Wealth & Private Banking

Key dates

2025-01-01

Beginning of the general period identified by the SEC during which the charged entities allegedly filed Forms ADV containing material misrepresentations; the publication does not specify an exact start date.

2026-08-27

The SEC announced the charges, disclosed the requested remedies, stated that the 38 ERA filings had been removed from its website, and referenced its related investor alert.

Suggested considerations

• Compliance teams may wish to perform a documented, line-by-line validation of Form ADV Part 1 and applicable Form ADV Part 2 disclosures, including business addresses, telephone numbers, websites, ownership, control persons, regulatory status, assets, private funds, clients, and service providers.
• Firms should consider retaining contemporaneous evidence supporting material Form ADV representations, such as lease or office records, corporate and ownership documents, fund records, audited financial statements, auditor engagement evidence, and records supporting reported assets and advisory activities.
• ERA and registered adviser compliance programs may wish to establish independent verification of counterparties' SEC registration or ERA status through the Investment Adviser Public Disclosure system and should avoid treating an SEC filing, certificate, or website badge as conclusive proof of legitimacy.
• Firms that market investment advice to individuals should consider reviewing whether their regulatory status, Form ADV disclosures, and marketing materials accurately describe whether they are registered, exempt reporting, or otherwise authorized to provide services to retail investors.
• Compliance teams may wish to investigate repeated or highly similar ownership structures, numerical disclosures, addresses, telephone numbers, websites, auditor names, or filing patterns across related advisers as potential indicators of coordinated fraudulent filings.
• Firms should consider escalating unanswered SEC requests for records and preserving relevant books, records, communications, websites, and filing-support materials, because the SEC expressly relied on alleged failures to substantiate Form ADV information.
• Private fund sponsors and allocators may wish to verify that purported fund audits were performed by identifiable independent public accounting firms with appropriate federal or state registration or licensing, rather than relying solely on statements in Form ADV.
• Financial-crime and onboarding teams may wish to incorporate the SEC's PAUSE list, investor alerts, foreign-jurisdiction indicators, website authentication checks, and independent corporate-registration checks into risk-based due diligence for purported U.S. advisers.

What changed

This publication announces enforcement complaints rather than a new rule or generally applicable filing requirement. The SEC alleges violations of Section 204(a) of the Investment Advisers Act of 1940, which governs adviser records and reports including Form ADV, and Section 207, which prohibits untrue statements or omissions in applications and reports filed under the Act. The SEC seeks permanent injunctions, conduct-based injunctions preventing the defendants from filing Forms ADV as exempt reporting advisers, and civil penalties.

Key dates

2026-07-24

The FCA conducted the Attest quantitative survey of 666 UK adults aged 18 to 40 who owned investments or were considering buying investments within 12 months.

2026-08-27

The FCA published the press release and research findings on young investors' trust in AI.

Suggested considerations

• Compliance teams may wish to map all AI use cases across investment research, recommendations, suitability, appropriateness assessments, client communications, and financial promotions, distinguishing general-purpose tools from systems specifically configured to provide financial advice.
• Firms should consider assessing whether any AI-generated output amounts to a personal recommendation, regulated advice, or a financial promotion under the Financial Services and Markets Act 2000 and the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, rather than relying on the technology's general-purpose label.
• Firms using AI in regulated activities should consider applying the same suitability, appropriateness, customer understanding, disclosure, record-keeping, oversight, and accountability standards that apply to equivalent human-led processes.
• Customer-facing communications may warrant clear explanation that general-purpose chatbot outputs are not FCA-regulated advice and do not themselves create entitlement to FSCS compensation or access to the Financial Ombudsman Service.
• Compliance teams may wish to test AI outputs for hallucinations, stale or unsupported sources, misleading performance claims, inappropriate personalisation, bias, and inadequate risk warnings, with escalation and human-review controls for higher-risk outputs.
• Firms should consider reviewing whether AI-generated content used in promotions complies with the FCA financial promotion restriction in section 21 of the Financial Services and Markets Act 2000 and applicable FCA financial-promotion rules.
• Governance reviews may include vendor due diligence, approved-use restrictions, audit trails, model-change monitoring, incident reporting, staff training, and controls preventing customers or staff from treating AI output as a substitute for regulated advice.
• Firms may wish to monitor the FCA's expected late-2026 publication on good and poor AI practice and any subsequent FCA, HM Treasury, or industry measures addressing advice-like outputs from general-purpose AI.

What changed

No binding regulatory requirement, rule, prohibition, or implementation deadline was introduced. The FCA clarified its current supervisory position that general-purpose AI chatbots are not regulated by the FCA where they respond to varied prompts and are not specifically established to provide financial advice, research, or decision-making support. By contrast, an AI tool specifically deployed to provide financial advice would be likely to fall within the FCA's remit and could engage the existing UK regulatory framework for regulated advice and financial promotions.

Key dates

2016-01-01

The period began during which the FCA found that the investor-visa scheme operated; the exact start date is not specified in the publication.

2019-01-01

The period ended during which the FCA found that the scheme operated; the exact end date is not specified in the publication.

2021-03-12

The FCA imposed restrictions preventing Dolfin from carrying on regulated activities, following concerns including its operation of the investor-visa funding scheme.

2021-06-01

Dolfin entered special administration; the exact date in June is not specified in the publication.

2022-02-17

The Home Office closed the Tier 1 investor visa route of entry to the UK.

2026-08-26

The FCA published the enforcement announcement concerning the bans, fines and Joukovski Decision Notice.

Suggested considerations

• Compliance teams may wish to review whether any product or client arrangement could create a misleading impression that a regulatory, immigration or other statutory investment threshold has been met when the client’s own qualifying capital is materially lower.
• Firms should consider testing the end-to-end governance of immigration-linked investment business, including approval of the business model, ownership and control disclosures, conflicts management, introducer due diligence, fee flows and oversight of connected or offshore entities.
• Firms may wish to reassess source-of-funds and source-of-wealth controls where client investments are supported by loans, circular funding, guarantees or funds provided by affiliated entities, and document why the resulting structure is consistent with the relevant immigration and financial-services requirements.
• Senior managers and boards should consider whether regulatory submissions, notifications and attestations fully disclose shadow directorships, controllers, beneficial ownership, related-party involvement and the true commercial purpose of client arrangements.
• Firms should consider conducting targeted reviews of historical investor-visa or residence-by-investment clients, including communications and files supplied to regulators or other public authorities, and escalating any potentially misleading statement or omission through the appropriate remediation and notification processes.
• Training and surveillance may be reviewed to ensure staff understand that conduct outside the core regulated service, including assistance with immigration-rule circumvention, can affect the firm’s and individuals’ integrity, fitness and propriety.
• Where third-party immigration agents or introducers are used, firms may wish to assess their incentives, remuneration, representations to clients, due-diligence records and ongoing monitoring, particularly where fees are unusually high or linked to visa approval.

What changed

This is a final enforcement outcome for Nagy and Maraj, not a new generally applicable rule or supervisory requirement. Both were prohibited from performing any function in relation to regulated activities; Nagy’s discounted penalty was £324,800, compared with an undiscounted £464,000, and Maraj’s discounted penalty was £122,000, compared with an undiscounted £174,300. Joukovski was issued a Decision Notice proposing a prohibition order, but the proposed action has no effect pending the Upper Tribunal’s determination.

Key dates

2021-09-01

ASIC's investigation into Edwards and associated entities commenced; the publication gives only September 2021 and does not specify a day.

2022-12-13

ASIC executed search warrants at Edwards's business premises and seized materials.

2025-01-22

The remaining court proceeding brought by Edwards that had delayed ASIC's review of seized materials was dismissed by consent.

2025-09-12

ASIC banned Edwards for 10 years under sections 920A and 920B of the Corporations Act 2001 from providing financial services, controlling an entity carrying on a financial services business, or performing functions involved in such a business.

2026-03-25

ASIC commenced NSW Supreme Court winding-up proceedings against the 12 companies and sought appointment of provisional liquidators.

2026-05-28

ASIC's disqualification of Edwards as a self-managed superannuation fund auditor took effect.

