ_International_financial_sa...

What Changed

• - The CSSF demonstrates that it is prepared to impose administrative sanctions directly on members of the board of directors of electronic money institutions, not just on the institution as a legal...
• Board members of Luxembourg‑authorised electronic money institutions are now clearly exposed to personal regulatory liability for governance, risk management and safeguarding failures under the CSSF...
• This enforcement confirms that CSSF Circular 26/906 on central administration, internal governance and risk management for payment institutions and electronic money institutions is not only a formal...
• The sanction underscores CSSF expectations that the supervisory body (board of directors) must ensure sound and prudent management, continuity of the institution and protection of its reputation, and...
• The case signals a stricter enforcement posture by the CSSF towards the payments and e‑money sector, aligning its expectations and enforcement intensity more closely with bank‑equivalent governance...

Suggested Considerations

• Review and map the institution’s current governance framework, board charter and committee mandates against the detailed requirements of CSSF Circular 26/906, including central administration, board composition, responsibilities and functioning.
• Ensure that the board of directors collectively has the required expertise, independence, diversity and time commitment, and that this is documented and periodically reassessed in line with CSSF expectations.
• Update board policies to explicitly assign responsibility for strategy, risk appetite, safeguarding of client funds, information security, outsourcing, conflicts of interest and AML/CFT, and ensure these responsibilities are effectively discharged and evidenced.
• Confirm that the institution’s central administration, decision‑making centre and administrative centre are physically located in Luxembourg and that members of the management body are sufficiently present on site, as required under the governance framework.
• Establish or reinforce the “three lines of defence” model by clearly separating business units, control functions (compliance and risk) and internal audit, and ensure reporting lines to the board are independent and robust.

Key Dates

References

• [1] klgates.com/Luxembourgs-CSSF-Circular-26/906-on-Central-A...
• [2] finconduit.com/resources/cssf-circular-26-906-emi-pi-gove...
• [3] loyensloeff.com/insights/news--events/news/circular-cssf-...
• [4] elvingerhoss.lu/insights/publications/circular-cssf-26906...
• [5] cssf.lu/en/2026/03/communication-to-the-investment-fund-i...
• [6] financialcrime.lu/2026/01/20/CSSF-Circular-26-906/

What Changed

• - Article 8 funds must describe how the investment strategy actually enables the fund to meet the environmental and/or social characteristics disclosed to investors.
• If an Article 8 fund relies mainly on an exclusion strategy, the CSSF expects the exclusion policy to be detailed enough for investors to understand how the stated characteristics are being met.
• Article 9 funds cannot rely only on an exclusion strategy; they must invest in sustainable investments and use a positive selection process that demonstrates alignment with Article 2(17) SFDR.
• For Article 9 funds, the CSSF expects sustainable-investment status to be maintained at all times, including on an ongoing basis during the life cycle of the fund.
• Financial market participants should make available the methodology used to determine whether an investment is a sustainable investment, including any thresholds used for a pass-fail approach.

Suggested Considerations

• Review all Article 8 pre-contractual disclosures to confirm that the stated investment strategy clearly explains how the fund’s environmental or social characteristics are achieved.
• Strengthen any Article 8 exclusion-based strategy disclosures so they provide sufficient detail for investors to understand the connection between exclusions and the claimed sustainability characteristics.
• Reassess all Article 9 product classifications to confirm that the portfolio is built around qualifying sustainable investments, not only exclusions.
• Implement controls to verify that Article 9 holdings remain aligned with Article 2(17) SFDR on an ongoing basis throughout the fund lifecycle.
• Document and retain the internal methodology used to assess sustainable-investment status, including any thresholds, and ensure it can be provided to investors or supervisors upon request.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/FAQ-SFDR.pdf
• [2] bsp.lu/lu/publications/newsletters-newsflashes/new-cssf-f...
• [3] debevoise.com/-/media/files/pdf/faq_sfdr.pdf?rev=85b95600...
• [4] maples.com/knowledge/cssf-updates-sfdr-faq
• [5] elvingerhoss.lu/insights/publications/sustainable-finance...
• [6] cms.law/en/lux/legal-updates/CSSF-FAQ-on-Cross-Border-Dis...
• [7] mondaq.com/pdf/1362226.pdf
• [8] cms.law/en/content/download/739359/file/From%202025%20to%...

What Changed

• - The PRA has explicitly reinforced that FSCS Liabilities and FSCS Fee Tariff data are core prudential reporting metrics, and misreporting them may both impede risk assessment and cause underpayment...
• The enforcement action clarifies that failures to consult the PRA Rulebook and applicable guidance on FSCS coverage and fee tariff methodologies constitute a breach of Fundamental Rule 2 (due skill,...
• The PRA has signalled that the absence of effective written processes for calculating regulatory data, and lack of clear accountability, internal oversight, and challenge over those calculations,...
• The case demonstrates that remediation submissions are subject to the same accuracy and governance expectations as original returns, and that errors in purported remediation will be treated as...
• The PRA’s Early Account Scheme (EAS), formally incorporated into its enforcement policy in January 2024, is now clearly positioned as a mechanism that can materially reduce penalties where firms...

