on 1 july 2026, the bvi financial services commission (fsc) issued industry circular 20 of 2026, confirming that will not implement fees for economic substance filings through the virrgin system for the 2026 filing year. the fsc indicated that a new fee regime will instead take effect for 2027 filings, with details to follow after an industry consultation. background: the boss-to-virrgin transition key points on 1 july 2026, the bvi financial services commission issued industry circular 20 of 2026, confirming that will not implement fees for economic substance filings through the virrgin system for the 2026 filing year. the fsc indicated that a new fee regime will instead take effect for 2027 filings, with details to follow after an industry consultation. bvi fsc postpones economic substance filing fees to 2027 on 1 july 2026, the bvi financial services commission (fsc) issued industry circular 20 of 2026, confirming that will not implement fees for economic substance filings through the virrgin system for the 2026 filing year. the fsc indicated that a new fee regime will instead take effect for 2027 filings, with details to follow after an industry consultation. background: the boss-to-virrgin transition key points

on 13 july 2026, the uk and eu announced a coordinated sanctions package targeting russian state actors, cybercriminal proxies and disinformation networks, marking the first joint uk-eu cyber sanctions action. key designations and attributions what is novel on 13 july 2026, the uk and eu announced a coordinated sanctions package targeting russian state actors, cybercriminal proxies and disinformation networks, marking the first joint uk-eu cyber sanctions action. uk and eu announce first joint cyber sanctions package targeting russian state-linked networks on 13 july 2026, the uk and eu announced a coordinated sanctions package targeting russian state actors, cybercriminal proxies and disinformation networks, marking the first joint uk-eu cyber sanctions action. key designations and attributions what is novel

on 30 july 2026, the cssf published a communiqué confirming that updated notification and de-notification templates for cross-border management passporting are now live, reflecting changes introduced by the transposition of directive (eu) 2024/927 (aifmd ii) into luxembourg law via the law of 3 march 2026. what has changed affected templates practical takeaway on 30 july 2026, the cssf published a communiqué confirming that updated notification and de-notification templates for cross-border management passporting are now live, reflecting changes introduced by the transposition of directive (eu) 2024/927 (aifmd ii) into luxembourg law via the law of 3 march 2026. luxembourg implements aifmd ii changes to cross-border notification procedures on 30 july 2026, the cssf published a communiqué confirming that updated notification and de-notification templates for cross-border management passporting are now live, reflecting changes introduced by the transposition of directive (eu) 2024/927 (aifmd ii) into luxembourg law via the law of 3 march 2026. what has changed affected templates practical takeaway

on 24 june 2026, the financial action task force (fatf) launched a public consultation on new draft guidance. the guidance is designed to help put into practice its updated recommendation 16 (r.16), the payment transparency standard often known as the “travel rule”. fatf updated r.16 back in june 2025 to keep pace with new payment products, players, business models and messaging standards, and with changing fraud and money laundering risks. countries are expected to be ready to apply the tougher standards by the end of 2030, and responses to the consultation are due by 21 august 2026. what’s new in the draft guidance: on 24 june 2026, the financial action task force launched a public consultation on new draft guidance. the guidance is designed to help put into practice its updated recommendation 16, the payment transparency standard often known as the “travel rule”. fatf updated r.16 back in june 2025 to keep pace with new payment products, players, business models and messaging standards, and with changing fraud and money laundering risks. countries are expected to be ready to apply the tougher standards by the end of 2030, and responses to the consultation are due by 21 august 2026. follow the money: fatf opens consultation on its modernised "travel rule" on 24 june 2026, the financial action task force (fatf) launched a public consultation on new draft guidance. the guidance is designed to help put into practice its updated recommendation 16 (r.16), the payment transparency standard often known as the “travel rule”. fatf updated r.16 back in june 2025 to keep pace with new payment products, players, business models and messaging standards, and with changing fraud and money laundering risks. countries are expected to be ready to apply the tougher standards by the end of 2030, and responses to the consultation are due by 21 august 2026. what’s new in the draft guidance:

