on 21 may 2026, the court of justice of the european union (cjeu) delivered two significant sets of judgments addressing the interaction between trust structures and, respectively, eu restrictive measures and anti-money laundering transparency obligations. taken together, these rulings reinforce the eu's substance-over-form approach to financial regulation and carry important implications for trustees, fiduciary service providers, and compliance professionals across the member states. freezing of assets held through trusts: case c-483/23 (t trust) and joined cases c-428/24 and c-476/24 the first set of judgments arose from three italian references for a preliminary ruling concerning the freezing of funds and economic resources linked, indirectly through trust arrangements, to persons designated under eu restrictive measures adopted in response to russia's military aggression against ukraine. in each case, assets were held through trusts established under the laws of bermuda, and the italian authorities imposed freezing measures notwithstanding that the trust instruments purported to bar any transfer to, or control by, the sanctioned individuals. the cjeu held that the concepts of "belonging to" and of "control" within the meaning of article 2 of council regulation (eu) no 269/2014 must be interpreted broadly, so as to encompass all forms of power or influence exercised over funds and economic resources, including in the absence of any formal legal link between the assets and the designated person. assets may therefore be regarded as belonging to, or being under the control of, a settlor or beneficiary of a trust where those persons retain the power to use, benefit from, or dispose of such resources, or to exert influence over the decisions made by the trustee in relation to them, or indeed if they are or can exert such influence over other power-holders.. the cjeu emphasised that this interpretation is consistent with the purpose of asset-freezing provisions, which is to limit as far as possible the transactions that may be carried out with the assets concerned, and with the overarching objective of restrictive measures, namely the protection of ukraine's territorial integrity and the maintenance of international peace and security. critically, the cjeu noted that indications of belonging or control may be inferred from factual circumstances, such as the relationships between the beneficiary or settlor and other persons involved in the trust, such as the trustee and other power-holders, or the allocation of economic resources to activities intended primarily for the benefit of the designated person, as well as from the presence of needlessly complex legal structures. examples of relevant indicators include a majority shareholding in the trustee held by the beneficiary or settlor, the establishment or reorganisation of entities shortly before the imposition of sanctions, and close relationships between directors of the entities subject to freezing and the designated person. the line of thinking adopted by the cjeu is, in many ways, broadly consistent with the reasoning adopted by the english court of appeal in the so -called “eurochem judgment” of 31 july 2025 (llc eurochem north-west-2 and eurochem group ag v societe generale s.a. and others [2025] ewhc 1938 (comm)), which we issued an advisory on here. beneficial ownership transparency for trust mandates: joined cases c-684/24 and c-685/24 the second judgment concerned the validity and interpretation of the beneficial ownership transparency regime under the fourth anti-money laundering directive (directive (eu) 2015/849), as applied to mandati fiduciari (trust mandates) governed by italian law. italian fiduciary companies challenged the requirement to disclose beneficial ownership information to members of the public demonstrating a legitimate interest, arguing that trust mandates do not entail a transfer of ownership and should therefore fall outside the scope of the directive's transparency obligations. the cjeu confirmed the validity of the challenged provisions, holding that the requirement for public access to beneficial ownership information, subject to the demonstration of a legitimate interest, is compatible with the rights to private and family life and to the protection of personal data guaranteed by articles 7 and 8 of the charter of fundamental rights of the european union. the cjeu found that the eu legislature is pursuing a legitimate and important objective, namely, the prevention of money laundering and terrorist financing through enhanced transparency and that the measures adopted are proportionate to that objective. this is clearly an evolution of the precedent and standards set by the european court of justice in sovim v luxembourg in 2023, see our blog here on the classification question, the cjeu held that eu law permits the italian legislature to regard trust mandates concluded with italian fiduciary companies as "other types of legal arrangements" having a structure or functions similar to trusts, notwithstanding that the mandato fiduciario does not entail a transfer of ownership of the relevant property. the cjeu considered that the italian legislature did not exceed the margin of discretion available to it in implementing the access regime. as regards procedural safeguards, the cjeu accepted that eu law permits the task of ruling on exemptions from disclosure, for instance, where access would expose the beneficial owner to a disproportionate risk of fraud, violence, or intimidation, to be entrusted to non-judicial administrative bodies, such as italian chambers of commerce. however, the cjeu underscored that, where such an exemption is not granted, the beneficial owners concerned must be afforded the right to obtain interim legal protection. key takeaways for compliance and regulatory practitioners these judgments signal a firm judicial endorsement of the eu's expansive, effects-based approach to both sanctions enforcement and anti-money laundering regulation in the context of trust and fiduciary structures. for practitioners advising in relation to trust structures with any nexus to sanctioned individuals, the broad interpretation of "belonging to" and "control" demands heightened due diligence and a careful assessment of all factual indicators of influence, not merely formal legal title. for fiduciary service providers subject to aml obligations, the confirmation that trust mandates and similar arrangements fall within the directive's transparency regime reinforces the need for robust beneficial ownership identification, record-keeping, and disclosure processes. the requirement that beneficial owners retain access to interim judicial protection, even where exemption decisions are taken by administrative bodies, is a notable safeguard that member states must ensure is effectively available in practice. for more information see below the cases and the relevant press releases: press release no 73/26 for case c-483/23 and in joined cases c-428/24 / c-476/24 - here c-0483-23 joined cases c-428/24 and c-476/24 press release no 74/26 for cases c-684/24 and c-685/24 - here c-0684-24 c-685/24