Suggested Considerations

• Review and map all FSCS Liabilities and FSCS Fee Tariff reporting obligations under the PRA Rulebook and applicable guidance, ensuring the firm’s methodology aligns with regulatory definitions of FSCS-covered liabilities.
• Conduct a detailed end-to-end review of regulatory reporting processes for FSCS data, including data sourcing, calculations, validations, and submission workflows, to identify and remediate control weaknesses.
• Develop and document formal, robust written procedures that govern the calculation and validation of FSCS Liabilities and FSCS Fee Tariff data, including change-control processes for methodologies.
• Assign clear ownership and accountability for FSCS-related reporting within the firm’s governance framework, ensuring named individuals or functions are responsible for accuracy, completeness, and timely submission.
• Strengthen internal oversight, challenge and review mechanisms over prudential and FSCS-related reporting, including regular independent checks by risk, compliance or internal audit.

Key Dates

References

• [1] lexology.com/library/detail.aspx?g=e13d06f0-5743-4ad2-bbe...

What Changed

• - The UN sanctions committee amended the list of sanctioned individuals, companies, and organizations relating to the Democratic Republic of Congo on 16 July 2026.
• The change is directly applicable in Switzerland, so firms cannot wait for a separate Swiss implementing act before acting on the updated list.
• SECO updated the Swiss sanctions database SESAM on 17 July 2026 and published the update on its website.
• Financial intermediaries must implement the prohibitions set out in the ordinance, including freezing the assets of sanctioned persons.
• Financial intermediaries must report the affected business relationships to SECO.

Suggested Considerations

• Review sanctions screening results immediately against the updated Congo-related list in SESAM and any internal watchlists to identify matching clients, counterparties, and beneficial owners.
• Freeze assets and block prohibited dealings involving newly designated persons, companies, or organizations as required by the ordinance.
• Report affected business relationships to SECO in line with the sanctions ordinance requirements.
• Perform enhanced internal clarifications under Article 6 GwG/AMLA whenever a sanctions hit or other red flags create suspicion.
• File an immediate suspicious activity report with the Money Laundering Reporting Office under Article 9 GwG/AMLA if doubts cannot be resolved.

Key Dates

References

• [1] finma.ch/de/news/2026/07/20260720-sr-946-231-12/
• [2] eda.admin.ch/en/newnsb/KbHRHJgit-lofkgs08y9Q
• [3] uvek.admin.ch/de/newnsb/KbHRHJgit-lofkgs08y9Q
• [4] admin.ch/fr/newnsb/KbHRHJgit-lofkgs08y9Q
• [5] un.org/german/de/media/16079
• [6] fiu.gov.ai/financial-and-targeted-sanctions/sanction-notices
• [7] gov.im/news/2026/jul/17/sanctions-lists-update-democratic...
• [8] ch.marketscreener.com/boerse-nachrichten/un-verhaengen-sa...

What Changed

• * The AMF advocates removal of many existing “Member State options” in SRD in order to achieve greater harmonisation of shareholder rights and issuer–shareholder interactions across the EU, reducing...
• The AMF reiterates that long‑term shareholder engagement should remain a core objective of the revised SRD and that the framework should explicitly facilitate ongoing dialogue between issuers and...
• The AMF supports the development of hybrid general meetings with real‑time remote voting as a structural feature of EU listed company governance, in line with the digitalisation of the economy and...
• The AMF considers “closed‑door” general meetings (with no in‑person or remote shareholder participation) to be incompatible with SRD objectives and proposes that such formats be prohibited in the...
• The AMF proposes that “virtual‑only” general meetings should remain possible but be subject to tighter regulation at EU level, including a requirement to obtain shareholders’ approval on a regular...

Suggested Considerations

• Monitor the European Commission’s SRD review process closely, including the forthcoming legislative proposal and any related impact assessments, as these will determine concrete new obligations on meeting formats, shareholder identification and intermediaries’ duties.
• Map current practices for general meetings (physical, hybrid, virtual‑only) against the AMF’s positions and SRD II requirements, and assess the extent to which existing procedures depend on national options or flexibilities that may be removed in a revised SRD.
• For intermediaries and custodians, assess existing cross‑border voting, information transmission and shareholder identification processes to identify areas of fragmentation or reliance on local practices that may be affected by EU‑level harmonisation.
• Engage with industry associations and local regulators to provide practical feedback on operational challenges (e.g. complex custody chains, vote confirmation, cut‑off times) so that future SRD revisions reflect realistic implementation constraints.
• Update internal regulatory change logs and risk assessments to flag the SRD review as an emerging structural change to shareholder‑rights processes, with potential impacts on IT systems, contracts with intermediaries, and investor communications.

Key Dates

References

• [1] amf-france.org/fr/actualites-publications/positions-ue-de...
• [2] amf-france.org/en/news-publications/news/amf-encourages-f...
• [3] societegenerale.lu/fileadmin/user_upload/sgss_regulatory_...
• [4] ici.org/system/files/2026-05/2605-cl-ec-consultation-on-s...

What Changed

• - Regulation (EU) 2024/2809 amends elements of the Prospectus Regulation, and those amendments fully took effect on 5 June 2026.
• The Prospectus Regulation continues to apply as the core EU framework for prospectuses, with the CBI acting as the competent authority in Ireland for approval matters.
• The CBI states that it must decide on a prospectus application within 90 working days of receipt of the initial application, or 100 working days for an SME.
• If the review exceeds the applicable working-day limit, the CBI will cease reviewing the prospectus without approving it and will notify the issuer, offeror, or person seeking admission to trading.
• A one-off extension of 30 working days may be requested before the original 90 working-day period lapses, including for SMEs.