on 30 july 2026, following a consultation with the cssf and alfi, a draft bill was submitted to insert a new article 28bis into chapter 5 of the luxembourg aifm law (the amended law of 12 july 2013). the amendment allows alternative investment funds (aifs) constituted as a société en commandite simple (scs) or a société en commandite spéciale (scsp) to adopt multi-compartment structures without being subject to any of the four existing product law regimes, the uci law, the sicar law, the sif law, or the raif law. authorised aifms only key features of article 28bis practical significance on 30 july 2026, following a consultation with the cssf and alfi, a draft bill was submitted to insert a new article 28bis into chapter 5 of the luxembourg aifm law. the amendment allows alternative investment funds constituted as a société en commandite simple or a société en commandite spéciale to adopt multi-compartment structures without being subject to any of the four existing product law regimes, the uci law, the sicar law, the sif law, or the raif law. luxembourg expands its fund structuring toolkit: multi-compartment aifs without a product law on 30 july 2026, following a consultation with the cssf and alfi, a draft bill was submitted to insert a new article 28bis into chapter 5 of the luxembourg aifm law (the amended law of 12 july 2013). the amendment allows alternative investment funds (aifs) constituted as a société en commandite simple (scs) or a société en commandite spéciale (scsp) to adopt multi-compartment structures without being subject to any of the four existing product law regimes, the uci law, the sicar law, the sif law, or the raif law. authorised aifms only key features of article 28bis practical significance

on 23 july 2026, the council of the european union adopted its 21st package of restrictive measures against russia. on 17 july 2026, the council separately imposed targeted listings on one individual and five entities within the russian military-industrial complex, specifically linked to drone manufacturing. financial services and crypto energy and shadow fleet military-industrial complex lng measures other notable measures on 23 july 2026, the council of the european union adopted its 21st package of restrictive measures against russia. on 17 july 2026, the council separately imposed targeted listings on one individual and five entities within the russian military-industrial complex, specifically linked to drone manufacturing. eu's 21st russia sanctions package: focus on energy, crypto and financial restrictions on 23 july 2026, the council of the european union adopted its 21st package of restrictive measures against russia. on 17 july 2026, the council separately imposed targeted listings on one individual and five entities within the russian military-industrial complex, specifically linked to drone manufacturing. financial services and crypto energy and shadow fleet military-industrial complex lng measures other notable measures

the british virgin islands international tax authority (ita) has moved economic substance (es) declarations onto the virtual integrated registry regulatory general information network (virrgin), which became available on 2 january 2026. the transition timeline what is new on the platform reporting and supporting information declarations and relevant activities financial period change requests (t602) processing, bulk filing and fees practical takeaways the british virgin islands international tax authority has moved economic substance declarations onto the virtual integrated registry regulatory general information network, which became available on 2 january 2026. bvi economic substance reporting migrates to virrgin: the practical changes the british virgin islands international tax authority (ita) has moved economic substance (es) declarations onto the virtual integrated registry regulatory general information network (virrgin), which became available on 2 january 2026. the transition timeline what is new on the platform reporting and supporting information declarations and relevant activities financial period change requests (t602) processing, bulk filing and fees practical takeaways

the previous position the cjeu's ruling the updated faq key takeaways on 17 july 2026, the european commission updated its consolidated faq guidance on the meaning of "operator" under article 2f(1) of regulation (eu) 833/2014, which prohibits the broadcasting of content from russian media outlets listed in annex xv. the revision follows the court of justice of the eu's judgment in case c-67/25, delivered on 2 july 2026, in which the court departed from the eu commission's prior interpretation. eu updates faq on "operators" under the russia broadcast ban following cjeu ruling the previous position the cjeu's ruling the updated faq key takeaways

the reporting process of actual or potential violations of regulation (eu) no. 596/2014 to the cyprus securities and exchange commission law 2026 published on 6 march 2026, in the official gazette of cyprus (the mar reporting law). key provisions: the reporting process of actual or potential violations of regulation (eu) no. 596/2014 to the cyprus securities and exchange commission law 2026 published on 6 march 2026, in the official gazette of cyprus. cysec's new framework for reporting market abuse violations the reporting process of actual or potential violations of regulation (eu) no. 596/2014 to the cyprus securities and exchange commission law 2026 published on 6 march 2026, in the official gazette of cyprus (the mar reporting law). key provisions:

on 24 june 2026, the cayman islands financial reporting authority (fra) published its 2025 annual report. read it as a positioning exercise: most of the headline developments point towards the jurisdiction's next cfatf mutual evaluation in 2027. what this means in practice on 24 june 2026, the cayman islands financial reporting authority published its 2025 annual report. read it as a positioning exercise: most of the headline developments point towards the jurisdiction's next cfatf mutual evaluation in 2027. consent, crypto and sanctions: five things to watch in cayman’s 2025 fra report on 24 june 2026, the cayman islands financial reporting authority (fra) published its 2025 annual report. read it as a positioning exercise: most of the headline developments point towards the jurisdiction's next cfatf mutual evaluation in 2027. what this means in practice