on 24 april 2026, the uk office of financial sanctions implementation (ofsi) issued a new general licence (int/2026/9512597) under the sanctions and anti-money laundering act 2018, replacing the previous legal services general licence which expired on 28 april 2026. the licence allows uk law firms and counsel to receive payments from designated persons under the uk autonomous sanctions regimes listed in annex 1 including, notably, russia, without needing a separate ofsi-specific licence, provided all terms are met. key updates include a new “dp group” definition (allowing fee and expense caps to apply on a group basis), the ability to make payments to non-uk bank accounts held by solicitors regulation authority (sra), law society of scotland, or law society of northern ireland-regulated individuals, and revised fee and expense caps. the licence is split into two parts: part a covers prior obligation matters and part b covers non-prior obligation matters, with conditions under each part not being interchangeable. both parts cap professional legal fees and counsel fees at £2,000,000 (including vat) per law firm or counsel for the licence duration, with expenses limited to 10% of legal fees or £200,000, whichever is lower. additional rate caps apply: counsel’s hourly rates are capped at £1,500 per hour (including vat), legal advisers’ rates are capped per a detailed schedule, and where no professional fees are received, expenses are capped at £50,000. the licence permits designated persons and their dp groups to pay legal fees but does not authorise any act that would breach the uk autonomous sanctions regulations or result in funds being dealt with in contravention of the relevant regimes. payments received under the licence must be reported to hm treasury via an online form within 14 days, with supporting documentation, and records must be retained for a minimum of six years. the licence took effect on 29 april 2026 and expires on 28 october 2026. non-compliance renders the licence inapplicable and may result in criminal or monetary penalties. while uk sanctions apply to british overseas territories and crown dependencies, similar licences have not yet been issued in these jurisdictions at the time of publication. for full details, the general licence can be found here.

on 3 june 2026, the bermuda monetary authority (bma) published a consultation paper, together with an illustrative draft banks and deposit companies amendment bill 2026, proposing a series of amendments to the banks and deposit companies act 1999 (bdca). comments are due by 3 july 2026. the proposals represent the most substantial overhaul of the bdca since its enactment 27 years ago, targeting four key objectives: enforceability of standards, implementing operational resilience obligations, introducing late fees and recalibrating civil penalties, and effecting consequential amendments. key proposals winding-up the bma proposes to amend section 19 of the bdca to broaden the circumstances in which the bma may present a petition to the court for the winding-up of a company. under the proposed new wording, the bma may petition for winding-up where an institution is operating, or has been operating, in contravention of any provision of the bdca — removing the current requirement that the licence first be revoked. formalisation of prudential and technical standards the bma proposes amending section 36a to expand its rule-making powers beyond statutory returns to include binding prudential and technical standards — standards which currently exist only in non-enforceable guidance notes. the areas covered include: capital adequacy liquidity large exposures annual returns of controllers, directors, and senior executives statutory returns (quarterly, semi-annual, and annual) licensees will be permitted to apply for exemptions from, or modifications to, prudential or technical standards, subject to a $1,500 application fee. separately, licensees may apply for extensions of filing deadlines, subject to application fees ranging between $500 and $1,000 depending on the licence class. applications for filing deadline extensions must be made not less than five business days before the end of the relevant filing period. the bma may impose conditions on any exemption or modification and may subsequently revoke or vary such grant, subject to a notice and representations procedure. the proposals also empower the bma to take any action necessary to protect the public or clients where the nature, scale, complexity, and risk-profile of the institution warrants, after giving notice and considering representations. expanded conditions power amendments to section 14(5a) would extend the bma's power to impose, vary, or revoke licence conditions across all classes of bdca licence, rather than being limited to restricted bank licences as at present. enhanced licensing criteria the bma proposes amending section 13 of the bdca to expand the criteria against which licence applications are assessed from ‘nature and scale’ to ‘nature, scale, complexity, and risk-profile’. corresponding amendments to the second schedule will ensure consistent application of these expanded criteria across regulatory assessments. material changes in business notification a new notification regime will require licensees to obtain bma "no objection" prior to effecting any material change, including: changes to authorised products and services under section 14(5)(a) outsourcing of important business services or material outsourcing of risk management, compliance or internal audit functions, including appointment or replacement of outsourcing service providers material changes to the most recent business plan submitted to the authority the bma will have a 30-day determination period, which is tolled where further information is requested. a preliminary notice procedure applies where the authority is minded to object, affording the licensee 28 days to make representations. operational resilience reporting to underpin the bma's operational resilience and outsourcing code (effective for bdca licensees from 1 january 2027), a new section 35a will require licensees to notify the authority within 24 hours of becoming aware of a breach of any operational resilience impact tolerance threshold. the operational resilience framework requires licensees to establish at least one impact tolerance for each important business service, with maximum tolerable period of disruption as the minimum required metric. further guidance on setting impact tolerances is set out in part xi of the operational resilience and outsourcing code. key definitions, including "outsourcing", "outsourcing provider", "material outsourcing", "important business service" and "operational resilience impact tolerance threshold" are to be incorporated directly into section 2 of the bdca. penalty recalibration the proposals introduce a tiered enforcement model: late filings of statutory returns and audited financial statements will attract a fixed late fee of $1,000 per week (or part thereof), replacing civil penalties for administrative non-compliance breaches of prudential or technical standards and failures to report operational resilience tolerance breaches will remain subject to civil penalties the civil penalty cap under section 49a increases from $500,000 to $10,000,000, reflecting the systemic importance of the banking sector late fees may be recovered by the bma as a civil debt consequential amendments the banks and deposit companies (fees) act 1975 is to be repealed with effect from 1 january 2027, with legacy annual fees consolidated under the bermuda monetary authority act 1969. as part of this consolidation, the annual fee payment date will be aligned with existing bdca provisions, moving from 31 january to 31 march. section 24 will also be amended to require gazette publication, in such form as the bma may think fit, upon voluntary surrender of a licence. the proposed amendments bring the bdca into alignment with other bma-administered supervisory frameworks and signal a marked shift toward proactive, enforceable regulation of bermuda's banking sector. bma’s consultation paper can be accessed here.