2026-08-19

ASIC's interlocutory application for appointment of provisional liquidators was heard before Justice Nixon.

2026-08-21

The NSW Supreme Court appointed Kathryn Evans and Vaughan Strawbridge of FTI Consulting as provisional liquidators of the 12 companies.

Suggested considerations

• Firms with exposure to the 12 companies should consider reviewing receivables, investments, security interests, guarantees, trust relationships and outstanding transactions, and preserving relevant records for engagement with the provisional liquidators.
• Investor-facing firms should consider identifying clients or funds exposed to the companies, suspending any further investor subscriptions or transfers involving the affected entities where legally and operationally appropriate, and assessing communications and complaint-handling requirements.
• Financial services licensees and professional firms that dealt with Edwards or the companies should consider checking the scope of their engagements, referral arrangements, client-money or custody controls, representations made to investors, and potential conflicts or undisclosed related-party transactions.
• Compliance teams may wish to verify that no person acting for the affected companies is relying on Edwards to provide financial services, control a financial services business or perform a function involved in carrying on such a business, given the 10-year prohibition under sections 920A and 920B of the Corporations Act 2001.
• Relevant firms should consider monitoring the NSW Supreme Court proceeding and the provisional liquidators' creditor and investor information portal ahead of the 2 November 2026 directions hearing.
• Persons holding potentially relevant information may wish to consider providing it to ASIC at Edwards.investigation@asic.gov.au and preserving documents relevant to the ongoing investigation.

What changed

The directors of the 12 companies no longer control their affairs to the extent provided by the Court's orders; the provisional liquidators are responsible for investigating and reporting on the companies' assets, liabilities, asset recoverability, solvency, likely creditor returns, suspected contraventions of the Corporations Act 2001 or ASIC Act 2001, and transactions requiring further investigation.

Key dates

2025-12-30

MAS issued the revised Notices FAA-N27, 508 and SFA 04-N24 and published its response to feedback.

2026-08-24

MAS published the circular and FAQs explaining the revised misconduct-reporting requirements and the discontinuation of the existing system.

2027-01-01 Deadline

The revised Notices FAA-N27, 508 and SFA 04-N24 take effect; the existing Notices FAA-N14, 504 and SFA 04-N11 are cancelled; and the existing misconduct reporting system is discontinued.

2027-01-22 Deadline

Default deadline for reporting qualifying pre-2027 misconduct matters that were not reported under the cancelled Notice, calculated as 21 calendar days after 1 January 2027, unless MAS permits a longer period in writing.

Suggested considerations

• Compliance teams may wish to map existing misconduct, incident, whistleblowing, investigation, HR and police-referral processes to the revised definition and categories of reportable misconduct.
• Firms should consider establishing a documented escalation test for when reasonable grounds to believe misconduct occurred arise, rather than waiting for a final investigation finding, and configuring workflow controls around the 21-calendar-day initial-reporting deadline.
• Firms may wish to obtain and operationalise the prescribed misconduct-report, investigation-report and update-report formats before the existing system is discontinued.
• Internal investigation procedures should be reviewed to ensure that the prescribed investigation information, supporting evidence, investigator assessment, corrective action and appeal information can be produced concurrently with the initial MAS report where an investigation has commenced.
• Police-report handling should be updated so that available police reports and required accompanying details are captured and submitted with the misconduct report, with subsequent police or criminal-proceeding developments tracked for update reporting.
• Firms should consider controls for providing representatives with copies of initial misconduct reports and subsequent updates within the prescribed timelines, including appropriate treatment of former representatives and confidentiality or privilege issues.
• A transitional review of open matters may be appropriate to identify cases where reasonable grounds arose before 1 January 2027 but no report was filed under the cancelled Notice; those matters may need to be reported by 22 January 2027, subject to any written extension from MAS.
• Record-retention policies, case-management systems and management information should be tested against the minimum five-year retention requirement and the requirement that electronic records remain accessible, retrievable and readable.

What changed

From 1 January 2027, Notices FAA-N27, 508 and SFA 04-N24 replace and cancel the existing Notices FAA-N14, 504 and SFA 04-N11. The initial misconduct report must generally be submitted within 21 calendar days after the firm has reasonable grounds to believe that reportable misconduct was committed or is likely to have been committed; a conclusive investigation finding is not required before reporting.

Key dates

2026-08-21

Proposal published in the Federal Register for public comment.

2026-10-05 Deadline

Written comments are due 45 days after Federal Register publication.

Suggested considerations

• Firms should assess each pool’s investor eligibility against the natural-person and non-natural-person requirements in proposed Regulation 4.13(a)(4), including the distinctions between qualified eligible persons and accredited investors.
• RIAs should review offering documents, subscription procedures, investor representations, and transfer controls to support the required reasonable belief at investment or conversion that all participants satisfy the applicable eligibility criteria.
• Compliance teams may wish to confirm that each relevant pool’s interests qualify for a Securities Act exemption and that U.S. marketing practices comply with the proposed restriction, including the Rule 506(c) exception.
• Eligible advisers should map Form PF obligations and determine whether existing SEC filings would satisfy the proposed condition that Form PF be filed where required.
• Firms should prepare to file or update electronic exemption notices with the NFA and maintain the proposed Regulation 4.13 annual affirmation, recordkeeping, disclosure, and statutory-disqualification representations.
• Managers operating both registered and exempt pools should assess the proposed Regulation 4.13(e)(2) communications and redemption-right requirements and identify whether any existing participants would require notice before a pool is operated as exempt.
• Small-pool operators should model eligibility using the proposed $800,000 aggregate threshold while continuing to monitor the 15-participant-per-pool limit and unchanged contribution exclusions.
• Managers relying on Staff Letter 25-50 should preserve evidence of current compliance and evaluate transition implications because the CFTC preliminarily proposes to supersede that relief if the rule is finalized.

What changed

Proposed Regulation 4.13(a)(4) would exempt an SEC-registered investment adviser from CPO registration for qualifying pools if the pool interests are exempt from Securities Act registration and are not publicly marketed in the United States, except that the marketing restriction would not apply to pools offered under SEC Rule 506(c) of Regulation D.

Key dates

2021-03-01

First Guardian Diversified Class and Growth Class became available to adviser-led members through Netwealth Super Accelerator Plus; the publication gives March 2021 rather than a specific day.

2022-12-01

First Guardian classes were closed to new investments; the publication gives December 2022 rather than a specific day.

2024-05-01

Falcon Capital froze redemptions, leaving approximately 1,080 NSMF members invested with holdings totalling about $100.7 million; the publication gives May 2024 rather than a specific day.

2025-12-17

APRA accepted a court-enforceable undertaking from Netwealth Superannuation Services addressing material weaknesses in its investment governance framework and practices.

2025-12-18

ASIC commenced Federal Court proceedings against Netwealth and accepted a court-enforceable undertaking requiring compensation of affected members.

2026-01-28

Netwealth credited compensation payments to affected members' superannuation accounts; ASIC reported that more than $100 million had been paid to over 1,000 investors in January 2026.

2026-08-20

The Federal Court made declarations that Netwealth contravened the Corporations Act in relation to First Guardian.

Suggested considerations

• Firms should consider mapping their investment-option onboarding and review processes against sections 912A(1)(a) and 912A(5A) of the Corporations Act 2001, including documenting how the trustee independently validates issuer-provided information.
• Compliance teams may wish to require documented evidence of independent enquiries into strategy, underlying assets, valuation methodology, leverage, related-party exposure, custody, redemption terms, liquidity and operational risks before an option is approved.
• Trustees should consider implementing risk-based ongoing monitoring, watch-list and escalation criteria for complex or high-risk options, with clear triggers for suspension, closure, member notification and review of future investment directions.
• Firms should consider testing whether product disclosure documents, investment menus, member communications and online materials accurately explain potential illiquidity and any limits or conditions affecting withdrawals or redemptions.
• Trustees may wish to review historical investment options that were onboarded between March 2021 and December 2022, or during comparable periods, to identify gaps in due diligence, monitoring, risk disclosure and remediation records.
• Compliance teams should consider preserving approval papers, committee minutes, independent research, issuer correspondence, risk assessments, liquidity analyses and member communications sufficient to demonstrate the basis for each onboarding and monitoring decision.
• Where material weaknesses are identified, firms should consider a documented remediation assessment covering member impact, compensation, disclosure correction, governance uplift and potential notification to ASIC, APRA or AFCA as appropriate.
• Trustees should consider whether their governance framework can evidence alignment with the best financial interests duty and applicable APRA prudential expectations, particularly when adding high-risk investments to a platform.