on 17 july 2026, the cyprus securities and exchange commission (cysec) published circular c792 providing implementation guidance on the active account requirement (aar) and the related representativeness obligation under articles 7a and 7b of regulation (eu) 648/2012 on otc derivatives, central counterparties and trade repositories (emir), as supplemented by regulation (eu) 2026/305. the circular is addressed to cifs, ucits management companies, aifms, and non-financial counterparties. scope the aar requires financial and non-financial counterparties that exceed the clearing threshold to establish and maintain an active account at an authorised european central counterparty (eu ccp). the obligation is limited to: interest rate derivatives denominated in euro or polish zloty and short-term interest rate derivatives denominated in euro. for entities belonging to a group subject to consolidated supervision in the eu, the threshold assessment is performed on a consolidated basis, considering all in-scope contracts cleared by group entities but excluding intragroup transactions. where a counterparty is deemed to be subject to the obligation of holding an active account, it must notify esma and its relevant competent authority and must establish the active account within six months of becoming subject to that requirement. operational and representativeness requirements counterparties subject to the aar must ensure the active account remains continuously operational and capable of clearing at all times. additionally, under the representativeness obligation, a proportion of in-scope derivative contracts must actually be cleared through the eu ccp account, it is not sufficient merely to open an account. a notable carve-out applies counterparties whose aggregate notional amount across in-scope categories does not exceed eur 6 billion (assessed at group level) are exempt from the representativeness obligation, under article 7a(4) emir, though they remain subject to the aar itself. notification and reporting key practical steps for in-scope entities include: notification: entities must notify both cysec (at emir@cysec.gov.cy) and esma (at aar-notifications@esma.europa.eu) using the prescribed excel template. the template format must not be modified. first reporting deadline: the first aar compliance report is due to cysec by 31 july 2026, covering backloaded data from 25 june 2025 onward, in addition to data for 2026. ongoing reporting: thereafter, reports are submitted semi-annually (31 january and 31 july), each covering a twelve-month reference period. entities that subsequently meet the 85 per cent exemption threshold under article 7a(5) emir are encouraged to re-submit the notification template on a voluntary basis to confirm their exempt status. implementation steps cysec expects regulated entities to: assess whether they fall within scope (including at group level); if they do fall within scope, create and maintain an active account at an authorised eu ccp; ensure appropriate legal, operational, and it arrangements are in place to satisfy the requirements under emir and regulation (eu) 2026/305; monitor compliance with the representativeness obligation on an ongoing basis; and maintain sufficient records to demonstrate aar compliance. key takeaway the immediate practical significance of this circular is the tight reporting timeline: entities must assess scope, establish an active account, and submit their first compliance report within two weeks of publication. entities that have not yet begun preparations should prioritise the group-level threshold assessment and the operational readiness of their eu ccp account cysec’s circular c792 can be found here.