on 1 april 2026, the bvi financial services commission (fsc) published its q1 2026 newsletter, detailing significant updates and initiatives in the financial services sector. the publication highlights the bvi fsc's proactive approach to global stakeholder engagement, legislative reforms, and compliance enhancement. to help you stay ahead, we have summarised the most critical updates from the newsletter: global expansion: the bvi fsc announced a new latin american representative office in panama, set to open by the end of 2026. furthermore, they officially inaugurated a highly modernised asia representative office in hong kong, strengthening their presence in key international markets. legislative reforms: the bvi fsc detailed vital updates to beneficial ownership regulations. these include new rules around exemptions, liquidator responsibilities, and access to filed information. compliance enhancements: the bvi fsc strongly emphasised its commitment to aml/cft/cpf compliance. through targeted training initiatives and strategic partnerships, such as those with the robert mathavious institute, they continue to build robust industry capacity. deadlines and penalties: you must remain vigilant about upcoming filing deadlines. the bvi fsc clearly outlined the strict penalties for non-compliance regarding beneficial ownership filings, which take effect this month. these developments reflect ongoing adjustments in the bvi’s regulatory environment and highlight active measures being taken to address international standards and industry expectations. stakeholders are encouraged to review these updates carefully and assess their potential impact on future operations. for more information the bvi fsc’s newsletter can be accessed here

the bermuda monetary authority (bma) introduced an approval in principle (aip) process to streamline the establishment of new investment funds in bermuda. this initiative aims to balance efficient decision-making with robust regulatory oversight. key highlights of the aip process: conditional pre-approval can be granted within 2-3 business days for applicants submitting the required documentation. this allows sponsors to address operational and outstanding requirements in a structured manner. full applications are typically reviewed within eight business days. it is important to note that aip is not equivalent to formal registration or authorisation under the investment funds act 2006. funds cannot commence operations, accept subscriptions, or claim registration until all statutory and regulatory requirements are met, and formal approval is granted. for further details, bma’s notice can be found here

on 17 april 2026, the european securities and markets authority (esma) published a statement clarifying its supervisory expectations as the mica transitional period reaches its eu-wide expiry on 1 july 2026. 1) transitional period expiry esma states that the mica transitional period “will officially expire across the eu on 1 july 2026” and after 1 july 2026, any entity providing crypto-asset services to eu clients without a mica licence will be “in breach of eu law” and “must cease offering such services”. esma also underlines that the prohibition applies irrespective of whether mica has been implemented in a member state or not, reinforcing the pan‑eu compliance cut‑off. 2) wind-down obligations for unauthorised casps esma reiterates following its related statement of 4 december 2025 that casps unauthorised by that date should have orderly wind‑down plans “ready for implementation” if authorisation is not obtained by the relevant deadline. esma expects wind‑down plans to: wind-down plans must be operational, credible, and immediately executable, designed in compliance with applicable eu conduct, prudential, and aml/cft obligations. plans must facilitate orderly client offboarding, including by arranging the transfer of crypto-assets held on behalf of clients to an authorised casp or to a self-hosted wallet, with prior notice to affected clients. by 1 july 2026, unauthorised casps must have already implemented their wind-down plans — the mere existence of a plan on paper will not suffice. 3) client migration at the same time, esma expects authorised casps to “actively manage” migration of existing clients ahead of 1 july 2026, including taking steps to onboard eu clients before the expiry of the transitional period. esma expressly links such onboarding to robust aml/cft processes and “full compliance” with applicable aml/cft requirements, signalling limited tolerance for simplified procedures during mass migration. 4) third‑country perimeter, reverse solicitation and anti‑circumvention esma further reminds market participants that entities established outside the eu are (save for those relying on the reverse‑solicitation exception) prohibited from providing crypto-asset services to eu clients or soliciting eu clients with a view to providing such services. esma further reaffirms that this restriction applies also in a b2b context and notes that mica prohibits casps from outsourcing/delegating certain services to non-eu entities which are not authorised as casps under mica. 5) expectations on ncas: verification and enforcement esma’s expectations for ncas ahead of and after expiry, including: verifying the existence and adequacy of wind‑down plans and ensuring timely implementation without undue economic harm to clients. acting against the unauthorised provision of crypto-asset services post‑expiry of the transitional period (including cooperation with other authorities where appropriate); and scrutinising client migration strategies, including to ensure unauthorised casps do not continue “business‑as‑usual” beyond the transitional period. 6) investor-facing warnings finally, esma directs investors to verify whether a provider is authorised as a casp in the eu. esma stresses that mica protections apply only when dealing with specific eu-authorised casps, not other group companies and not non‑eu entities, even where a common brand is used across jurisdictions. esma’s statement can be found here.