What changed

The publication records binding Federal Court declarations against Netwealth; it does not introduce a new statutory rule or generally applicable deadline. The relevant conduct was found to breach the Australian financial services licensee obligation in section 912A(1)(a) to do all things necessary to ensure licensed financial services are provided efficiently, honestly and fairly, together with section 912A(5A), in the context of Netwealth's operation of the Netwealth Superannuation Master Fund.

Key dates

2020-01-01

The FCA's temporary product intervention restricting mass-marketing of speculative illiquid securities to retail investors took effect.

2020-12-10

The FCA published PS20/15, confirming permanent rules for marketing speculative illiquid securities, including speculative mini-bonds, to retail investors.

2021-01-01

The permanent FCA restrictions on mass-marketing speculative illiquid securities to ordinary retail investors came into force.

2026-08-19

The FCA published the consumer warning following continuing losses and concerns about unregulated loan notes and mini-bonds, including the collapse of Woodville Consultants Limited.

2026-08-20

The FCA page was updated; the publication continues to operate as a warning and supervisory or enforcement signal rather than a new rule.

Suggested considerations

• Compliance teams may wish to inventory all loan notes, mini-bonds, debentures, preference shares, and comparable securities promoted, approved, advised on, arranged, or distributed by the firm.
• Firms should consider testing each product against the FCA definition of a speculative illiquid security, including the denomination threshold of less than £100,000, the use of proceeds, transferability, listing, and the applicable exemptions.
• Authorised firms should consider blocking mass-market communications, including websites, social-media advertising, broad email campaigns, affiliate content, and introducer activity, where the promotion is likely to reach ordinary retail clients.
• Where an exemption is relied on, firms should consider evidencing investor eligibility, the basis for any high-net-worth or sophisticated-investor status, the timing and validity of the investor declaration, and controls preventing onward dissemination to ineligible persons.
• Firms approving or communicating relevant promotions should consider verifying that required risk warnings, loss-of-capital disclosures, liquidity and default information, and third-party fee or commission disclosures are accurate, prominent, and consistent across all distribution channels.
• Due diligence should consider whether claims such as asset-backed, secured, FCA-authorised security trustee, listed, or fixed return accurately describe the legal and economic position of investors.
• Compliance teams may wish to review introducer agreements, commission arrangements, marketing costs, investor-money flows, and the proportion of subscriptions actually applied to the underlying investment.
• Firms should consider checking that communications do not use artificial deadlines, pressure tactics, unrealistic return comparisons, or performance claims unsupported by a credible explanation of repayment capacity.

What changed

No new binding requirement or prohibition was introduced by this publication. The FCA restated that its permanent rules prohibit authorised firms from approving or communicating financial promotions for speculative illiquid securities in a manner likely to be received by retail clients, subject to defined exemptions.

Key dates

2018-05-01

Demetrios Hadjigeorgiou became CEO of SVS Securities Plc.

2019-08-02

The FCA required SVS to cease regulated activities, safeguard assets and notify affected third parties.

2019-08-05

SVS Securities Plc entered special administration.

2023-08-10

SVS Securities Plc was dissolved.

2024-04-25

The FCA issued its initial Decision Notice proposing an £84,600 penalty and prohibition order against Mr Hadjigeorgiou.

2026-08-19

The FCA published the settled enforcement outcome: a £56,400 fine and prohibition from senior management positions in financial services.

Suggested considerations

• Compliance teams may wish to review whether senior managers have documented challenge and escalation responsibilities for investments involving issuer payments, commissions, related parties or other conflicts of interest.
• Firms should consider testing whether investment due diligence appropriately assesses product risk, liquidity, valuation methodology, concentration and suitability for pension and retail customers.
• Firms should consider reconciling all fees, commissions, retained spreads and exit-value adjustments against customer disclosures, ensuring that any reduction in redemption or sale value is prominent, timely and understandable.
• Boards and senior managers may wish to evidence periodic review of model portfolios against customers’ stated objectives, risk appetite, liquidity needs and pension-transfer circumstances.
• Compliance teams may wish to assess whether management information would have identified customer detriment, unusually high issuer-related income or investment decisions that prioritised firm revenue over customer interests.
• Firms should consider retaining clear records showing how conflicts were identified, mitigated, disclosed and challenged, including the rationale for approving high-risk or illiquid products for retail and pension-related portfolios.
• Authorised firms may wish to review the FCA’s SVS enforcement materials alongside their own senior-manager accountability maps and Statements of Responsibilities, while recognising that this case does not itself create a new universal obligation.

What changed

This is a concluded enforcement action against an individual, not a new general rule or threshold applicable to firms. The FCA imposed a financial penalty under section 66 of the Financial Services and Markets Act 2000 and a prohibition order under section 56 of that Act, following settlement and withdrawal of the Upper Tribunal referral. The FCA found a breach of Statement of Principle 6, requiring an approved person to exercise due skill, care and diligence in managing the business of the firm.

Key dates

2026-08-19

MAS published the announcement of the proposed tax exemption, Hedge Fund Investment Programme and Investment Management Track.

2027-01-01

The proposed tax exemption is expected to apply from Year of Assessment 2027; the precise income-period mechanics and legislative commencement remain to be confirmed.

Suggested considerations

• Firms should inventory existing carried-interest, performance-fee, incentive-allocation and other profit-participation arrangements and identify whether returns are received directly or indirectly for fund-management services.
• Tax and legal teams may wish to map each relevant fund against Sections 13D, 13O, 13OA, 13U and 13V of the Income Tax Act 1947 and retain evidence of Singapore-based management and applicable economic-substance conditions.
• Firms should avoid treating the announcement as an immediately available exemption and should monitor Budget 2027 and subsequent legislation or administrative guidance for the effective scope, rate, thresholds, attribution rules and documentation requirements.
• Compliance teams may wish to review fund, management-company, partnership and individual remuneration agreements so that the commercial basis for any profit-related return is clearly documented and distinguishable from ordinary salary or bonus remuneration.
• Asset managers considering Singapore expansion should assess whether participation in the Hedge Fund Investment Programme or the proposed Investment Management Track could support their business and talent strategy, while awaiting eligibility and application details.
• Immigration and HR teams may wish to identify senior investment professionals whose compensation is materially linked to investment performance and assess the potential implications once revised ONE Pass criteria are published.
• Firms should continue applying existing tax, licensing, employment, payroll, conduct, books-and-records and anti-avoidance requirements; this announcement does not displace those obligations.

What changed

MAS and the Ministry of Finance plan to introduce a tax exemption from Year of Assessment 2027 for qualifying profit-related returns arising from fund-management services. The exemption is intended to cover a contractual share of profits of funds qualifying under Sections 13D, 13O, 13OA, 13U or 13V of the Income Tax Act 1947, where the funds are managed by Singapore-based fund managers and the returns are received directly or indirectly by corporate entities, partnerships or individuals for providing fund-management services.

Key dates

2026-08-17

EAER amended Annexes 12, 13 and 14 and SECO updated the SESAM sanctions database.

2026-08-18 Deadline

The amendment became legally effective at 23:00 Swiss time; affected prohibitions, asset freezes and SECO reporting obligations applied from that time.