on 21 july 2026, the cssf published version 5 of its faq on the sustainable finance disclosure regulation (sfdr). the update modifies a single question, section ii, question 1, but carries practical implications for how luxembourg fund managers assess and process changes to article 8/9 sfdr precontractual templates. what changed question 1 addresses whether changes to the sfdr rts precontractual templates follow the same regime as any other prospectus amendment, and which changes qualify as "material." the revised answer confirms and refines the cssf's position on three key points: templates remain part of the prospectus. the sfdr does not impose specific requirements on the review of article 8/9 precontractual disclosures. accordingly, ordinary prospectus-amendment rules apply, and all changes must be submitted via the "e-identification procedure for uci prospectus and offering document." only material changes require prior cssf review and authorisation, assessed case-by-case under circular cssf 14/591. the updated faq sets out a non-exhaustive list of material changes, namely: material changes to the fund or sub-fund in the context of the esma guidelines on funds' names using esg or sustainability-related terms (esma34-472-440) changes in the sfdr classification (e.g. a shift between article 6, 8 or 9) material changes to the sfdr criteria set-up, including the strategy, index, methodology, investment objective, or a material variation in the threshold. revised materiality framing. the original december 2022 wording centred on minimum committed percentages, binding elements of the investment strategy, and benchmark changes. the july 2026 version replaces that framing with the three categories above, most notably adding explicit references to the esma fund-naming guidelines and to sfdr classification changes as materiality triggers. why this matters interaction with the esma fund-naming guidelines. by expressly linking materiality to the esma guidelines (implemented in luxembourg via circular cssf 24/863), the cssf ties together two previously separate compliance streams, a fund's naming-related self-assessment can itself trigger a material-change process for its prospectus. classification changes are now explicitly flagged. any planned "upgrade" or "downgrade" of a fund's sfdr status (e.g. moving from article 8 to article 6) will require cssf prior review and, for open-ended ucis, the one-month investor redemption right under circular cssf 14/591. clearer decision framework for routine vs prior-authorisation filings. ifms, aifms and ucits management companies now have a more concrete, illustrative checklist for determining whether a template change can proceed as a routine filing or requires prior authorisation and possible investor notice. continuity with the "no gold-plating" approach. as with earlier versions, the cssf is not creating new sfdr obligations but clarifying how existing circular cssf 14/591 materiality concepts apply to sfdr-related prospectus changes, reducing interpretive uncertainty for managers preparing prospectus updates. takeaway although the scope of this update is narrow, a single question, the revised materiality indicators give fund managers a sharper lens through which to assess upcoming template changes. managers reviewing their article 8/9 disclosures should revisit their internal change-management procedures to ensure alignment with the updated faq, particularly where fund-naming assessments or sfdr reclassifications are under consideration. the updated cssf sfdr faq (version 5) can be found here.

in june 2026, the bermuda government published its first-ever proliferation financing national risk assessment (pfnra), prepared by the national anti-money laundering committee (namlc) and aligned with updated fatf recommendations 1 and 7. no direct pf activity, targeted financial sanctions (tfs), or assets linked to designated entities were identified in bermuda. however, the pf nra found there is indirect exposure to pf risks through cross-border financial activity and sectoral vulnerabilities. bermuda’s status as an international financial centre, its expanding digital assets business sector and its diverse range of legal structures present inherent exposure to pf risks. key findings the assessment examined pf threats from dprk, iran, russia and syria, with dprk, iran and russia rated as medium pf threats to bermuda, while syria is rated as low. sector-by-sector vulnerability assessments produced a differentiated risk picture: digital asset businesses (dabs) received the highest vulnerability rating of any sector with a rating of high. the assessment drew a distinction between licence classes: class m (modified) and class f (full) licences were rated high risk, reflecting the breadth of permitted services, cross-border transaction flows, and exposure to impersonation vulnerabilities, while class t (testing) licences were rated medium owing to strict activity limits. no evidence of exploitation by pf actors was identified, but the sector's inherent characteristics were flagged as susceptible to misuse. banking was rated medium only four licenced banks operate in bermuda, and no pf activity has been recorded in the sector; however, the assessment highlighted exposure through cross-border transfers and international correspondent relationships. wealth management and private banking sub-sectors were rated medium, while credit unions were rated low. securities were rated medium, driven by rapid cross-border transactions, multiple intermediaries, and complex corporate investor structures. insurance (long-term), legal sector, trust and corporate service providers were each rated medium, with the trust sector’s rating reflecting its international client base and complex structuring capabilities. counting, real estate, lending, and casino gaming were all rated low. legal persons and legal arrangements were assessed with a medium inherent vulnerability. across all sectors, no instances of pf activity were identified during the assessment period, and no direct sectoral ties to dprk, iran, or syria were found. next steps the pf nra is designed to inform bermuda's national pf action plan and feed into ongoing risk-based supervision. the government has committed to periodic updates to reflect evolving risks and to maintain the integrity of bermuda's financial system. regulated entities should expect the findings to shape supervisory expectations, particularly in the digital asset and banking sectors, where inherent vulnerability ratings are highest. the report can be found here.