Suggested Considerations

• Review all prospectus templates, disclosure checklists, and approval workflows against the amended Prospectus Regulation provisions that became fully applicable on 5 June 2026.
• Reassess transaction timetables to ensure the planned filing date allows for the 90 working day or 100 working day CBI review window, plus any needed extension request.
• Submit any request for a one-off 30 working day extension before the original approval period expires, and include the required reference details in the request.
• Confirm whether any current or planned issuance qualifies as an SME transaction, because the approval deadline differs from the standard timetable.
• Update internal sign-off procedures so legal, finance, and compliance teams can demonstrate that prospectus materials are prepared in line with the CBI’s statutory mandate and the amended EU framework.

Key Dates

References

• [1] centralbank.ie/regulation/industry-market-sectors/securit...
• [2] centralbank.ie/regulation/industry-market-sectors/securit...
• [3] lexology.com/library/detail.aspx?g=3a44879f-3ddb-4233-974...
• [4] byrnewallaceshields.com/news-and-recent-work/publications...
• [5] irishstatutebook.ie/eli/2022/si/135/made/en/print
• [6] irishstatutebook.ie/eli/2019/si/380/made/en/pdf
• [7] williamfry.com/wp-content/uploads/2023/10/Securities-Regu...

What Changed

• - Introduced a two‑step ICAAP/ILAAP submission model under the SREP: (1) annual submission of the main “ICAAP & ILAAP package” by 15 March and (2) continuous, year‑round submission of any new or...
• Shortened the standard annual deadline for ICAAP/ILAAP information from 31 March to 15 March, reducing the preparation and governance window by roughly two weeks versus prior practice.
• Confirmed that the clarifications apply from the SREP 2025 cycle onwards, with a general transition approach for 2025 and limited transitional flexibilities for banks whose internal processes cannot...
• Required inclusion of two distinct, concise documents within the annual packages: a “Capital Adequacy Statement” and a “Liquidity Adequacy Statement” reflecting the management body’s formal view on...
• Clarified governance expectations around capital and liquidity planning, including regular updates of governance frameworks to reflect external conditions and the submission of a complete risk...

Suggested Considerations

• Review existing ICAAP and ILAAP submission calendars and internal governance timelines and formally reset them to ensure core packages can be prepared, approved by the management body, and submitted by 15 March each year.
• Design and implement a documented two‑step submission process, including procedures for continuous, year‑round identification, approval and transmission to the ECB of any new or materially updated ICAAP/ILAAP‑relevant documents.
• Develop, approve and embed the new Capital Adequacy Statement and Liquidity Adequacy Statement, ensuring they reflect the management body’s signed‑off view on adequacy and are supported by clear references to ICAAP/ILAAP analyses and results.
• Update ICAAP and ILAAP governance frameworks to reflect ECB expectations, including explicit roles and responsibilities, escalation paths, periodic reviews triggered by external developments, and Board‑level oversight of capital and liquidity planning.
• Compile and maintain a comprehensive risk inventory covering both normative and economic perspectives, and ensure it is aligned with business models, risk appetite frameworks, recovery plans, stress testing programmes and SREP submissions.

Key Dates

References

• [1] bankingsupervision.europa.eu/ecb/pub/pdf/ssm.ICAAP_ILAAP_...
• [2] regulationtomorrow.com/2025/02/ecb-clarification-on-icaap...
• [3] blogs.pwc.de/en/risk/article/247557/ecb-clarification-on-...
• [4] pwcplus.de/de/article/247557/risk-blog-ecb-clarification-...
• [5] linkedin.com/pulse/ecb-clarification-icaaps-ilaaps-respec...
• [6] linkedin.com/posts/la-partners-sarl_ecb-clarification-on-...
• [7] linkedin.com/posts/deloitte_ecb-bankingrisklab-activity-7...
• [8] managementsolutions.com/en/publications-and-events/regula...

What Changed

• - The PRA proposes to delete in full the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part of the PRA Rulebook, removing the specific ring‑fencing continuity‑of‑services...
• The PRA will make consequential amendments to the Ring‑fenced Bodies Part to remove or adjust cross‑references, defined terms and obligations that are linked to the deleted Continuity of Provision of...
• The proposal effectively retires the bespoke continuity‑of‑services construct that was introduced when ring‑fencing was implemented (including detailed constraints on termination, suspension or...
• The consultation paper explains how the PRA intends to align ring‑fenced bodies’ continuity‑of‑services expectations with existing supervisory statements on operational continuity in resolution (for...
• The PRA invites stakeholders to comment on whether deleting the Continuity of Provision of Services Chapter, and relying on the broader operational continuity regime, still adequately protects the...

Suggested Considerations

• Assess the current use of the Continuity of Provision of Services Chapter in the Ring‑fenced Bodies Part within your firm’s ring‑fencing policies, procedures, contracts and governance, and identify all controls that explicitly rely on those rules.
• Prepare and submit a considered response to CP10/26 by 14 October 2026, addressing the practical impact of deleting the Continuity of Provision of Services Chapter, any residual areas of concern, and suggestions for guidance or transitional arrangements.
• Coordinate with group entities acting as permitted suppliers or critical service providers to ensure their OCIR documentation, service catalogues, TSAs and liquidity arrangements remain aligned with the ring‑fenced body’s continuity requirements in the absence of the deleted chapter.
• Monitor for the subsequent PRA policy statement that will follow CP10/26, and be prepared to implement any final rule changes, transitional provisions or clarifications on how ring‑fencing continuity expectations intersect with OCIR and operational resilience regimes.