Suggested considerations

• Compliance teams may wish to obtain the effective 2026-08-18 23:00 SESAM dataset and run an immediate rescreening of customers, beneficial owners, authorised signatories, counterparties, payment beneficiaries, securities positions and relevant transaction history.
• Firms should consider applying the Article 16 asset-freeze and availability prohibitions to positive matches, including assets or economic resources controlled indirectly, and escalating potential matches for ownership-and-control analysis rather than relying only on exact-name screening.
• Financial intermediaries should consider reporting affected business relationships and frozen assets to SECO without delay in accordance with the ordinance, while documenting the screening timestamp, match disposition, freeze decision and notification trail.
• Teams may wish to review pending and recurring Iran-related payments against Article 21, including the CHF 10,000 SECO reporting threshold, the five-working-day reporting period, and the CHF 50,000 prior-authorisation threshold.
• A SECO sanctions report should not be treated as a substitute for AMLA analysis: where circumstances create suspicion, firms should consider additional clarifications under Article 6 AMLA/GwG and an immediate MROS report under Article 9 AMLA/GwG if the suspicion cannot be dispelled.
• Firms should consider reviewing delisted and amended entries separately, because removal from an Iran annex does not necessarily resolve exposure under other Swiss, UN or foreign sanctions regimes or eliminate unrelated AML, proliferation-financing or reputational-risk concerns.
• Compliance and operations teams may wish to confirm that screening vendors, payment filters, case-management workflows, correspondent-bank controls and sanctions procedures recognise the 23:00 Swiss-time effective moment and preserve an auditable change-management record.

What changed

The amendment updates the Swiss SESAM sanctions database and the designation annexes of the Ordinance of 12 December 2025 on measures against the Islamic Republic of Iran. Six individuals were delisted, one entity record was amended, and two individuals and one entity were newly listed; the publication does not identify the parties in the FINMA notice itself, so firms should rely on the current SECO SESAM data rather than the notice's entry counts alone.

Key dates

2026-08-14

EAER amended Annexes 2 and 14a of the Ukraine Ordinance; one entity was removed from Annex 14a and 610 Annex 2 individual and entity entries were amended.

2026-08-17 Deadline

The amendments and resulting prohibitions, asset-freezing requirements and reporting implications take effect at 23:00 Swiss time; firms should have implemented screening and control changes by this time.

Suggested considerations

• Compliance teams should load the amended Annex 2 and Annex 14a data into sanctions-screening systems and complete identifier, alias, ownership and account-linkage checks before the 17 August 2026 23:00 effective time.
• Firms should compare the pre-amendment and post-amendment lists to distinguish the Annex 14a deletion from the 610 amended Annex 2 entries and should avoid treating an amended record as cleared without validating the current consolidated list.
• Firms should review customers, beneficial owners, counterparties, payment instructions, securities positions, custody assets and correspondent relationships against the amended records, including possible indirect ownership or control links.
• Where a match is confirmed, firms should consider stopping prohibited activity, freezing relevant funds and economic resources, restricting access in accordance with the Ordinance, and reporting the affected business relationship to SECO using the applicable reporting channel and form.
• For suspected sanctions evasion, inconsistent customer information or other money-laundering indicators, compliance teams may wish to document the Article 6 AMLA enhanced clarification and assess whether an immediate Article 9 AMLA report to the Money Laundering Reporting Office is required.
• Firms should document screening-rule changes, alert disposition, freeze decisions, SECO notifications, AMLA escalation decisions and any controlled release following the Annex 14a removal. Any unblocking should be preceded by checks for separate Annex 2 designation, ownership or other sanctions grounds.

What changed

The EAER amended Annex 2 and Annex 14a of SR 946.231.176.72. The official government notice indicates that one entity was removed from Annex 14a and the entries concerning 610 individuals and entities were amended in Annex 2; the publication does not state that all 610 entries are new designations, so firms should obtain and compare the underlying consolidated and delta lists before determining the precise status of each relationship. Financial intermediaries must implement the applicable prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO.

Key dates

2026-08-14

The SEC announced the enforcement action and filed the complaint in the U.S. District Court for the Southern District of New York.

2020-12-01

Approximate beginning of the conduct period alleged by the SEC.

2025-06-30

Approximate end of the conduct period alleged by the SEC.

Suggested considerations

• Firms should consider reconciling every investor-facing statement about upfront fees, markups, commissions, carried interest, advisory fees, transaction spreads, and total acquisition cost against actual fund and affiliate-level economics.
• Compliance teams may wish to map all principal transactions and related-party transfers between advisers, sponsors, general partners, feeder funds, and portfolio-acquisition vehicles, with documented conflict reviews and valuation support.
• Firms should consider testing whether each person soliciting private-fund interests is properly registered or otherwise operating within an applicable broker-dealer exemption, and whether compensation arrangements create broker-dealer registration or supervision concerns.
• Compliance teams may wish to review cold-calling scripts, call recordings, lead-generation practices, sales-agent training, and escalation controls for high-pressure claims, guaranteed or implied returns, scarcity statements, and misleading descriptions of pre-IPO access.
• Firms should consider verifying offering exemptions, investor eligibility, registration status, subscription documentation, and disclosure delivery for each private fund and distribution channel.
• Compliance teams may wish to perform targeted surveillance of retail and retiree sales, including cancellation or cooling-off requests, unusual concentration, complaints about undisclosed fees, and differences between quoted and realized investor charges.
• Firms should consider preserving communications, transaction records, fee calculations, investor files, sales-agent compensation data, and valuation materials in anticipation of regulatory inquiries or investor claims.

What changed

This is a civil enforcement action, not a new rule or generally applicable safe harbor. The SEC alleges violations of the antifraud, securities-registration, and broker-dealer-registration provisions of the Securities Act of 1933, the Securities Exchange Act of 1934, and the Investment Advisers Act of 1940, together with control-person liability and aiding-and-abetting violations by Spaventa.

Suggested considerations

• Compliance teams may wish to verify that all marketed activities fall within the firm’s FSCA authorisation scope.
• Firms should consider checking that public-facing names, trading names, and FSP numbers match the FSCA register exactly.
• Market-conduct teams may wish to review websites, brochures, and social-media posts for any implication of authorisation where none exists.
• Firms should consider confirming that representatives and key individuals involved in client-facing activity are properly appointed and not subject to debarment or other restrictions.
• Compliance functions may wish to reassess oversight of affiliates, introducers, and other third-party distribution channels that could create unauthorised solicitation risk.
• Firms offering investments to South African clients may wish to map the product and jurisdictional footprint to ensure online or cross-border offers are within authorisation boundaries.

What changed

The publication reflects a regulatory enforcement outcome, not a new rule or consultation. The core conduct issue is that Acqumen Fund Limited was said to have offered investments to the public while not being authorised by the FSCA to provide financial products or intermediary services in South Africa.

Key dates

2026-06-24

FSCA decision to provisionally withdraw the FSP licence of Mixirite (Pty) Ltd (licence number 52110), pending completion of an investigation and consideration of the firm’s submissions

Suggested considerations

• Firms should consider reviewing their sales practices for online trading and call-centre channels to identify and remediate any aggressive, manipulative or high-pressure techniques that could be viewed as creating client harm or mis-selling risk.
• Compliance teams may wish to confirm that all financial advice and intermediary activities are provided only by authorised representatives recorded under the firm’s FSP licence, including where services are delivered through outsourced call centres, affiliates or introducing brokers.
• Firms should consider assessing marketing materials, scripts, social-media promotions and platform messaging to ensure they do not imply guaranteed or unrealistically high returns, particularly for leveraged or speculative products such as forex and CFDs.
• Compliance teams may wish to test whether suitability and needs analyses are being performed consistently for relevant advice and intermediary services, and whether these assessments are properly documented in client files before onboarding or product activation.
• Firms should consider strengthening risk disclosures for retail clients trading leveraged or speculative products so that warnings are prominent, product-specific, understandable and aligned with the actual risks of loss and volatility.
• Control and supervisory functions may wish to enhance monitoring of representatives and introducers, including review of sales calls, chats and digital onboarding journeys, to detect patterns of pressure selling, misrepresentation or advice by unauthorised persons at an early stage.
• Firms operating online trading platforms should consider checking that their licence status, scope of authorisation and platform branding are clearly and accurately presented to clients, and that no impression is created that activities fall outside the authorised categories under the FAIS Act.
• Compliance teams may wish to document how their current controls address the conduct themes highlighted by the FSCA (authorised status, advice boundaries, sales conduct, suitability and risk disclosure) to be able to demonstrate a proactive approach in the event of supervisory queries or thematic reviews.