on 3 june 2026, the british virgin islands financial services commission (fsc) issued industry circular 16 of 2026, advising stakeholders of the government of the virgin islands' initiative to develop a national financial services strategy. the strategy is directed at enhancing the territory's competitiveness, resilience, and global standing within the international financial services landscape. as part of this initiative, the government is soliciting structured input from industry participants via a confidential stakeholder survey, administered through a dedicated platform. key aspects of the survey process are as follows: responses will be aggregated and analysed anonymously, with completion estimated at approximately ten minutes. the data collected will directly inform both the formulation of the strategy and its accompanying implementation roadmap. a select group of respondents may subsequently be invited to participate in targeted focus groups to examine specific topics in further detail. the survey seeks to capture stakeholder perspectives on current sectoral strengths, prevailing challenges, and prospective opportunities. the fsc has underscored that meaningful stakeholder engagement is critical to ensuring the strategy adequately reflects industry realities, addresses emerging risks, and positions the bvi financial services sector for sustained competitiveness. the deadline for survey submissions is 15 june 2026. stakeholders with operations or interests connected to the bvi are encouraged to participate promptly, given the limited consultation window. industry circular 16 of 2026 can be accessed here

on 19 may 2026, the department for business and trade (dbt) published general trade licence gbsan0004 (the licence). the licence exempts diesel and jet fuel refined from russian-origin crude oil in third countries from the new import ban introduced under chapter 4ib of the russia (sanctions) (eu exit) regulations 2019 (the russia regulations). it came into force on 20 may 2026, has no fixed end date and will be periodically reviewed by the secretary of state. notably, the licence was published without prior announcement, on the same day the new chapter 4ib import ban was due to take effect. in practice, it carves out the two product categories that constitute the vast majority of the uk's imports of refined russian-origin oil products, meaning the new ban has limited immediate impact on existing supply chains for diesel and jet fuel. what does the licence cover? the licence applies only to products falling within the following commodity codes: 2710 19 42 or 2710 19 44: diesel 2710 19 21: jet fuel all other oil products derived from russian crude remain subject to the new import ban. the licence does not override any other provisions of the russia regulations, if an act would breach another sanctions rule, the licence does not authorise it. standard record-keeping obligations under regulation 76 continue to apply, as do any windsor framework obligations for northern ireland. the secretary of state may vary, revoke, or suspend the licence at any time, with aim to give at least four months' notice before revocation. why has the government done this? the uk banned direct russian energy imports in 2022. however, a gap in the sanctions framework allowed over £4 billion of jet fuel and other oil products refined from russian crude in third countries, principally india, to continue entering the uk market. ministers had committed to close this loophole by spring 2026, most recently reaffirming that position in april. the policy reversal is driven by supply disruptions from the us–israeli conflict with iran, including the effective closure of the strait of hormuz, which has pushed brent crude to around us$110 per barrel. a separate temporary licence has also been issued for liquefied natural gas from certain russian plants. trade minister chris bryant described both exemptions as "temporary" and stated that the government would "suspend them as soon as we possibly can," whilst acknowledging that the communication of the decision could have been handled better. how does this compare with the us and eu approach? the us treasury extended its own sanctions waiver for russian oil cargoes already at sea, renewed for a second time in may 2026. the eu, by contrast, has taken a harder line, with economics commissioner valdis dombrovskis stating at the g7 finance ministers' meeting that it was not a time to "ease pressure on russia". reports suggest that certain european counterparts and ukraine were not consulted before the uk's decision. can i use this licence in the uk overseas territories or crown dependencies? in general terms, unfortunately not, as each uk overseas territory and crown dependency is responsible for issuing their own licences despite the fact that the underlying trade sanctions are based on the uk sanctions regime. we are keeping track of developments in the harneys jurisdictions and will update this blog in due course as and when further licences are issued. what should compliance teams do now? market participants should note the following points: narrow scope: the licence covers only diesel and jet fuel under the specified commodity codes. all other russian crude products remain prohibited under chapter 4ib. compliance screening processes should be updated to reflect this distinction. revocation risk: although the licence has no fixed end date, it can be revoked on four months' notice. this creates uncertainty for longer-term supply contracts and procurement planning. ongoing monitoring: dbt guidance should be monitored closely. the government has stated its intention to withdraw the exemption once supply conditions normalise, so the position may change at relatively short notice. the general licence can be accessed here.

we are delighted to announce that we will be attending fintech on the seas 2026 as a proud gold sponsor. the summit takes place from 22–24 june 2026 on the stunning necker island in the british virgin islands, and we could not be more excited to be part of it. hosted by bvi finance, this flagship event brings together global innovators, policymakers, regulators and industry leaders for three days of in-depth dialogue on the forces shaping the next era of financial technology. it is a unique opportunity to exchange ideas, forge partnerships and explore the trends that are redefining how financial services operate worldwide. what to expect the summit programme covers the full breadth of the modern fintech landscape. delegates can expect focussed discussions on the developments shaping global markets, from blockchain, tokenisation and decentralised finance to ai innovation, virtual asset regulation, dao governance and structuring for web-based projects. the agenda also addresses the practical side, with sessions on compliance strategies and building market resilience in an era of rapid technological change. why it matters as the intersection of financial services and technology continues to accelerate, events like this offer a valuable opportunity to stay ahead of the curve. join us we would love to see you there. if this sounds like your kind of event, registration is now open. register here: fintech on the seas 2026 — registration find out more about the event: fintech on the seas 2026 we look forward to connecting with fellow professionals, clients and collaborators in the bvi this june. do get in touch if you would like to arrange a meeting during the summit — we are always happy to make time for a conversation.