the jersey financial services commission (jfsc) published a revised alternative investment funds code of practice (aif code), marking the culmination of a consultation process that began in october 2025. the central change is that jersey's single aif code has been divided into two separate instruments: an eu/eea-focussed code, effective from 16 april 2026, and the existing aif code, which now applies solely to the uk regime. why the split? jersey operates a dual alternative investment fund manager (aifm) regime that complies with both the eu aifmd and the uk aifm regulations, underpinning its ability to access both markets through private placement rules. when the eu updated its directive in april 2024 through eu aifmd ii, with a mandatory implementation deadline of april 2026, jersey needed to adapt accordingly. however, the eu and uk regimes are now diverging. the eu's reforms have been finalised, while the uk's revised approach remains under development. a single code could no longer serve both purposes, so the jfsc opted to split it rather than delay compliance with the eu deadline. what has changed in practice the jfsc has noted that the practical impact on most jersey businesses is minimal. most of the changes apply to full passport aifs and aifms and do not affect the national private placement regime, which is the mechanism through which jersey retains its third-country market access. updated guidance and frequently asked questions have been published alongside the revised code. the consultation process the jfsc's october 2025 consultation paper received one response. the respondent confirmed that the impact of the proposed changes on jersey businesses was not considered material, and no substantive objections were raised. in the absence of material comments, the jfsc confirmed it would proceed as proposed. what comes next a uk-focussed aif code will be introduced once the uk's new approach to aifs and aifms is fully developed. in the interim, the existing aif code continues to apply for uk regime purposes. the jfsc has also confirmed that a new eu annex iv reporting template is expected to be made available in 2027. the jfsc will continue to monitor developments in both the uk and eu that are relevant to aifms. stakeholders with queries may contact the jfsc's policy team at policy@jerseyfsc.org. updated alternative investment funds code of practice, guidance and faqs can be found here. the feedback on the consultation for the changes to the alternative investment fund code to transpose the eu’s alternative investment fund managers directive ii can be accessed here.

in brief: the cayman islands is preparing for its cfatf 5th round of mutual evaluation, with the onsite assessment expected in late 2027. a government request for proposals (rfp) signals that the cayman islands monetary authority (cima) is procuring professional support for sector-level risk assessments. the evaluation will focus on the effectiveness of the jurisdiction’s aml/cft/cpf and sanctions framework. regulated entities should prioritise evidential readiness, including maintaining data and case studies covering up to five years. the rfp and evaluation focus the cayman islands government has published an rfp (reference ppc-2026-cima-046-rfp) for professional services to support cima’s readiness for the cfatf’s evaluation. the evaluation will focus heavily on the effectiveness of the jurisdiction’s aml/cft/cpf and targeted financial sanctions framework, including beneficial ownership and virtual asset services. cima has notes that the 5th round will place greater emphasis on effectiveness, risk and context, and the dnfbps and financial services sectors will be assessed separately. according to the cayman independent newspaper, citing clarification responses published on the procurement portal, the successful bidder would be required to prepare standalone risk assessments for each cima-regulated sector, including banking, insurance, securities, mutual fund administration, money services business, trust and corporate services providers, and virtual asset service providers. the exercise is intended to go beyond updating existing assessments and to reflect changes in fatf standards and evolving financial crime risks. alignment with the national risk assessment the rfp is closely aligned with the cayman islands’ 2025 – 2026 national risk assessment (nra), a one-year initiative to strengthen the aml/cft/cpf framework ahead of the 2027 evaluation. the nra is coordinated by the office for strategic action on illicit finance, with participation from government agencies, regulators and private-sector stakeholders. its objective includes identifying current and emerging ml/tf/pf threats and vulnerabilities, supporting risk-based policy development, maintaining alignment with fatf recommendations, and demonstrating the cayman islands’ commitment to transparency and global cooperation. cima’s 2024-2027 strategic plan identifies support for a positive fatf assessment as a strategic objective. what this means for regulated entities the practical message is that evidential readiness is likely to be as important as formal compliance. cima has encouraged financial service providers to maintain data, statistics and case studies covering up to five years before the onsite inspection, and to be able to demonstrate the effectiveness of their aml/cft/cpf and sanctions controls. cima has also highlighted the need for entity-wide proliferation financing risk assessments, accurate beneficial ownership information, staff training and proactive engagement with the nra process. regulated entities should accordingly anticipate continued regulatory focus on risk assessments, beneficial ownership transparency, sanctions controls, proliferation financing risk and documented remediation of compliance weakness. the rfp can be found here. more information on the 2025–2026 national risk assessment factsheet here and cima’s blog here. cima’s strategic plan 2024-2027 can be accessed here and the press release here.