Key Dates

References

• [1] bankofengland.co.uk/prudential-regulation/publication/201...
• [2] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [3] legislation.gov.uk/ukpga/2013/33/notes/division/4/data.xh...
• [4] freshfields.com/en/our-thinking/blogs/risk-and-compliance...
• [5] bankofengland.co.uk/-/media/boe/files/prudential-regulati...
• [6] regulationtomorrow.com/2015/05/the-implementation-of-ring...
• [7] bankofengland.co.uk/-/media/boe/files/prudential-regulati...

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

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

Suggested Considerations

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

Key Dates

References

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

What Changed

• - ESMA has started publishing annual market capitalisation figures and market capitalisation ratios for each EU Member State under its FASTER Directive mandate.
• The published figures are based on a harmonised methodology developed by ESMA in technical standards, using transaction data reported under MiFIR.
• Market capitalisation is calculated from shares admitted to trading on a regulated market or multilateral trading facility, with aggregation at the level of the issuer’s legal address in the relevant...
• The market capitalisation ratio is calculated as the Member State’s market capitalisation divided by the total market capitalisation of all Member States on the same date, expressed as a percentage.
• Member States whose market size exceeds 1.5% of total EU market capitalisation for four consecutive years are subject to specific withholding tax relief-related requirements.

Suggested Considerations

• Compliance teams should map whether any serviced Member State may approach or exceed the 1.5% threshold over a rolling four-year period and flag jurisdictions that could trigger special withholding tax relief consequences.
• Tax operations teams should align withholding tax relief workflows with the ESMA-published ratios so that jurisdictional eligibility assessments use the current official figures.
• Data and controls teams should document the calculation source, methodology, and reconciliation process for any internal use of ESMA market capitalisation data.
• Investment firms and intermediaries should review client-facing tax-relief processes to ensure they can respond to changes in Member State status under FASTER.
• Market-data and regulatory-reporting teams should prepare for annual updates by building a recurring review process around each ESMA publication cycle.

Key Dates

References

• [1] esma.europa.eu/sites/default/files/2025-10/ESMA12-1406959...
• [2] esma.europa.eu/sites/default/files/2025-06/ESMA12-1406959...
• [3] cnmv.es/DocPortal/DocFaseConsulta/CESR/CP_MarketCap_ENen.pdf
• [4] esma.europa.eu/press-news/consultations/consultation-meth...
• [5] czasopisma.uni.lodz.pl/fipf/article/view/27784
• [6] icmagroup.org/market-practice-and-regulatory-policy/repo-...
• [7] lexisnexis.com/en-gb/legal/news/esma-finalises-methodolog...
• [8] ec.europa.eu/transparency/documents-register/api/files/C(...

What Changed

• - The AMF has formalised and publicly communicated its enforcement findings and expectations on AML/CFT and AEI, turning past inspection outcomes into forward‑looking supervisory benchmarks for 2026...
• AML/CFT frameworks must move from generic and incomplete documentation to precise, activity‑specific procedures that clearly reflect the firm’s business model, products, distribution channels and...
• AML/CFT risk mapping must be personalised, complete, and demonstrably linked to the level and type of customer due diligence and ongoing monitoring applied; purely theoretical or non‑operational risk...
• Firms must implement robust oversight and documented supervision of delegates, distributors, service providers and other third parties involved in KYC or onboarding, rather than relying on unverified...
• Client, beneficial owner and source‑of‑funds information must be systematically collected, stored, updated and traceable, including clear identification and ongoing review of politically exposed...

Suggested Considerations

• Review and comprehensively update AML/CFT written policies and procedures to ensure they are complete, precise and clearly adapted to the firm’s specific activities, products, distribution channels and client profiles.
• Redesign AML/CFT risk mapping to be firm‑specific, cover all relevant money laundering and terrorist financing risks, and explicitly link identified risks to the intensity of customer due diligence and transaction monitoring measures applied.
• Implement a formalised framework for the oversight of delegates, distributors, service providers and other third parties performing KYC or onboarding tasks, including documented due diligence, contractual obligations, and periodic testing of their AML/CFT controls.
• Conduct a gap analysis of client and beneficial owner data collection, storage and updating processes to ensure full traceability of KYC information, including clear documentation of PEP identification and periodic review.
• Enhance due diligence procedures for investment and divestment operations involving fund assets, including documented risk assessments and escalation paths for unusual or higher‑risk transactions.

Key Dates

References

• [1] financialcrime.lu/2026/06/15/AMF-Enforcement-in-AML-CFT/
• [2] cssf.lu/wp-content/uploads/PSF-SP_2026_AML_conference.pdf
• [3] linkedin.com/posts/financialcrime-lu_amf-fra-amf-enforcem...
• [4] bradymartz.com/aml-cft-compliance-in-2026-staying-ahead-o...
• [5] amf-france.org/en/news-publications/news/autorite-des-mar...
• [6] freshfields.com/en/our-thinking/blogs/risk-and-compliance...
• [7] imf.org/en/topics/financial-integrity/amlcft
• [8] federalregister.gov/documents/2026/04/10/2026-07033/anti-...