on 25 march 2026, the british virgin islands financial services commission (bvi fsc) published circular 10 of 2026 to inform the public about the latest financial action task force (fatf) public statement issued on 13 february 2026. high-risk jurisdictions (call for action) jurisdictions under increased monitoring guidance for compliance on 25 march 2026, the british virgin islands financial services commission published circular 10 of 2026 to inform the public about the latest financial action task force public statement issued on 13 february 2026. bvi fsc highlights fatf's latest aml/cft updates for february 2026 on 25 march 2026, the british virgin islands financial services commission (bvi fsc) published circular 10 of 2026 to inform the public about the latest financial action task force (fatf) public statement issued on 13 february 2026. high-risk jurisdictions (call for action) jurisdictions under increased monitoring guidance for compliance

on 25 march 2026, the british virgin islands financial services commission (bvi fsc) published circular 10 of 2026 to inform the public about the latest financial action task force (fatf) public statement issued on 13 february 2026. these statements identify jurisdictions with strategic deficiencies in their anti-money laundering (aml), counter-financing of terrorism (cft), and counter-proliferation financing (cpf) regimes. compliance with these updates is essential for maintaining international financial standards. high-risk jurisdictions (call for action) the fatf has identified jurisdictions with significant deficiencies requiring enhanced due diligence (ecdd) and, in some cases, countermeasures to mitigate risks to the international financial system. key jurisdictions include: dprk (north korea): persistent deficiencies in aml/cft/cpf frameworks. fatf calls for robust countermeasures, including terminating banking relationships and limiting financial transactions. iran: concerns over terrorism financing and proliferation risks. recommended measures include prohibiting new financial relationships and limiting transactions while ensuring humanitarian funds are handled appropriately. myanmar: limited progress on action plan commitments. enhanced due diligence measures are advised, ensuring humanitarian and legitimate activities remain unaffected. jurisdictions under increased monitoring 22 jurisdictions, including kuwait and papua new guinea, are under increased monitoring (commonly referred to as the "grey list"). these jurisdictions are actively working to address deficiencies. fatf advises a risk-based approach without unnecessary de-risking or cutting off entire customer classes. guidance for compliance the bvi fsc advises entities to: apply appropriate due diligence measures when dealing with customers or transactions linked to jurisdictions under increased monitoring. implement enhanced due diligence and countermeasures for high-risk jurisdictions. continuously monitor transactions involving clients from identified jurisdictions for any changes that may require adjustments in due diligence measures. for detailed statements, visit the fatf public statements here and bvi fsc circular 10 here.

the british virgin islands financial services sector experienced significant growth in 2025, as highlighted in the bvi financial services commission's (fsc) q4 2025 statistical bulletin and recent reports. key developments include: record incorporations: a total of 31,134 new companies were registered in 2025, marking a 14 per cent increase from 2024 and the highest level in four years. q4 2025 alone saw 8,778 incorporations, a 21.4 per cent rise compared to q4 2024. despite this, the total number of active companies slightly declined to 356,256 due to removals and strike-offs. diversification efforts: the bvi has been expanding its financial services beyond incorporations. limited partnerships (lps) saw a 39.5 per cent year-on-year increase in q4 2025, while trademark applications rose by 50 per cent compared to q4 2024. since 2015, nearly 3,000 trademark applications have been filed, reflecting the bvi's efforts to broaden its business base. sectoral trends: the fsc reported robust activity across various financial services, including investment business, fiduciary services, and virtual asset service providers. the licensing and supervisory committee handled 266 matters in q4 2025, underscoring the sector's dynamic regulatory environment. these developments signal a rebound in the bvi's financial services sector, driven by strategic diversification and a resurgence in company incorporations. the bvi continues to position itself as a global hub for financial services, leveraging its regulatory framework and expanding offerings. bvi fsc’s statistical bulletin for q4-2025 can be accessed here