What changed

The FSCA has imposed a provisional withdrawal of Mixirite (Pty) Ltd’s authorisation under its FSP licence, effectively prohibiting the firm from carrying on further financial services business or receiving additional client funds while an investigation is ongoing. This is not a rule change but an enforcement and supervisory step under the Financial Advisory and Intermediary Services (FAIS) Act and the broader FSCA conduct mandate, and it immediately restricts Mixirite’s ability to provide intermediary services or advice to retail clients through its online platforms.

Key dates

2026-08-12

SEC announcement of the administrative proceeding

2026-08-22 Deadline

Payment deadline for the $28 million penalty by Wells Fargo Clearing Services, LLC and the $7 million penalty by Wells Fargo Advisors Financial Network, LLC, within 10 days of entry of the order

Suggested considerations

• Compliance teams may wish to review whether written supervisory procedures specifically address the risks of cash sweep and bank deposit sweep arrangements.
• Firms may wish to assess whether product selection, monitoring, escalation, and exception-handling controls are documented and operating as intended.
• Broker-dealers and advisers may wish to test whether disclosures, advisor training, and supervisory review processes match the actual operation of sweep programs.
• Firms may wish to examine whether affiliated deposit-product conflicts, yield incentives, and client-cash allocation defaults are identified and mitigated in practice.
• Operational risk and compliance functions may wish to evaluate whether periodic reviews capture changes in interest-rate conditions and client behavior that can affect sweep-program risk.

What changed

The order reflects SEC action under Sections 203(e) and 203(k) of the Investment Advisers Act and Section 15(b) of the Exchange Act, with cease-and-desist relief for violations of Section 206(4) of the Advisers Act and Rule 206(4)-7. The SEC’s settled resolution imposed a censure and civil penalties of $28 million on Wells Fargo Clearing Services, LLC and $7 million on Wells Fargo Advisors Financial Network, LLC, payable within 10 days of entry of the order.

Key dates

2026-08-12

SEC administrative proceeding and release for Santander Securities LLC

Suggested considerations

• Compliance teams may wish to review mutual fund share-class selection controls to confirm lower-cost alternatives are identified and used when available.
• Firms may wish to reassess whether 12b-1 fee compensation is clearly disclosed in client-facing materials and account documentation.
• Supervisory teams may wish to test whether review procedures flag cases where a cheaper share class was available but not selected.
• Firms may wish to examine whether representative compensation or revenue-sharing arrangements could bias share-class recommendations.
• Compliance functions may wish to verify that remediation processes can identify and reimburse affected clients where share-class selection increased costs.

What changed

The SEC charged Santander Securities LLC with willful violations of Advisers Act Sections 206(2) and 207 in connection with recommending mutual fund share classes that paid 12b-1 fees while lower-cost share classes were available for the same funds. The order alleges inadequate disclosure of the conflict created by the firm’s and associated persons’ receipt of 12b-1 compensation, and it describes the conduct as a breach of fiduciary duty and disclosure obligations.

Key dates

2014-01-01

Start of the relevant conduct period during which Trustcore selected and held mutual fund share classes paying 12b-1 fees where lower-cost alternatives were available

2018-03-28

End of the relevant conduct period examined in the SEC’s administrative proceeding

2019-03-11

Date of the SEC’s administrative order against Trustcore Financial Services, LLC under the Investment Advisers Act of 1940

2020-12-31

Closure date of Trustcore’s affiliated broker-dealer, TrustCore Investments, LLC, referenced as subsequent context

Suggested considerations

• Firms should consider reviewing mutual fund share class selection methodologies to confirm that, where multiple classes of the same fund are available, the process appropriately prioritizes lower-cost share classes for clients unless a documented, client-specific rationale justifies a different choice.
• Compliance teams may wish to assess whether existing Form ADV, advisory agreements, and other client-facing disclosure documents clearly describe 12b-1 fees, revenue-sharing, and other distribution or affiliate compensation, including how these payments arise from share class selection and the resulting conflicts of interest.
• Advisory firms should consider mapping and documenting all compensation flows between the adviser, affiliated broker-dealers, and associated persons that are tied to mutual fund holdings, including 12b-1 fees and other distribution-related payments, to support clear conflict identification and disclosure.
• Firms may wish to evaluate supervisory controls and surveillance around mutual fund share class usage, including periodic reviews or exception reports designed to detect legacy, higher-cost, or revenue-generating share classes that remain in client accounts where lower-cost alternatives exist.
• Compliance teams should consider testing whether advisory personnel understand the firm’s fiduciary obligations under the Advisers Act in the context of fee-driven product selection, and whether training materials adequately cover share class conflicts and disclosure expectations.
• Advisory firms may wish to implement or enhance procedures requiring documentation of the rationale for any recommendation or retention of mutual fund share classes that pay 12b-1 fees or other distribution fees, especially where cheaper classes of the same fund are available to the client.
• Firms should consider reviewing and, where needed, updating policies governing interactions between advisory and brokerage affiliates, to ensure that incentives tied to fund distribution or 12b-1 fees do not undermine client best interest or the adviser’s fiduciary duty.
• Compliance teams may wish to benchmark their practices against prior SEC share class selection initiatives and enforcement matters, using this order as an example of the types of conflicts, disclosure gaps, and remedial undertakings the SEC is prepared to pursue.

What changed

This publication does not introduce new rules but memorializes a final SEC enforcement action and related undertakings under the Investment Advisers Act of 1940. The SEC imposed a formal cease-and-desist order against Trustcore Financial Services, LLC for violations of Section 206(2) (fraudulent conduct by an investment adviser) and Section 207 (untrue statements or omissions of material fact in filings with the SEC), in connection with the adviser’s selection and retention of mutual fund share classes that paid 12b-1 fees where lower-cost share classes were available.

Key dates

2017-06-01

Beginning of the conduct period identified by the SEC for the undisclosed or inadequately disclosed rollover and referral incentive-compensation practices.

2022-02-01

End of the conduct period identified by the SEC for the disclosure and policies-and-procedures failures.

2025-01-17

The SEC issued the settled administrative order against Transamerica Financial Advisors, LLC.

Suggested considerations

• Compliance teams may wish to compare conflict disclosures against actual compensation practices to confirm that conditional language does not understate incentives that are being paid in practice.
• Firms may wish to review rollover-related compensation arrangements for specificity in Form ADV brochures, client agreements, training materials, and sales communications.
• Compliance teams may wish to test whether policies and procedures under Rule 206(4)-7 are designed to identify, monitor, and remediate gaps between business practices and client disclosures.
• Firms should consider whether representative-level incentive compensation tied to referrals or rollovers warrants heightened supervision, approval workflows, or additional conflict controls.
• Firms may wish to assess whether retirement rollover supervision includes review of disclosure consistency, repapering, and cross-functional sign-off when compensation structures change.

What changed

This is an enforcement action, not a new rule or interpretive release, so it does not amend the underlying regulatory text. The SEC found violations of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 because the firm allegedly paid incentive compensation to investment adviser representatives for referrals and retirement rollovers from at least 2017-06-01 through 2022-02-01, while earlier disclosures used language suggesting the firm merely 'may' provide incentives.

Key dates

2021-07-09

SEC announced settled administrative proceedings against Kestra Advisory Services, LLC and Kestra Private Wealth Services, LLC

2026-08-12

SEC administrative proceedings index and SEC newsroom list the Kestra Private Wealth Services matter under Release No. 34-106110

Suggested considerations

• Compliance teams may wish to review whether disclosures about affiliated compensation, markups, and related conflicts are specific and prominent enough for advisory clients.
• Firms should consider testing mutual fund trade processing and fee assessment workflows for undisclosed economic benefits to affiliates.
• Dual registrants may wish to assess whether advisory and broker-dealer compliance functions are coordinated so disclosures, operations, and compensation schedules are aligned.
• Firms may wish to examine whether written policies and procedures are detailed enough to detect and prevent conflicts tied to transaction fees and non-transaction service fees.
• Wealth management firms may wish to compare client-facing disclosures against internal agreements and operational fee flows to identify inconsistencies.
• Compliance teams may wish to consider periodic testing of conflict disclosures and fee practices to determine whether similar issues would be identified before an exam or enforcement review.