What Changed

• - CCPs must base admission criteria on a comprehensive risk assessment of the risks posed by clearing members and ensure the criteria reflect those risks.
• CCPs must consider whether clearing members have sufficient financial resources to meet obligations arising from participation in the CCP.
• CCPs must assess whether clearing members have access to reliable credit, liquidity, and foreign exchange facilities commensurate with the scale and nature of their clearing activity.
• CCPs must examine the clearing member’s operational capacity to meet CCP obligations, including readiness to support clearing operations and margin obligations.
• CCPs must take account of the client clearing activity of a clearing member, including the relative importance of that activity and the member’s ability to meet margin requirements if clients default.

Suggested Considerations

• CCPs should review their current admission criteria to ensure they are explicitly tied to a documented assessment of risks posed by each clearing member type.
• CCPs should update membership rulebooks and onboarding procedures to reflect the RTS requirement to consider financial resources, operational capacity, and liquidity support arrangements.
• CCPs should build or refine documented methodologies for assessing NFC clearing members’ ability to meet margin and default fund obligations.
• CCPs should ensure sponsored membership frameworks clearly define how the sponsor’s support, the sponsored member’s profile, and relevant risk controls are assessed for eligibility purposes.
• CCPs should prepare to publish clear admission criteria, application steps, timelines, required documentation, and explanations for any category-specific requirements.

Key Dates

References

• [1] esma.europa.eu/sites/default/files/2026-07/ESMA91-1505572...
• [2] esma.europa.eu/sites/default/files/2025-10/ESMA91-1505572...
• [3] eachccp.eu/wp-content/uploads/2026/01/EACH-Response-ESMA-...
• [4] isda.org/a/o4vgE/ISDA-Response-to-ESMA-on-CCP-Participati...
• [5] esma.europa.eu/press-news/esma-news/esma-consults-ccp-par...
• [6] asam.org/asam-criteria
• [7] deutsche-boerse.com/resource/blob/59972/5a6ef04dd55bcedf5...
• [8] drs-als.com/esma-publishes-guidelines-for-ccp-colleges/

What Changed

• (From the enforcement notice itself, there are no new rules; the impact is interpretative and enforcement‑related.)
• CSSF confirms that authorised electronic money institutions are subject to active supervisory and enforcement scrutiny, including public administrative sanctions for regulatory breaches.
• The sanction demonstrates that failures which may appear operational or procedural can nonetheless result in monetary fines and public naming, reinforcing the need for robust compliance frameworks in...
• The case is likely to be assessed by CSSF in light of the new governance, risk management and safeguarding expectations introduced under CSSF Circular 26/906 for payment and e‑money institutions,...
• The public nature of the sanction underscores CSSF’s use of transparency as a deterrent tool, increasing reputational risk for firms that do not comply with licensing, governance, reporting or...

Suggested Considerations

• Review the CSSF sanction against PingPong Europe S.A. and identify which categories of requirements (e.g. governance, safeguarding of client funds, reporting, outsourcing, internal controls) were implicated, then map these to your own control framework.
• Conduct a gap analysis against CSSF Circular 26/906, focusing on central administration, internal governance, risk management, and safeguarding of client funds for payment and e‑money institutions.
• Update policies, procedures and internal control documentation governing payment services, e‑money issuance, safeguarding (segregation, reconciliations), outsourcing and IT connectivity to ensure alignment with CSSF Circular 26/906.
• Ensure that a clearly designated member of the management body holds documented responsibility for oversight of safeguarding arrangements and compliance with CSSF requirements for payment and e‑money institutions.
• Implement or enhance daily reconciliations and robust segregation of client funds accounts, supported by periodic internal reviews and testing of safeguarding controls.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/S_3_EME_PingPong_Europe_S.A._0...
• [2] linkedin.com/pulse/enforcement-actions-against-private-fu...
• [3] opensanctions.org/datasets/lu_administrative_sanctions/
• [4] caceis.com/regwatch-2026/february-2026
• [5] klgates.com/Luxembourgs-CSSF-Circular-26/906-on-Central-A...
• [6] cssf.lu/en/Document/administrative-sanction-of-2-march-2026/
• [7] cssf.lu/en/Document
• [8] international.pingpongx.com/trust-center

What Changed

• - The SEC is reinstating the Retail Fraud Working Group within the Division of Enforcement to concentrate resources on identifying and pursuing misconduct that disproportionately harms retail...
• The Working Group will support stronger coordination with state and federal enforcement partners, including improved information-sharing and joint efforts.
• The SEC’s enforcement priorities now explicitly include offering fraud, accounting and disclosure fraud, insider trading, market manipulation, fraud by foreign actors, and fiduciary breaches...
• The SEC is signaling that it will distinguish between honest mistakes and actual fraud, but will still assess whether errors caused investor harm and calibrate remedies accordingly.
• The initiative reinforces the SEC’s broader retail-investor focus, building on the earlier Retail Strategy Task Force and related retail-protection efforts.

Suggested Considerations

• Review retail-facing sales, disclosure, and supervision controls for gaps that could create exposure under SEC fraud theories.
• Reassess product approval, marketing review, and suitability procedures for offerings sold to individual investors.
• Test whether financial reporting, performance, and valuation disclosures could be challenged as misleading or incomplete.
• Strengthen surveillance for insider trading, market manipulation, and suspicious transaction patterns involving retail accounts.
• Reevaluate client-asset safeguarding, custody, and trade-allocation controls to prevent misuse or misappropriation.