on 30 april 2026, the european securities and markets authority (esma) published a call for evidence (cfe) presenting a data-driven analysis of the evolution of trading in european equity markets between 2022 and 2025, based on mifir transaction reporting data. the cfe invites stakeholder feedback on observed structural trends and their potential regulatory implications, with responses due by 30 june 2026. background and rationale the cfe responds to mounting concerns regarding shifts in european equity market microstructure, in particular, the marked increase in dark trading, a corresponding decrease in lit continuous trading, and a rise in bilateral trading arrangements such as those involving systematic internalisers (sis). the publication follows two earlier major studies on the subject: one conducted by esma and the other by the european commission, which reached diverging conclusions on the state of liquidity in eu equity markets. esma's stated objective is to provide an independent, transaction-data-based assessment of how liquidity is evolving and how it is distributed across different execution venues and methods. key findings esma's headline finding is that european equity markets continue to function well overall, with addressable liquidity remaining stable at around 85 per cent of total trading volume and on-book trading accounting for approximately 75–80 per cent of volume over the period. however, beneath this aggregate stability, the cfe identifies several notable structural shifts: regulation enabling dark trading. the cfe identifies that dark trading primarily operates under two waivers provided for under eu regulation 600/2014 on markets in financial instruments (mifir), namely, the large in scale waiver (article 4(1)(c) of mifir) and the reference price (rp) waiver (article 4(1)(a) of mifir). the trading venues applying those waivers allow the execution of trades without pre-trade transparency when certain conditions are met. decline in lit continuous trading. lit continuous trading on central limit order books (clobs) has decreased over the observation period, with the reduction being counterbalanced by growth in other on-book trading mechanisms, notably closing auctions and frequent batch auctions (fbas). growth of closing auctions. closing auctions on regulated markets and intra-day auctions increased from an average of 18 per cent to 19.3 per cent of trading volume between 2022 and 2025. esma is separately undertaking an analytical study on the impact of evolving closing auction mechanisms on price formation, with results expected within the year. doubling of fba volumes. fbas have doubled their relative share of trading volume, from 3.1 per cent in 2022 to 6.2 per cent in 2025. esma presents preliminary evidence suggesting that dark orders may be migrating from the rp waiver venues to fba trading systems following the introduction of the single volume cap (svc). impact of the single volume cap. the svc limits trading volume under the rp waiver to 7 per cent per isin across the eu. esma's data shows that the use of the rp waiver decreased following the first svc suspension but returned to previous levels after the second suspension, indicating that the cap's disciplining effect may be limited. deep dives: sis, benchmark trades, and member preferencing the cfe dedicates substantial analysis to three areas that raise novel regulatory questions: systematic internalisers. esma examines the diverse business models of sis in the context of the revised mifid ii definition, which took effect in september 2025 and replaced the prior quantitative test with a qualitative opt-in framework under article 4(20). esma also flags the enhanced quoting and transparency obligations for sis that commenced on 23 november 2025 and seeks views on whether further regulatory intervention is warranted. benchmark transactions. esma raises technical questions around the classification and transparency treatment of benchmark trades under the post-trade transparency framework, including whether such trades should be considered as addressable liquidity or price-forming. member preferencing. esma defines member preferencing as the practice whereby an order submitted to a multilateral execution mechanism, such as an auction or continuous order book, is matched with a preferred member's order, bypassing time-priority or even price-priority rules. esma acknowledges that the practice is "relatively widespread" and may have legitimate operational justifications, but raises concerns regarding the potential for unfair treatment of non-preferred participants, its anti-competitive nature, and its resemblance to internalisation rather than genuine on-venue trading. esma is seeking evidence on whether legislative or regulatory intervention is warranted in this area. relevance to mip negotiations esma expressly notes that stakeholder feedback gathered through this cfe may inform the co-legislators' discussions in the context of the market integration package (mip) negotiations, including on the applicability of the tick-size regime to periodic auctions. the repeal of the existing q&a on tick-size applicability to periodic auctions is a deliberate step by esma to level the playing field across jurisdictions ahead of those negotiations. practical implications the cfe does not propose specific rule changes at this stage, but its scope and the granularity of its questions signal that esma is laying the groundwork for potential regulatory adjustments. market participants, particularly trading venues, investment firms operating as sis, and asset managers reliant on closing auction pricing, should consider responding to the consultation by the 30 june 2026 deadline. esma expects to publish a feedback statement in the second half of 2026. esma’s news release can be found here and the call for evidence here

on 12 march 2026, the jersey financial services commission (jfsc) launched a consultation on phase 1 amendments to its bank licensing policy (blp), which governs the assessment of applications under the banking business (jersey) law 1991 and informs aspects of ongoing supervision. responses are due by friday 12 june 2026, with a feedback summary expected by the end of august 2026. this is phase 1 of a two-phase programme. phase 1 focusses on modernising and simplifying the existing framework, while phase 2 will examine broader structural questions, including whether legislative changes are warranted and whether tailored regulatory approaches could be developed for lower-risk categories of bank, given that current legislation provides for only a single class. key proposals removal of the "top 1,000" restriction the current blp limits registrations to entities within the global "top 1,000" banking groups by tier 1 capital, or financial services conglomerates of equivalent size. the consultation proposes removing this threshold, while retaining requirements for international activity, financial strength, and a satisfactory supervisory track record. applications from entities that substantially, but not fully, meet these criteria may be considered where depositor risks are clearly mitigated. this continues a trajectory of relaxation, the threshold was previously reduced from "top 500" in 2014, following the post-crisis shift towards bail-in regimes. new framework for jersey start-up banks the consultation introduces, for the first time, a formalised approach to the licensing of de novo banks in jersey: assessment criteria include board and management experience, alignment of business model with jersey's risk profile, and stress testing of the business plan against potential financial risks to jersey in failure scenarios. existing jersey-based businesses evolving into banks would be assessed on regulatory history and business plans. a staged licensing pathway is envisaged: "in-principle" licences to support capital raising, followed by a mobilisation phase under restricted, time-limited conditions. restrictions would be lifted only upon evidence of depositor risk mitigation and compliance with prudential and aml/cft/cpf requirements. removal of managed bank and business continuity provisions the jfsc proposes removing blp provisions on managed banks and business-continuity-only registrations, on the basis that no such entities currently exist in jersey and such structures are uncommon elsewhere. proposed removal of the letter of comfort requirements the letter of comfort regime requiring a jersey-incorporated bank (jib) to obtain a parental letter confirming continuing financial viability is proposed for removal. the jfsc considers this requirement superseded by: recovery planning requirements under pillar 2, which now require jibs to demonstrate how they can address solvency events through group support and internal actions. resolution planning work by the jersey resolution authority (jra). financial support will instead be assessed through consideration of recovery plans. senior officer role the jfsc is seeking views on the off-island senior officer requirement imposed on all branches under article 11(2) of the banking business (general provisions) (jersey) order 2002. having established through aml/cft/cpf work that senior officers form part of senior management, the jfsc is asking whether clarifying the expectations of the role would better support role holders and affected businesses. general policy simplification the consultation also proposes removing general regulatory and application-process material from the blp (to be communicated via the jfsc's website instead) and eliminating duplication of requirements already in the code of practice for deposit-taking business (the banking code). a draft revised blp is provided as appendix a. responding to the consultation stakeholders are invited to submit responses via the jfsc's online form by friday 12 june 2026. the consultation poses eight specific questions covering each key proposal. for more information, the industry update and consultation can be found here