What changed

This is an enforcement order, not a rulemaking, so it does not create new requirements. It nonetheless reinforces that investment advisers must provide full and fair disclosure of conflicts created when an affiliated broker-dealer receives compensation from mutual fund trades and related services, including situations described by the SEC as fee markups. The order also underscores the need for written compliance policies and procedures reasonably designed to prevent violations, which the SEC tied to Rule 206(4)-7.

Suggested considerations

• Compliance teams may wish to review whether advertising approval workflows are designed to identify statements that could be materially false or misleading under Advisers Act standards.
• Firms may wish to verify that marketing claims are supported by current documentation before use, especially where claims relate to qualifications, capabilities, or other material attributes.
• Teams may wish to confirm that all promotional channels, including websites, PDFs, presentations, email campaigns, and social media, are included in supervisory review.
• Firms may wish to assess whether recordkeeping processes preserve final and pre-approved versions of advertisements and the support for material claims.
• Compliance teams may wish to consider whether training for marketing and advisory personnel clearly addresses the prohibition on untrue statements of material fact in advertisements.

What changed

This publication is an enforcement order, not a new rulemaking, so it does not create new generally applicable obligations. It applies existing Investment Advisers Act advertising standards by finding that the firm violated Section 206(4) and Rule 206(4)-1(a)(5) through advertisements containing untrue statements of material fact. The order also requires a cease-and-desist remedy and imposes a $200,000 civil money penalty, payable within 10 days of the order’s entry.

Key dates

2019-08-01

SEC civil action filed in the District of Massachusetts

2024-03-29

District court entered final judgment against Commonwealth

2024-04-01

Whistleblower notice lists the qualifying judgment/order date

2024-07-05

Whistleblower notice last reviewed or updated

Suggested considerations

• Compliance teams may wish to review whether Form ADV and client-facing disclosures describe revenue-sharing arrangements with enough specificity to explain the actual conflict and the related economic incentive.
• Firms may wish to assess whether disclosures address not only the existence of revenue sharing, but also whether it may steer recommendations toward higher-cost mutual fund share classes over cheaper alternatives.
• Firms may wish to test whether policies and procedures under Rule 206(4)-7 expressly cover identification, escalation, review, and disclosure of revenue-sharing conflicts.
• CCOs may wish to confirm that they are being kept fully informed of revenue-sharing arrangements and related conflicts, especially where those arrangements can affect product recommendations or supervision.
• Compliance functions may wish to evaluate whether representatives understand the structure of revenue-sharing payments and how those economics may influence client recommendations.
• Dual registrants may wish to align broker-dealer and advisory disclosures so that the conflict is not described in one channel while omitted or softened in another.

What changed

This was an enforcement action, not a rulemaking, so it did not create new industry-wide requirements. The SEC alleged violations of Section 206(2), Section 206(4), and Rule 206(4)-7 of the Investment Advisers Act based on inadequate disclosure of material conflicts of interest and failure to adopt and implement adequate compliance policies and procedures.

Key dates

2021-07-09

SEC announced and settled the Kestra Advisory Services administrative proceeding

2021-07-09 Deadline

Order required payment of disgorgement, prejudgment interest, and civil penalty within ten days of entry of the order

Suggested considerations

• Compliance teams may wish to review whether client disclosures describe all forms of affiliated compensation, revenue sharing, and other economic benefits that could influence recommendations.
• Firms should consider whether Form ADV narratives, client agreements, and supervisory documentation are consistent on affiliate compensation and conflict disclosure.
• Dual registrants may wish to map advisory and brokerage compensation streams in their conflict inventories to confirm that material conflicts are captured and escalated.
• Firms should consider whether written compliance policies and procedures are tailored to actual business practices, rather than existing only in generic form.
• Compliance functions may wish to test whether supervisory reviews can detect compensation arrangements that create disclosure obligations under the Advisers Act.
• Wealth management organizations may wish to assess training for advisers and supervisors on when affiliate compensation and shared revenue arrangements must be disclosed to clients.

What changed

This was not a new rulemaking; it was an SEC enforcement order applying existing requirements under Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7. The Commission found that Kestra AS failed to disclose two types of compensation received by its affiliated broker-dealer and predecessor firm, including compensation tied to conflicts of interest, and that clients therefore lacked material information needed to assess those conflicts.

Suggested considerations

• Compliance teams may wish to review mutual fund share class selection logic to confirm whether lower-cost eligible share classes were available and used where appropriate.
• Firms should consider whether 12b-1 fee revenue is fully identified in conflict inventories and disclosed clearly in Form ADV and related client materials.
• Advisory supervision may wish to test whether recommendations are consistent with a client-first or best-interest framework when fund share class options differ in cost.
• Firms may wish to evaluate whether exception handling for higher-cost share class usage is documented, approved, and supported by a client-specific rationale.
• Compliance functions may wish to assess whether remediation and restitution calculations are available if historical share class selection issues are identified.

What changed

This was not a new rulemaking or interpretive release; it was an SEC administrative enforcement action based on alleged breaches of fiduciary duty and inadequate disclosure tied to mutual fund share class selection and 12b-1 fee revenue. The SEC’s order indicates the firm recommended, purchased, or held higher-cost share classes for clients despite lower-cost alternatives being available, and the firm received compensation through 12b-1 fees that created a conflict.

Key dates

2014-01-01

Start of relevant conduct period during which Investacorp Advisory Services, Inc. recommended or retained mutual fund share classes with 12b-1 fees despite lower-cost alternatives being available

2018-03-30

End of relevant conduct period covered by the SEC administrative order against Investacorp Advisory Services, Inc.

2026-08-12

SEC issues administrative order in Release No. 34-106089, File No. 3-19037, imposing cease-and-desist relief, censure, disgorgement, and prejudgment interest on Investacorp Advisory Services, Inc.

Suggested considerations

• Firms should consider reviewing mutual fund share-class selection policies and procedures to confirm that, where clients are eligible, the lowest-cost available share class of a given fund is systematically considered and documented, particularly in accounts where the firm or an affiliate receives 12b-1 fees.
• Compliance teams may wish to evaluate Form ADV Part 2A, advisory brochures, and other client disclosures to determine whether receipt of 12b-1 fees and similar distribution or servicing compensation is clearly described as a material conflict of interest, including the incentives it creates for advisers and affiliated broker-dealers.
• Advisory firms with affiliated broker-dealers should consider mapping compensation flows, including 12b-1 fees and revenue sharing, between entities to identify where those arrangements could reasonably influence share-class recommendations, and whether enhanced disclosure or conflict-mitigation controls are warranted.
• Firms may wish to implement or refine surveillance and testing to identify accounts invested in higher-cost mutual fund share classes when a lower-cost share class of the same fund appears available to that client, and to assess whether any such positions reflect policy exceptions or potential remediation candidates.
• Investment committees and disclosure governance bodies should consider comparing actual fund-share-class usage patterns against stated policies and disclosures in advisory brochures, wrap-fee program documents, and client agreements to confirm alignment and identify gaps in describing conflicts tied to 12b-1 fee receipt.
• Firms that historically received 12b-1 fees or similar fund distribution compensation during periods comparable to 2014–2018 may wish to consider whether a retroactive review of share-class selection and client eligibility is appropriate and whether any client reimbursement, remediation, or supplemental disclosure exercises are advisable in light of the SEC’s enforcement posture.
• Compliance and supervisory functions should consider updating training for investment adviser representatives and registered representatives to ensure they understand how mutual fund share-class selection, 12b-1 fee arrangements, and affiliated broker-dealer compensation can create fiduciary and disclosure risk under the Advisers Act.
• Legal and compliance teams may wish to revisit enterprise-level conflicts of interest inventories to ensure that mutual fund share-class selection practices, 12b-1 fee arrangements, and related revenue-sharing structures are explicitly captured, assessed, and tied to appropriate controls and disclosures.