on 25 june 2026, the jersey financial services commission (jfsc) launched a consultation on proposed changes to its guidance on limited liability companies (llcs), with responses due by 6 august 2026. since the llc structure was introduced in jersey in 2018, only 49 llcs have been registered, a figure that suggests the current framework has constrained uptake. the jfsc, working with an industry working group, is now proposing four targeted changes designed to make the vehicle more versatile. notably, none of the proposals require amendments to primary legislation; they are changes to the jfsc's own regulatory guidance only. what's changing? llcs as corporate trustees. the consultation proposes permitting llcs to act as corporate trustees, following recent amendments to the trusts (jersey) law 1984 that removed the ambiguity over whether an llc could satisfy the statutory requirements for a corporate trustee. this is a notable expansion of the llc's functional role in jersey trust structures. use for regulated financial services activities. the jfsc proposes to allow llcs to carry on fund services business, trust company business, investment business, general insurance mediation business, and money service business under the financial services (jersey) law 1998 (fsjl). the consultation notes that neither the fsjl nor the llc law prohibits this, the change is to the jfsc's own guidance rather than to primary legislation. the standard authorisation process would continue to apply. removal of the "financially sophisticated investor" restriction. currently, llcs are limited to use by financially sophisticated investors or customers. the jfsc proposes to drop this restriction entirely. key safeguards remain in place: administration services must still be provided by a regulated trust company business. regulated firms' duties under the relevant codes of practice, including the obligation to have due regard to customer interests, are unaffected. improved clarity of the guidance. the consultation includes a draft revised guidance note (appendix a) intended to be clearer, more accessible, and more proportionate. why it matters taken together, these proposals represent a deliberate effort to reposition the jersey llc as a mainstream structuring option rather than a niche vehicle. the ability to use llcs for regulated activities and as corporate trustees could make them a more competitive alternative to jersey companies and limited partnerships in fund, trust, and financial services structures. the removal of the sophisticated investor limitation is particularly significant, as it eliminates a gating criterion that had no direct equivalent in the underlying legislation. next steps responses can be submitted via the jfsc's online survey by 6 august 2026. the jfsc expects to publish its feedback, and outline implementation plans in september 2026. the industry update can be found here. the consultation can be found here and the executive summary here.

on 17 june 2026, the cayman islands department for international tax cooperation (ditc) published an industry advisory, on behalf of the tax information authority, setting out updates to the common reporting standard (crs) regime and a change to how economic substance (es) communications will be issued. the following summarises the key developments for cayman islands financial institutions (fis) and responsible persons (rps). 2025 crs filing deadline remains 31 july 2026 industry is reminded that the deadline for the submission of 2025 crs xmls and/or 2025 crs filing declarations remains 31 july 2026. closure of the ditc portal for crs xml submissions the ditc portal will be closed for the submission of crs xmls and filing declarations in early august 2026 as a consequence of the transition to crs xml schema version 3.0 (xml v3.0). all other portal functionalities will remain operational. the practical implications are as follows: no new crs xml files or amendments to previous submissions will be possible until the functionality is reinstated (and this is anticipated to take place in early 2027). the closure does not extend the 31 july 2026 filing deadline. fis must ensure 2025 reporting year reportable accounts are submitted by the filing deadline. impact on the 2026 reporting year (30 june 2027 filing deadline) the advisory sets out several changes that will take effect in respect of the 2026 reporting year, which carries a filing deadline of 30 june 2027. transition to crs xml schema v3.0: following the re-opening of the ditc portal, fis will be required to submit any new reportable accounts, corrections, or deletions using xml schema v3.0. the updated oecd crs xml schema user guide (v4.0) and the xml schema v3.0 xsd files are available on the oecd tax transparency resource centre, and a summary of the new reporting fields is provided in the amended crs quick guide. transitional measures: the user guide (v4.0) addresses cases where an fi submits corrections under xml schema v3.0 and, as a result, there are new fields that were not included in a filing previously submitted under xml schema v2.0. withdrawal of the crs xml generator tool: with the transition to xml schema v3.0, the ditc will no longer provide an xml generator tool. updated crs self-certification forms (effective 1 january 2026) to align with the tax information authority (international tax compliance) (common reporting standard) (amendment) regulations, 2025 (the amendment regulations), the ditc has published an updated individual self-certification form and entity self-certification form on its website. industry should note the following: the forms highlight which fields are applicable under regulation 7 of the principal regulations, as amended by regulation 3 of the amendment regulations. neither form is a mandatory template; an fi may use its own form but must, as a minimum, collect the mandatory data set out in the principal regulations as amended. updated crs administration forms and guidelines the ditc is updating the portal administration forms to align with the amendment regulations, with these forms and further crs industry guidance both expected in q3 2026. ditc portal security enhancement two-factor authentication, currently required for account activation, will be extended to all access to the ditc portal, with further guidance anticipated in q3 2026. change to economic substance communications the ditc has historically issued courtesy email reminders to rps ahead of the es filing deadline, alongside the ditc portal messaging banner. noting that the es act came into force on 1 january 2019 and that its deadlines are now familiar to industry, the ditc has confirmed the following: courtesy reminder emails to rps will cease for esn year 2025 onward, with es reminders provided only via the ditc portal messaging banner. entities remain responsible for compliance with all applicable es reporting obligations and deadlines. taken together, these updates signal a shift towards greater self-reliance for fis and rps, given the end of es courtesy reminders and the withdrawal of the crs xml generator tool. with the portal closing to crs xml submissions in early august 2026 and reopening only in early 2027 under xml schema v3.0, fis should finalise and submit their 2025 crs filings ahead of the 31 july 2026 deadline and prepare for the v3.0 transition. for further details, the industry advisory can be found here.