on 20 may 2026, the russia (sanctions) (eu exit) (amendment) regulations 2026 (s.i. 2026/543) came into force, significantly expanding the uk's sanctions regime against russia. made by the secretary of state under the sanctions and anti-money laundering act 2018, these regulations amend the russia (sanctions) (eu exit) regulations 2019 and introduce a range of new trade and shipping prohibitions. uk significantly ramps up russia trade sanctions (may 2026): what you need to know on 20 may 2026, the russia (sanctions) (eu exit) (amendment) regulations 2026 (s.i. 2026/543) came into force, significantly expanding the uk's sanctions regime against russia. made by the secretary of state under the sanctions and anti-money laundering act 2018, these regulations amend the russia (sanctions) (eu exit) regulations 2019 and introduce a range of new trade and shipping prohibitions. key measures: specified ships. the regulations introduce prohibitions on providing services (including technical assistance, crew, operating, chartering, brokering and financial services) in relation to ships specified by the secretary of state, as well as a ban on chartering or operating such ships. processed oil products. it is now prohibited to import oil and oil products falling within commodity code 2710 that have been processed in a third country from russian-origin crude oil (commodity code 2709), together with associated financial, brokering and technical assistance services. uranium. new restrictions prohibit the import, acquisition, supply and delivery of uranium originating in or consigned from russia, alongside bans on related financial, brokering and technical assistance services. liquefied natural gas (lng). the maritime transportation by ship of russian-origin lng, both from russia to third countries and between third countries, is now prohibited, along with associated financial and brokering services. detained transport assets. the acquisition of detained ships or aircraft from designated persons or persons connected with russia is prohibited, and any such transaction is rendered void and ineffective as a matter of contract and property law. construction services. construction services have been added to the list of prohibited professional and business services under the 2019 regulations. expanded goods controls. additional goods have been added to key schedules, including ancillary chemicals used in advanced chip production, quantum computing and related goods, engineering biology ancillary goods, and further defence and security items. transitional provisions and exceptions limited wind-down periods apply. for construction services, contracts concluded before 20 may 2026 may be performed until 20 august 2026, subject to notification to the secretary of state. for restricted goods in the new categories (advanced chip chemicals, quantum computing goods, and engineering biology goods), the wind-down period extends to 20 november 2026. for lng maritime transportation, long-term contracts concluded before 17 june 2025 benefit from a carve-out until 1 january 2027, subject to conditions. exceptions also exist for uranium activities necessary for the continued operation of nuclear installations in third countries. licensing and enforcement new licensing regimes have been introduced for detained transport assets and ships, with associated offences for providing false information or failing to comply with licence conditions. enforcement mechanisms under the customs and excise management act 1979 and the serious organised crime and police act 2005 have been updated to reflect the new prohibitions. note on the overseas territories and crown dependencies the new uk regulations will, in many key respects, be automatically implemented into the sanctions regimes in the overseas territories and crown dependencies, as changes to underlying uk sanctions laws are generally given effect to automatically. however, some tailoring of the new sanctions will still be needed to make the provisions fully ‘fit for purpose’ and we would expect these to be implemented through new orders in council (or equivalent) which are still to be issued. we are keeping track of developments and will update this blog in due course. next steps organisations with exposure to russian trade, energy, shipping or asset markets should review existing contracts and commercial relationships against these expanded prohibitions as a matter of priority, noting the limited transitional periods available. the russia (sanctions) (eu exit) (amendment) regulations 2026 can be found here

on 26 may 2026, the uk foreign, commonwealth & development office (fcdo) announced 18 new designations under the russia (sanctions) (eu exit) regulations 2019, targeting cryptocurrency exchanges, financial intermediaries, and key individuals linked to russia's sanctions evasion infrastructure. the package represents one of the uk's most expansive crypto-focussed sanctions actions to date and marks the first application of regulation 17a to crypto asset exchanges. the measures came into force immediately. key targets the designations focus on two principal categories of sanctions evasion infrastructure: the a7 network. the a7 network is a kremlin-backed system which the uk fcdo described as being designed to bypass western sanctions, finance military procurement, and process funds from the sale of oil to fund russia's war economy. the network claimed to have moved more than us$90 billion last year - equivalent to roughly half of russia's yearly military expenditure. the package targets key a7-linked individuals who are said to be using a kyrgyz bank suspected of facilitating payments for the network. crypto asset exchanges. the designations also hit major global cryptocurrency exchanges that the uk government has stated have channelled over us$1.5 billion to russia. three georgian companies operating russia-focussed exchanges seeking to evade sanctions are also targeted. the most prominent of the new exchanges listed being: exmo exchange limited, operating through exmo.com and exmo.me nueva crytologia, s.a.s. de c.v. of el salvador, operating as abcex through abcex.io arvix llc of the republic of georgia, operating through arvix.pro and exnode.ru rapira group llc of the republic of georgia, operating through rapira.io (and other derivations) alistera limited / alistair limited with operations in russia and operating through alistera.ru bitpapa ic fzc llc of ajman, uae operating through bitpapa.com and bitpapa.org aifory llc of the republic of georgia huobi global s.a. of panama, operating as htx and operating htx.com uk/ukot-connected persons holding crypto assets through designated exchanges should seek legal advice in relation to their holdings to understand the implications of these new sanctions. wider context the uk government has stated that these measures demonstrate it is "moving faster and further than ever before" to clamp down on these routes and adapt its approach to stay ahead of suspected russian evasion. to date, the uk has sanctioned over 3,300 individuals, businesses, and ships, with russia's war economy having lost over us$450 billion due to international sanctions. practical significance the package represents a notable shift in the uk's sanctions enforcement, moving to directly designate cryptocurrency infrastructure used for sanctions circumvention. the simultaneous targeting of the a7 network's corporate structure, its banking conduit in kyrgyzstan, and the crypto exchanges facilitating its flows reflects an end-to-end approach aimed at dismantling the full payment chain, rather than individual nodes. compliance teams at uk-regulated financial institutions should promptly screen counterparties and transaction flows against the updated uk sanctions list, which now includes the 18 newly designated persons – including the prominent exchanges named above. the uk has indicated it is leading international efforts to disrupt these financial networks, working with allies to protect the integrity of the international financial system. firms with cross-border exposure should therefore anticipate coordinated designations from allied jurisdictions. the full list of designations is available on the uk sanctions list. uk’s press release can be found here and the sanctions notice here