What changed

The publication does not introduce new rules or amend existing regulations; it is an enforcement settlement applying existing fiduciary and disclosure obligations under the Investment Advisers Act of 1940, including Sections 203(e) and 203(k). The order confirms that the SEC considers the practice of placing advisory clients into mutual fund share classes that charge 12b-1 fees when lower-cost, non-12b-1 share classes of the same fund are available to be a material conflict of interest when the adviser or an affiliated broker-dealer receives those fees.

Key dates

2026-08-12

SEC administrative-proceedings listing date for the AXA Advisors matter

Suggested considerations

• Compliance teams may wish to review whether mutual fund share class selection processes systematically identify the lowest-cost eligible class for each account type and client segment.
• Firms may wish to assess whether disclosures in Form ADV, client agreements, and supervisory materials clearly describe 12b-1 compensation and other share-class conflicts.
• Supervisory teams may wish to confirm that representatives’ incentives tied to 12b-1 revenue are identified, reviewed, and mitigated or disclosed where necessary.
• Firms may wish to document a defensible comparison process for share classes and retain evidence supporting the selected class for each recommendation.
• Compliance functions may wish to evaluate whether prior-client remediation procedures are calibrated for situations where clients were placed in more expensive share classes than necessary.

What changed

This publication is an enforcement order, not a rulemaking or policy statement. The order requires AXA Advisors to cease and desist from future violations of Sections 206(2) and 207 of the Advisers Act, is accompanied by a censure, and imposes monetary relief totaling $1,134,152, consisting of $972,007.36 in disgorgement and $162,144.64 in prejudgment interest. The order also directs payment to affected investors, reflecting the SEC’s view that inadequate share-class selection and conflict disclosure can require remediation.

Key dates

10 August 2026

- The WBF amended Annexes 2 and 8 of the Ukraine sanctions ordinance and published the changes on its website

12 August 2026 Deadline

- The amended measures are published by FINMA and become operationally relevant for compliance teams

12 August 2026, 23:00

- The amended sanctions measures enter into force

Suggested considerations

• Firms must immediately screen customers, counterparties, and beneficial owners against the updated Annex 2 and Annex 8 listings and identify any matches.
• Firms must block and freeze any assets or economic resources belonging to sanctioned persons covered by the updated ordinance.
• Firms must report the affected business relationships to SECO in accordance with the ordinance.
• Firms must perform additional fact-finding under Article 6 GwG/AMLA whenever the sanctions hit or surrounding facts create suspicion that cannot be dismissed.
• Firms must submit an immediate suspicious activity report to MROS under Article 9 GwG/AMLA if the suspicion remains unresolved after additional clarifications.

What changed

• - The WBF amended Annex 2 and Annex 8 of the Swiss ordinance on measures connected with the situation in Ukraine, updating the sanctions list and/or restrictions applicable under SR 946.231.176.72.
• The amended measures become effective today at 23:00, meaning firms must be ready to apply the updated prohibitions without delay.
• Financial intermediaries must implement the prohibitions contained in the ordinance, which includes sanctions-related restrictions beyond ordinary asset freezes.
• Financial intermediaries must freeze the assets of sanctioned persons covered by the update.
• Financial intermediaries must report affected business relationships to SECO.

Key dates

10 August 2026

- The WBF amended Annex 2 of the Sudan sanctions ordinance, according to the related Swiss official notice

11 August 2026

- The updated Sudan sanctions measures enter into force at **23:00**

Suggested considerations

• Firms must update sanctions screening systems immediately to reflect the amended Sudan Annex 2 list in SESAM.
• Firms must identify and freeze any assets or economic resources belonging to or controlled by newly listed persons.
• Firms must block prohibited transactions and services involving sanctioned Sudan-related persons or entities.
• Firms must review all existing customer, counterparty, and beneficial owner relationships for matches against the updated list.
• Firms must report affected business relationships to SECO in line with the ordinance.

What changed

• - The WBF amended Annex 2 of the ordinance of 25 May 2005 on measures against Sudan (SR 946.231.18).
• The Swiss authoritative sanctions database SESAM was adjusted to reflect the change.
• The changes take effect today at 23:00, making the update operationally urgent for Swiss financial intermediaries.
• Financial intermediaries must implement the prohibitions under the ordinance, including freezing assets of sanctioned persons.
• Financial intermediaries must report affected business relationships to SECO.

Key dates

11 August 2026

- The Central Bank of Ireland published the warning notice naming **Abbey Croftson (CLONE)** as an unauthorised firm

Suggested considerations

• Block and escalate any customer or counterparty activity involving `abbeycroftson.com` or `info@abbeycroftson.com` for fraud and sanctions-style review, even though this is not a sanctions matter.
• Verify all new investment-firm counterparties against the Central Bank of Ireland’s unauthorised-firms list before onboarding, payment release, or referral acceptance.
• Review inbound complaints, payment instructions, and web leads for impersonation markers such as cloned names, copied addresses, or mismatched contact details.
• Update fraud and AML typologies to include clone-firm impersonation of regulated investment firms in Ireland.
• Notify relationship managers, operations teams, and front-line staff to escalate any contact from firms claiming to be Abbey Croftson or using similar branding.

What changed

• - The Central Bank has formally identified Abbey Croftson (CLONE) as an unauthorised investment firm / investment business firm in Ireland.
• The warning specifically lists the suspicious website as `https://abbeycroftson.com` and the email address used as `info@abbeycroftson.com`.
• The Central Bank states that the entity used details of a legitimate firm of a different name to deceive consumers.
• The Central Bank confirms there is no connection between the legitimate authorised firm and the fraudulent clone entity.
• The firm’s name has been published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013.

Key dates

05 August 2026

- CBI publishes the warning notice “Comgestfx (CLONE) – Central Bank of Ireland Issues Warning on Unauthorised Firm” under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, formally designating the entity as unauthorised and alerting the market

Suggested considerations

• Verify whether any clients, prospects, or staff have received communications from domains or email addresses associated with Comgestfx (CLONE), including http://www.comgestfx.com and mario.depaoli@comgestfx.com, and block these from internal systems and client channels.
• Update internal scam and clone‑firm watchlists and negative screening lists to include Comgestfx (CLONE), ensuring that onboarding, transaction monitoring, and client servicing teams can identify and escalate any reference to the entity.
• Communicate a targeted client alert to relevant investors and distributors, reminding them to verify firms against the CBI’s authorisation registers and clarifying that Comgest Asset Management International Limited (CAMIL) is not connected to Comgestfx (CLONE).
• Review and, where necessary, enhance financial crime, fraud, and conduct risk policies to ensure they explicitly address clone‑firm risks, impersonation of authorised entities, and obligations to report suspected unauthorised firms to the CBI.
• Ensure customer‑facing staff, relationship managers, and call‑centre teams are briefed on this specific warning and can explain to clients how to check a firm’s authorisation status and the risks of dealing with unauthorised entities.

What changed

• - The CBI has formally designated Comgestfx (CLONE) as an unauthorised investment firm / unauthorised investment business firm, explicitly stating it is not authorised to provide investment services...
• The warning specifies the clone’s website (http://www.comgestfx.com) and email address (mario.depaoli@comgestfx.com), enabling firms and clients to identify and block known fraudulent contact points.
• The CBI confirms that Comgestfx has cloned the name and details of Comgest Asset Management International Limited (CAMIL), and that there is no connection between the authorised firm and the...
• The firm’s name is published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, demonstrating the use of CBI’s statutory powers to publicly warn about unauthorised firms.
• The CBI reiterates its reporting channels for suspected unauthorised firms (telephone and online reporting), effectively re‑emphasising expectations that market participants and consumers will...