on 22 june 2026, the proceeds of crime (anti-money laundering and anti-terrorist financing) amendment regulations 2026 came into force, amending the proceeds of crime (anti-money laundering and anti-terrorist financing) regulations 2008. the headline development is that bermuda's regulatory framework now expressly addresses proliferation financing (pf) and counter-proliferation financing (cpf), moving the regime from an "aml/atf" footing to an "aml/atf/cpf" one. a new defined target what this means in practice the sanctions linkage is explicit practical takeaways on 22 june 2026, the proceeds of crime amendment regulations 2026 came into force, amending the proceeds of crime regulations 2008. the headline development is that bermuda's regulatory framework now expressly addresses proliferation financing and counter-proliferation financing, moving the regime from an "aml/atf" footing to an "aml/atf/cpf" one. bermuda extends its aml/atf regime to capture proliferation financing on 22 june 2026, the proceeds of crime (anti-money laundering and anti-terrorist financing) amendment regulations 2026 came into force, amending the proceeds of crime (anti-money laundering and anti-terrorist financing) regulations 2008. the headline development is that bermuda's regulatory framework now expressly addresses proliferation financing (pf) and counter-proliferation financing (cpf), moving the regime from an "aml/atf" footing to an "aml/atf/cpf" one. a new defined target what this means in practice the sanctions linkage is explicit practical takeaways

on 22 june 2026, the proceeds of crime (anti-money laundering and anti-terrorist financing) amendment regulations 2026 came into force, amending the proceeds of crime (anti-money laundering and anti-terrorist financing) regulations 2008. the headline development is that bermuda's regulatory framework now expressly addresses proliferation financing (pf) and counter-proliferation financing (cpf), moving the regime from an "aml/atf" footing to an "aml/atf/cpf" one. a new defined target the amendments insert two definitions into regulation 2: "cpf" is defined as counter-proliferation financing. "proliferation financing" captures the provision of funds or financial services used, in whole or in part, in the manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer or stockpiling of, or otherwise in connection with the possession or use of, chemical, biological, radiological or nuclear (cbrn) weapons. the definition extends to the means of delivery of such weapons and to other cbrn-related goods and technology for non-legitimate purposes in contravention of international sanctions obligations in operation in bermuda. the sanctions nexus is significant: pf is framed not as a free-standing predicate but by reference to bermuda's existing international sanctions obligations. what this means in practice rather than create a parallel regime, the amendments thread pf and cpf through the existing obligations, so the operative requirements are largely unchanged in mechanism but broadened in scope: risk assessment and controls now expressly extend to proliferation financing, with "or terrorist financing" replaced by ", terrorist financing or proliferation financing" across the customer, business and risk-assessment provisions (regulations 6, 8, 10, 16, 17 and 18, and the schedule). the "aml/atf" shorthand becomes "aml/atf/cpf" in the policies, procedures and controls provisions (regulations 12, 14a and 17a), so internal frameworks, documentation and governance references will need to be updated to reflect the third limb. counter-proliferation financing control is added as a distinct control category alongside aml and atf controls (regulations 11(3)(c), 12a(c) and 18(2)(b)). the sanctions linkage is explicit two changes tie the regime more closely to sanctions compliance: regulation 9(1)(d) now also refers to the international sanctions act 2003 and any regulations made under it, extending the relevant statutory basis beyond the anti-terrorism (financial and other measures) act 2004. regulation 11(3b)(c) is expanded so that internal reporting captures "breaches of international sanctions obligations" in addition to aml/atf offences. practical takeaways regulated persons should revisit business and customer risk assessments to ensure pf is identified and assessed as a discrete risk, not subsumed within terrorist financing. aml/atf policies, procedures and training materials should be re-papered to the aml/atf/cpf standard, including a dedicated cpf control framework. internal reporting and escalation channels should be reviewed so that suspected sanctions breaches are routed alongside aml/atf concerns. the amendments align bermuda more closely with fatf expectations on proliferation financing, but the practical burden lies in operationalising the new cpf limb across existing systems rather than in any wholesale change to the compliance architecture. proceeds of crime (anti-money laundering and anti-terrorist financing) amendment regulations 2026 can be accessed here. the proceeds of crime (anti-money laundering and anti-terrorist financing) regulations 2008 can be found here.