Key Dates

References

• [1] hklaw.com/en/insights/publications/2026/05/sec-enforcemen...
• [2] thecorporatecounsel.net/blog/2026/05/sec-enforcement-new-...
• [3] stblaw.com/about-us/publications/view/2026/05/14/sec-watc...
• [4] morganlewis.com/pubs/2026/06/securities-enforcement-round...
• [5] sec.gov/fact-sheets/sec-protects-retail-investors-markets
• [6] sec.gov/newsroom/speeches-statements/woodcock-remarks-mfa...
• [7] linkedin.com/posts/timothynewman_yesterday-newly-appointe...
• [8] investor.gov/introduction-investing/investing-basics/role...

What Changed

• - Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
• During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
• All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
• Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
• Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.

Suggested Considerations

• Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
• Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
• Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
• Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
• Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.

Key Dates

References

• [1] reuters.com/world/uk/uks-fca-says-parts-motor-finance-red...
• [2] fca.org.uk/publications/policy-statements/ps26-3-motor-fi...
• [3] paulhastings.com/insights/client-alerts/update-fca-confir...
• [4] content.govdelivery.com/accounts/UKFCA/bulletins/3fe085b
• [5] cliffordchance.com/insights/resources/blogs/regulatory-in...
• [6] aoshearman.com/en/insights/fca-consultation-on-motor-fina...
• [7] mpamag.com/uk/news/general/fca-motor-finance-redress-sche...

What Changed

• - ESMA has clarified, through enforcement, that CRAs must ensure complete, accurate and up‑to‑date data is reported to ESMA across all relevant CRA reporting channels (including the European Rating...
• ESMA has reinforced that errors limited to regulatory reporting data (and not directly affecting published ratings) can still constitute material breaches of the CRA Regulation, demonstrating that...
• ESMA has indicated that group reporting arrangements (where one CRA entity reports on behalf of others in the group) must have clear documentation of responsibilities, validation processes, and...
• ESMA has emphasized that regulatory reporting frameworks must include robust policies, procedures and internal control mechanisms, and that deficiencies in these frameworks constitute distinct...
• ESMA has signalled that negligence, rather than intentional misconduct, is sufficient to trigger significant fines under the CRA Regulation, and that both aggravating and mitigating factors will be...

Suggested Considerations

• Conduct a comprehensive review of all ESMA‑related reporting processes to ensure that data submitted to ESMA (including rating information, historical performance data, rating changes, and other CRA regulatory reports) is complete, accurate, and kept up‑to‑date at all times.
• Map and document all responsibilities for ESMA reporting within the CRA group, ensuring that where one entity reports on behalf of others, the allocation of roles, ownership of data, and validation steps is explicitly defined, approved, and regularly reviewed.
• Perform a gap analysis of existing regulatory reporting policies, procedures, and internal control mechanisms against CRA Regulation requirements and ESMA supervisory expectations, and update documentation to remove ambiguities and outdated provisions.
• Implement or strengthen data validation and reconciliation controls over submissions to the European Rating Platform and ESMA’s central repositories, including automated checks for missing ratings, non‑withdrawn ratings, incorrect rating actions, and inconsistencies in historical performance data.
• Establish a formal governance process for changes to regulatory reporting frameworks, ensuring regular review, independent challenge by compliance or risk functions, and clear escalation routes for identified data quality issues or control failures.

Key Dates

References

• [1] fxnewsgroup.com/forex-news/regulatory/esma-imposes-e2-1m-...
• [2] esma.europa.eu/sites/default/files/2026-07/ESMA43-8572387...
• [3] mnb.hu/en/pressroom/press-releases/press-releases-2017/es...
• [4] pinsentmasons.com/out-law/news/esma-fines-moodys-in-germa...
• [5] fintech.global/2021/03/30/esma-fines-moodys-e3-7m-for-fai...
• [6] reuters.com/article/business/eu-fines-moodys-for-failing-...
• [7] finextra.com/pressarticle/86859/esma-fines-moodys-37-mill...
• [8] moodys.com/uploadpage/Mco%20Documents/SCL0042_Policy%20Re...

What Changed

• - BaFin reinforces that issuers on an organised market must publish inside information “without delay” under Article 17(1) MAR; failure to do so constitutes an administrative offence subject to...
• The publication clarifies the maximum fine levels for MAR ad‑hoc disclosure breaches: up to €2.5 million or 2% of total turnover, whichever is higher, for legal persons.
• BaFin reiterates half‑yearly financial reporting obligations under the German Securities Trading Act (WpHG): issuers must publish half‑yearly financial reports no later than three months after the...
• In addition to the report itself, firms must publish a separate announcement (“Hinweisbekanntmachung”) specifying when and where the half‑yearly financial report will be publicly available (including...
• BaFin confirms that failure to publish financial reports and the corresponding announcements, or to do so within the prescribed period, is a WpHG contravention and subject to enforcement.