Key dates

05 August 2026

- CBI publishes the warning notice on Progestrade (CLONE) as an unauthorised investment firm / investment business firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Implement or strengthen screening of all investment counterparties, introducers and online platforms against the CBI’s “Search Unauthorised Firms” list and the authorised firm registers before any client referrals or transactions.
• Update client‑facing communications, websites, and onboarding materials to include clear warnings about clone firms, including guidance to verify firm details via the CBI register and to be wary of unsolicited investment approaches.
• Review and enhance fraud, AML / financial crime and conduct‑risk controls to explicitly address clone‑firm typologies, including monitoring for use of your firm’s name, logo or authorisation details by third parties.
• Conduct an immediate internal sweep to identify any references to, or contact with, Progestrade (CLONE), progestrade.com, or support@progestrade.com, and block or blacklist these identifiers in client‑facing and internal systems.
• For authorised firms whose names or details are vulnerable to cloning, establish a formal incident‑response plan for brand and authorisation misuse, including escalation to the CBI and law enforcement.

What changed

• - The CBI has formally designated Progestrade (CLONE), using the website progestrade.com and email support@progestrade.com, as an unauthorised investment firm and unauthorised investment business...
• The CBI explicitly confirms that Progestrade (CLONE) has cloned the name and details of Comgest Asset Management International Limited (CAMIL), a legitimately authorised firm, and that there is no...
• The firm’s name is published as a warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reinforcing the CBI’s supervisory and enforcement powers over...
• The CBI reiterates that firms and individuals can and should report suspected unauthorised firms directly to the Central Bank via the designated telephone line and reporting channels.
• The warning aligns with the CBI’s broader scam‑prevention messaging, directing consumers and market participants to its financial scams resources and the central list of unauthorised firms.

Key dates

2026-08-04

Federal Reserve published the proposed rule in the Federal Register at 91 FR 49526.

2026-10-05 Deadline

Public comments on the proposed rule are due.

Suggested considerations

• Compliance teams may wish to map the proposal’s threshold changes against existing Regulation O controls, including board-approval triggers, disclosure triggers, and internal lending limit checks.
• Firms may wish to identify any lending relationships that rely on current presumptions of control, especially where portfolio companies of investment fund complexes could be affected.
• Banks may wish to review insider-lending policies, forms, recordkeeping, and disclosure workflows for provisions that the proposal would codify, clarify, or remove.
• Stakeholders may wish to submit comments by 2026-10-05 if they want to influence the final treatment of thresholds, fund-complex ownership, valuation rules, or correspondent-lending provisions.
• Legal and compliance teams may wish to compare the proposed text against existing Regulation O, Regulation Y, and internal interpretive guidance to spot implementation impacts if the rule is finalized largely as proposed.

What changed

The proposal would amend 12 CFR part 215 (Regulation O) and conform related provisions in Regulation Y and other Board regulations. It would make a one-time adjustment to several dollar-based thresholds, then index those thresholds going forward based on nominal GDP. It would clarify how certain limits apply on an aggregate basis and streamline limits on loans to executive officers, including prior board-approval requirements for certain large loans.

Key dates

January 2021

- Start of the period during which Financière Fonds Privés is found to have committed unauthorised placement and advisory breaches

October 2024

- End of the factual period examined by the AMF Enforcement Committee for the identified breaches

TBD (post‑21 July 2026)

- Potential appeal phase before the Conseil d’État; the decision indicates that an appeal may be lodged, so firms should monitor for any subsequent case law impacting interpretation of CIF professional obligations

21 July 2026

- AMF Enforcement Committee decision imposing fines of €100,000 on Financière Fonds Privés, €70,000 on Pierre‑Michel Deléglise, and €40,000 on Thierry de Chambure, and attributing all breaches to the two senior managers

28 July 2026

- Public announcement of the decision via AMF news release

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.

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...

Key dates

19 September 2022 – 7 October 2022

- Approximate three‑week period during which LFSHK’s systems were restored in phases and clients could not trade via mobile app or internet platform, relying only on account executives to place orders

19 September 2022

- Ransomware attack on LFSHK’s critical IT infrastructure, affecting servers and core trading‑related systems

7 October 2022

- Completion of LFSHK’s system restoration following the ransomware attack

TBD (post‑incident)

- LFSHK conducted internal reviews and appointed an independent reviewer at the SFC’s request to assess the incident and cybersecurity internal controls; exact dates are not specified but occurred after the attack and prior to enforcement

TBD (enforcement publication date)

- SFC issues public disciplinary action reprimanding and fining LFSHK HK$2.1 million for misconduct relating to inadequate cybersecurity controls; the reference number indicates 2026 publication but the precise calendar date is not specified in the excerpt

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.

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...

Key dates

31 July 2023

- Consumer Duty came into force for open products and services and firms were expected to have outcomes monitoring capability in place from day one

31 July 2024 Deadline

- The final Consumer Duty implementation deadline applied to all in-scope financial services firms

2025

- The FCA reviewed firms’ approaches to outcomes monitoring over the past year and published its findings in this blog and related review material

TBD (ongoing)

- Firms are expected to continue regular monitoring, testing, and evidence-gathering on an ongoing basis under PRIN 2A.9

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.

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.

Key dates

23 July 2026

- Central Bank of Ireland publishes the warning notice identifying Bates Finance Limited (CLONE) as an unauthorised investment firm and stating its lack of authorisation and cloning behaviour

Suggested considerations

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

What changed

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

Key dates

23 July 2026

- Central Bank of Ireland publishes the warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013 naming Russell Administration Limited (CLONE) as an unauthorised investment firm

Suggested considerations

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

What changed

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

Key dates

2026-07-23

EBA launches consultations on draft ITS on depositor information, ITS on information exchange, RTS on DGS payouts of client funds deposits, and Guidelines on investment of available financial means under DGSD3

2026-09-21 Deadline

Registration deadline (12:00 CEST) for public hearing on all four regulatory products

2026-09-24

Public hearing on the four DGSD3-related regulatory products (10:00–13:00 CEST)

2026-10-23 Deadline

Deadline for submission of comments to the four consultation papers

Suggested considerations

• Compliance teams at EU credit institutions should consider reviewing existing depositor information sheets, account-opening documentation and ongoing communications to assess alignment with the emerging harmonised formats and content envisaged by the draft ITS on depositor information, particularly for merger and failure scenarios.
• DGSs and banks may wish to map current data flows and reporting processes for covered deposits, available financial means and bank failure events against the proposed ITS on information exchange, to identify gaps in data granularity, timeliness, and standardisation that could require system and process changes.
• Firms that hold client funds in pooled or intermediary deposit accounts (such as investment firms or payment institutions) should consider analysing how client identification and segregation data are captured and shared with DGSs, in light of the draft RTS on client funds that aim to ensure accurate and timely reimbursement of underlying clients and avoidance of duplicate payouts.
• DGS operators and finance teams may wish to review investment policies, risk limits, eligible instruments and liquidity management frameworks for DGS financial means, to anticipate adjustments needed to comply with the forthcoming Guidelines on diversification, low risk and liquidity, including readiness to support resolution financing within the DGSD3 mandate.
• All affected stakeholders should consider preparing internal positions and impact assessments and submit consultation responses to the EBA by the stated deadline, highlighting operational challenges, data availability issues, and any potential conflicts with existing national frameworks for depositor protection and crisis management.
• Risk and treasury functions in banks may wish to engage with DGSs and supervisors to understand how enhanced reporting on covered deposits and DGS financial means under the ITS on information exchange could affect crisis-preparedness expectations, stress-testing assumptions and disclosure practices.
• Legal and regulatory affairs teams should consider monitoring the progression of these four draft instruments alongside the remaining eight technical standards and guidelines mandated by DGSD3, to plan for a coordinated implementation programme once final texts and application dates are confirmed.

What changed

The publication launches consultations on four draft regulatory products mandated by DGSD3: (i) Implementing Technical Standards on depositor information, which define harmonised content and format for depositor information sheets at account opening and on a regular basis, and specify communication requirements in special situations such as bank mergers or failures; (ii) Implementing Technical Standards on information exchange between credit institutions, Deposit Guarantee Schemes (DGSs) and other relevant authorities, introducing standardised procedures, templates and minimum information...