on 11 may 2026, the european union's foreign ministers reached a unanimous agreement to impose restrictive measures on israeli settlers and settler organisations over violence against palestinians in the occupied west bank. the sanctions arise against the backdrop of escalating tensions in the west bank. whilst the foreign ministers reached a political agreement on 11 may, technical and legal work remains before the sanctions are formally adopted and published in the official journal of the european union. the list of designated persons and entities will need to be finalised, following which the sanctions will be legally binding across all eu member states. businesses and financial institutions should monitor the publication of the formal sanctions listings closely and ensure that their compliance frameworks are updated accordingly. as the regulatory landscape continues to evolve, proactive engagement with sanctions compliance will be essential to mitigating legal and reputational risk.

the bvi recently enacted the mutual legal assistance (tax matters) (amendment) act 2026 (the 2026 amendment). this vital piece of legislation formally aligns local law with the updated common reporting standard (crs) approved by the organisation for economic co-operation and development (oecd) in june 2023. the 2026 amendment was gazetted on 5 march 2026. purpose of the 2026 amendment the primary goal of the 2026 amendment is to integrate digital money products into existing frameworks, enhance overall reporting requirements, and clarify specific terms and due diligence obligations. by adopting the latest oecd standards, the bvi maintains its position as a highly regulated financial centre. definition amendments the 2026 amendment updates several key definitions under section 21 to modernise financial compliance, for example: “non-reporting financial institutions”: the definition now explicitly accounts for the maintenance of central bank digital currencies. “account classifications”: the definition updates the thresholds for a "pre-existing account" (maintained as of 31 december 2025 under the new rules) and a "new account" (opened on or after 1 january 2026). “bvi residency”: the definition introduces a precise definition for "resident in the virgin islands". this includes entities incorporated or established in the bvi, those with a place of effective management in the bvi, or those subject to local financial supervision. implementation and timelines section 26a of the 2026 amendment confirms that the crs amendments officially take effect on 1 january 2026. to ease the transition, the 2026 amendment includes practical data provisions. for reportable accounts maintained as of 31 december 2025, financial institutions are only required to report the specific roles of controlling persons or equity interest holders where that information is already captured in electronically searchable records. this means financial institutions are not obliged to conduct retrospective data remediation exercises for legacy accounts – this will be a welcomed relief for institutions with large pre-existing client books. strengthened anti-avoidance the 2026 amendment takes a strict stance on compliance evasion by entirely replacing section 34. under the new rules, if a person or entity enters an arrangement where the main purpose is to bypass reporting obligations, the authorities will treat the situation as if the arrangement never took place. given the immediate application of these new legal provisions. we recommend that bvi-regulated entities operating in the bvi review their compliance frameworks promptly to ensure alignment with the updated crs requirements and anti-avoidance provisions. the mutual legal assistance (tax matters) (amendment) act, 2026 can be found here

the jersey financial services commission updated its sanctions list, which includes measures implemented and enforced by jersey. these sanctions are categorised by country and specific regimes, providing an overview of the legal acts, latest news, and jersey's enforcement regime. recent updates the jersey financial services commission updated its sanctions list, which includes measures implemented and enforced by jersey. these sanctions are categorised by country and specific regimes, providing an overview of the legal acts, latest news, and jersey's enforcement regime. latest updates on jersey's sanctions regimes the jersey financial services commission updated its sanctions list, which includes measures implemented and enforced by jersey. these sanctions are categorised by country and specific regimes, providing an overview of the legal acts, latest news, and jersey's enforcement regime. recent updates

the jersey financial services commission updated its sanctions list, which includes measures implemented and enforced by jersey. these sanctions are categorised by country and specific regimes, providing an overview of the legal acts, latest news, and jersey's enforcement regime. recent updated: global irregular migration and trafficking: latest news as of 5 may 2026, with revisions on 6 may 2026. russian federation: updated on 21 may 2026. afghanistan: latest news on 14 may 2026. sudan: latest news on 28 april 2026, revised on 29 april 2026. global human rights: updated on 16 april 2026. the sanctions cover a wide range of areas, including counter-terrorism, cyber-attacks, global anti-corruption, and human rights. each category provides detailed information on the measures and their implications. for more details, visit the jersey’s fsc sanctions page.