Suggested Considerations

• Review and, where necessary, update internal MAR Article 17(1) ad‑hoc disclosure policies to ensure that all inside information is identified promptly and disclosed to the market without undue delay.
• Implement or strengthen inside information identification and escalation procedures, ensuring front‑office, finance, strategy and legal functions can rapidly flag potentially price‑sensitive, non‑public information to compliance and the executive board.
• Conduct a gap analysis of past and upcoming financial reporting cycles (annual and half‑yearly) to confirm that all reports and associated announcements have been published within the WpHG three‑month deadlines and in the prescribed form.
• Establish a formal reporting calendar that clearly tracks statutory deadlines for half‑yearly financial reports and “Hinweisbekanntmachungen”, with responsibility assigned to named owners in finance, legal and investor relations.
• Review and update disclosure committee charters or equivalent governance structures to ensure clear accountability for MAR‑relevant decisions, including documentation of the assessment of inside information and any delay decisions.

Key Dates

References

• [1] bafin.de/SharedDocs/Veroeffentlichungen/EN/Massnahmen/40c...
• [2] bafin.de/SharedDocs/Veroeffentlichungen/DE/Massnahmen/40c...
• [3] bafin.de/EN/die-bafin/die-bafin_node_en.html
• [4] bafin.de/EN/die-bafin/publikationen-daten/jahresbericht/j...
• [5] policyrix.com/news/2026-07-06/germany-bafin-steps-up-enfo...
• [6] handelsblatt.com/unternehmen/industrie/bafin-batteriehers...
• [7] bafin.de/EN/PublikationenDaten/Jahresbericht/Jahresberich...
• [8] jdsupra.com/legalnews/bafin-publishes-guidelines-for-high...

What Changed

• - MAS reaffirmed its willingness to hold senior management personally accountable where they fail to ensure their institution complies with MAS regulations, as illustrated by reprimands against...
• MAS demonstrated continued zero tolerance for trading-related offences under the Securities and Futures Act (SFA), supporting criminal prosecutions that resulted in imprisonment and substantial fines...
• MAS confirmed that Major Payment Institution (MPI) licences can and will be revoked where inspections reveal significant weaknesses in risk management, conflict-of-interest policies, and...
• MAS signalled continued priority on AML/CFT supervision and enforcement by imposing a $300,000 composition penalty on a licensed trust company (Padang Trust Singapore Pte.
• MAS underscored its ongoing focus on insider trading and market abuse by imposing a civil penalty on an individual for insider trading in shares of a Singapore-listed (now delisted) company.

Suggested Considerations

• Review and, where necessary, enhance senior management and board-level oversight frameworks to ensure that responsibilities for MAS regulatory compliance are clearly allocated, documented, and evidenced (e.g. through committee charters, management information, and challenge records).
• Conduct a targeted compliance review at fund managers and other CMS licence holders to assess adherence to MAS regulations, focusing on areas previously cited in MAS enforcement actions (e.g. internal controls, client asset safeguards, and recordkeeping).
• For Major Payment Institutions and other payment providers, perform a comprehensive gap analysis of risk management frameworks, conflict-of-interest policies, and compliance with MAS Guidelines on Outsourcing, including due diligence, ongoing monitoring, and intra-group/related-party arrangements.
• Implement or strengthen formal governance around the accuracy and completeness of all information submitted to MAS (licence applications, regulatory returns, inspection responses), including sign-off controls, documentation standards, and verification procedures.
• For licensed trust companies and other AML/CFT-obliged entities, review and update AML/CFT policies, customer due diligence (CDD) and enhanced due diligence (EDD) procedures, ongoing monitoring, and suspicious transaction reporting processes in line with MAS Notices and Guidelines.

Key Dates

References

• [1] mas.gov.sg/news/media-releases/2026/key-enforcement-actio...
• [2] linkedin.com/pulse/mas-imposes-over-20m-penalties-aml-mar...
• [3] mas.gov.sg/regulation/enforcement/enforcement-actions
• [4] ncontracts.com/nsight-blog/enforcement-actions-roundup-ap...
• [5] sec.gov/newsroom/press-releases/2026-34
• [6] opensanctions.org/datasets/sg_mas_enforcement_actions/
• [7] reedsmith.com/articles/investigations-and-enforcement-tre...
• [8] fincen.gov/news/enforcement-actions

What Changed

• - The ECB has reaffirmed that institutions using internal ratings-based (IRB) approaches must apply their approved internal models consistently for expected loss calculation on defaulted retail and...
• The ECB has underscored that the IRB shortfall (difference between expected loss and accounting provisions) must be correctly calculated and deducted from regulatory capital whenever expected loss...
• The ECB has classified intentional failure to apply approved internal models to expected loss calculations as a “severe” breach under its Guide to the method of setting administrative pecuniary...
• The enforcement action confirms the ECB’s readiness to use its sanctioning powers under Article 18 of Council Regulation (EU) No 1024/2013 against internal-model users that misreport capital due to...
• The case highlights that miscalculation of expected loss and IRB shortfall over multiple reporting periods, even without an explicit capital ratio breach of minima, can be sanctioned where capital...

Suggested Considerations

• Review and confirm that all regulatory capital calculations, including expected loss and IRB shortfall for defaulted exposures, consistently use the approved internal models as authorised by the ECB or national competent authority.
• Map and reconcile the internal-model implementation across risk systems, finance, and regulatory reporting to ensure that there are no manual overrides, alternative methods, or parallel calculations that deviate from the approved model specifications.
• Strengthen model risk governance by ensuring that any proposed changes to expected loss methodologies, including for defaulted retail and corporate portfolios, are formally approved by the competent authority before being used in regulatory capital reporting.
• Implement robust controls and periodic testing within Finance, Risk, and Regulatory Reporting functions to detect and prevent misapplication or non-application of approved internal models, with clear escalation procedures for identified discrepancies.
• Ensure that the calculation of IRB shortfall (difference between expected loss and accounting provisions) is independently validated and appropriately deducted from CET1 capital in accordance with CRR and ECB internal models guidance.