on 1 july 2026, the luxembourg government introduced a bill proposing a new tax framework for employee stock option plans (plans d'options sur titres) issued by qualifying young innovative companies (jeunes entreprises innovantes). the bill also codifies the general tax treatment of stock options at the legislative level. the new regime will apply to options granted from tax year 2027 onwards, whether the plan is newly established or already in place. key features of the new regime single taxable event at the moment of sale: under the proposed regime, the only point at which tax is triggered is when the employee actually sells the shares. the grant, vesting, and exercise of the option are all tax-free events. the benefit arising on exercise is valued at zero for tax purposes, meaning no tax liability arises even where the share value significantly exceeds the exercise price at that point. this eliminates the need for complex interim valuations, a longstanding practical difficulty for unlisted start-ups. general capital gains rules do not apply: the general provisions on speculative gains and substantial participation disposals are expressly disapplied. the sale of shares acquired through the option plan is taxed exclusively under this new regime, regardless of the employee's participation percentage or how long they held the shares. reduced tax rate: the capital gain on disposal (sale price minus the exercise price paid by the employee) is taxed as extraordinary income at one-quarter of the employee's overall tax rate. the exercise price can be freely set by the employer, including at zero, as long as it is clearly stated in the plan. if the exercise price is zero, the full sale proceeds constitute the taxable gain. opt-in mechanism: the regime is elective. the employer must expressly opt in on a plan-by-plan basis. companies that meet the eligibility criteria may still choose to apply the general regime to any given plan. eligibility criteria for the employer: to qualify, the issuing company must satisfy all of the following conditions, assessed as at the close of the financial year preceding the year of grant: incorporated less than 10 years ago; fewer than 150 full-time equivalent employees; balance-sheet total or turnover not exceeding €30 million; r&d spending of at least 15 per cent of total expenditure; at least 2 full-time equivalent persons working for the company; eligibility certified by an approved statutory auditor or chartered accountant; activities of a genuinely innovative character; not operating in certain excluded sectors (including law firms, audit/accounting firms, real estate companies, sicars, listed entities, and entities resulting from mergers or demergers); and notably, companies that have distributed dividends or reduced their share capital since incorporation are not excluded from this regime (unlike under the existing start-up tax credit regime). conditions for the option plan itself: options must be non-transferable and unlisted; the employee must not hold (directly or indirectly) more than 25 per cent of the capital, voting rights, or profit rights at the time of grant or during the preceding 24 months; options must not replace any element of the employee's existing remuneration; and the employee must be a luxembourg tax resident (or a former resident domiciled there for more than 15 years) at the time of disposal. employer reporting obligations: the employer must submit prescribed electronic documentation to the tax authorities by 1 march of the year following the grant or exercise. this includes, in particular, the group structure and evidence supporting the qualifying conditions. non-compliance results in the regime not applying. codification of the general stock option regime: separately, the bill codifies the general rules previously governed only by administrative practice. a distinction is drawn between freely transferable options (taxed at grant, valued using recognised methodologies such as black-scholes) and non-transferable options (taxed at exercise, based on the difference between market value and the exercise price). these provisions will now sit in a dedicated statutory framework, improving legal certainty. virtual or phantom stock options are expressly excluded from both regimes. this bill forms part of the government's march 2025 action plan for start-ups and responds to broader eu initiatives, including the european commission's "blue carpet" package and the eu inc. proposal, which emphasise employee equity incentives as a means of retaining talent within the single market. the text of the bill can be consulted here.