Key Dates

References

• [1] zandersgroup.com/en/insights/blog/ecbs-revised-guide-to-i...
• [2] corporatefinanceinstitute.com/resources/career-map/sell-s...
• [3] bankingsupervision.europa.eu/ecb/pub/pdf/ssm.supervisory_...
• [4] finanssivalvonta.fi/globalassets/fi/saantely/maarayskokoe...
• [5] bis.org/basel_framework/chapter/CRE/53.htm?inforce=202201...
• [6] managementsolutions.com/sites/default/files/publicaciones...
• [7] finalyse.com/blog/banking/ecb-revised-guide-to-internal-m...
• [8] bankingsupervision.europa.eu/framework/legal-framework/pu...

What Changed

• - The FCA is consulting on clearer scope boundaries for the Consumer Duty to confirm that wholesale, business‑to‑business activities that do not shape retail consumer outcomes should normally be out...
• The FCA will provide case studies and examples of “grey areas” to illustrate when activities are, and are not, caught by the Duty, particularly for early‑chain and wholesale‑only firms.
• The FCA is clarifying accountability in multi‑firm arrangements, confirming that each firm is responsible for its own activities, can rely on other firms to meet their obligations where appropriate,...
• The FCA plans to reduce duplication of obligations across distribution chains, including refining how the “look‑through” concept and co‑manufacturing apply where firms do not directly interact with...
• The FCA is narrowing the territorial scope of the Consumer Duty so that business conducted for genuinely non‑UK customers will generally be out of scope, aligning with the principle that local...

Suggested Considerations

• Map all business lines and activities to identify which are genuinely wholesale, early‑chain or business‑to‑business, and assess where the firm does or does not “shape consumer outcomes” at the end of the chain.
• Review existing Consumer Duty scoping decisions for activities such as market making, custody, safeguarding and other wholesale services, and prepare to adjust those decisions in line with FCA case studies and clarified boundaries.
• Re‑evaluate cross‑border business conducted for non‑UK clients to determine which products and services may fall outside the Consumer Duty under the proposed narrowed territorial scope, and document the basis for this classification.
• Analyse multi‑party distribution chains and co‑manufacturing arrangements to clearly delineate responsibilities, reliance points and escalation mechanisms where other firms are expected to meet their Consumer Duty obligations.
• Update product governance and Consumer Duty frameworks to distinguish between “manufacturers” and supporting firms, ensuring manufacturers continue to meet full Duty requirements while supporting firms apply Principle 12 and cross‑cutting rules proportionately.

Key Dates

References

• [1] skadden.com/insights/publications/2025/10/fca-clarifies-a...
• [2] freshfields.com/en/our-thinking/briefings/2025/10/fca-ref...
• [3] linkedin.com/posts/cgregulatorysolutions_fca-compliance-c...
• [4] simmons-simmons.com/en/publications/cmn92abw80056ukto0v9d...
• [5] stepchange.org/policy-and-research/fca-consultation-new-c...
• [6] fca.org.uk/publications/consultation-papers/cp21-13-new-c...
• [7] traverssmith.com/knowledge/knowledge-container/consumer-d...
• [8] fca.org.uk/markets/strengthening-wholesale-markets

What Changed

• - CSSF has published its 2025 supervisory disclosure covering supervisory measures and administrative penalties taken during the year.
• The publication serves as a public register-style disclosure of enforcement outcomes, increasing transparency around CSSF supervision and sanctioning activity.
• A related 2025 CSSF administrative sanction shows that AML/CFT non-compliance can result in a reprimand under the amended Luxembourg AML/CFT Law.
• The 28 July 2025 sanction confirms that CSSF can act where firms fail to maintain adequate professional AML/CFT obligations and related internal controls.

Suggested Considerations

• Review the firm’s AML/CFT control framework against the Luxembourg AML/CFT Law provisions that can trigger CSSF reprimands or sanctions, including governance, monitoring, and escalation controls.
• Verify that suspicious activity detection, investigation, and escalation procedures are documented, implemented, and tested for effectiveness.
• Reassess whether internal controls are sufficient to demonstrate timely compliance with professional AML/CFT obligations under CSSF supervision.
• Update remediation tracking to ensure supervisory findings are closed out promptly and supported by evidence of corrective action.
• Brief senior management on the reputational impact of public supervisory disclosures and ensure that recurring weaknesses are escalated to the board.

Key Dates

References

• [1] cssf.lu/wp-content/uploads/S_49_B_X_280725_en.pdf
• [2] elvingerhoss.lu/insights/publications/international-sanct...
• [3] cssf.lu/wp-content/uploads/FAQ_International_financial_sa...
• [4] cssf.lu/en/supervisory-disclosure/
• [5] cssf.lu/en/regulatory-framework/page/6/
• [6] linkedin.com/pulse/enforcement-actions-against-private-fu...
• [7] cliffordchance.com/content/dam/cliffordchance/PDFDocument...
• [8] cssf.lu/wp-content/uploads/2025-AML-CFT-conference-dedica...