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ESMA Statement On MiCAR Transitional Measures
The European Securities Markets Authority (ESMA) has issued a statement on the discretionary transitional regime for cryptoasset service providers (CASPs) that offered their services in accordance with applicable law prior to 30 December 2024, contained in the markets in cryptoassets regulation (MiCAR). Member States may decide not to apply the transitional regime or to reduce its duration....By: A&O Shearman
European Commission Publishes Capital Market Integration Package
The European Commission (EC) has published a Communication to the European Parliament, the European Council, the Council, the European Central Bank, the European Economic and Social Committee and the Committee of the Regions on further development of capital market integration and supervision within the Union, announcing a set of major legislative reforms. The package seeks to address obstacles to innovation and barriers to integration resulting from divergent rules, duplicative requirements and...By: A&O Shearman
Bank Of England Launches SWES Exercise Focused On Private Markets
The Bank of England (BoE) has launched its second system-wide exploratory scenario (SWES) exercise, this time focused on the private markets ecosystem. It will be run in collaboration with a group of banks and NBFIs active in these markets. Its aim is to better understand how banks and non-banks active in private markets would respond to a severe but plausible global downturn, how their actions interact at a system level, and whether these interactions can amplify stress across the financial...By: A&O Shearman
The General Court Of The CJEU Clarifies The Scope Of VAT Exempt Negotiation Services
The question referred to the Court was whether a comprehensive mortgage intermediation service that proactively sources clients, provides product information, assists with documentation, transmits and tracks proposals, compares offers, advises on financing terms, communicates decisions, and operates on a success-based remuneration model, should be viewed as a VAT exempt negotiation service. The question was raised, in particular, considering that it was found that the intermediary had neither...By: DLA Piper
UK Provisional Licences Authorisation Regime
The UK's Treasury has published a policy update on creating a provisional licences authorisation regime for early-stage financial services firms seeking FCA authorisation. The purpose is to reduce the barriers that financial services firms face when seeking authorisation. The proposed "provisional licences" regime will enable the FCA to grant time-limited permissions (generally up to 18 months) so that firms can get "up and running" in a controlled environment with strong regulatory oversight,...By: A&O Shearman
OCC Issues Preliminary Findings on Its Supervisory Review of Large Banks’ “Debanking” Activities
On December 10, the Office of the Comptroller of the Currency (OCC) released preliminary findings from its supervisory review of “debanking” activities at the nine largest national banks. The objective of the review was to determine whether the banks debanked or discriminated against any customers or potential customers on the basis of their political or religious beliefs or lawful business activities. The review, which was required to be completed by the OCC and other federal banking agencies...By: Troutman Pepper Locke
Fed Requests Input, Looks to Change Check Services
On December 9, 2025, the Federal Reserve published a Request for Information seeking public input on the future of its paper check services. The RFI highlights the possibility of the Fed forgoing future investments in check infrastructure, streamlining current offerings, materially upgrading infrastructure, or even ending the services altogether......By: Davis Wright Tremaine LLP
Changes To EU List Of High-Risk Third Countries With Strategic AML/CTF Framework Deficiencies
The European Commission (EC) has announced that it has listed Russia as a high-risk country with strategic deficiencies in its anti-money laundering and counter-terrorist financing frameworks (AML/CFT) pursuant to the EU's directive on anti-money laundering and terrorist financing (AMLD IV). This follows Delegated Regulation (EU) 2025/1393, adopted in July, which committed the EC to conclude a review of third countries not listed by the Financial Action Task Force (FATF), but whose membership is...By: A&O Shearman
Food Venture Financing News – Weekly Issue No. 264
Food Venture Financing Trends - Campbell's is purchasing a 49% stake in La Regina, the maker of Rao's pasta sauce, for $286 million....By: Davis Wright Tremaine LLP
UK FCA Finalises Policy On Streamlining Complaints Data Reporting
The UK Financial Conduct Authority (FCA) has published policy statement PS25/19, confirming final rules to modernise complaints reporting. Following its May consultation, the FCA confirms the rules largely as proposed, including: replacing five existing returns with a single consolidated return; removing group-level reporting; updating complaints categorisation to reflect evolving product types; improving guidance on products subject to complaints reporting; and introducing a category to capture...By: A&O Shearman
Hybrid Horizons: Investor Group Issues in Hybrid Capital Transactions: Approvals, Sacred Rights and Disproportionate Treatment
Other installments in our Hybrid Horizons series address issues faced by holders of Hybrid Capital instruments tied to the nature of the security itself and how Hybrid Capital instruments govern the rights and obligations of the Issuer and the investor group collectively. This article discusses inter-investor group dynamics -- issues to consider regarding the internal workings of a group of unaffiliated investors who participate in a Hybrid Capital issuance....By: Proskauer Rose LLP
Insider Job and Dōmo Arigatō Mr. Roboto
Judge delays sale of Genesis to insider, ‘concerned’ about creditors’ claims, bidder controversy | McKnights - The company had been seeking approval for a “stalking horse” bid submitted by an affiliate of Genesis’ private equity owner....By: Seward & Kissel LLP
US dollar licks wounds following bruising week
Pound (GBP) muted amid fiscal credibility questions - The pound (GBP) was subdued on Friday as headlines around the UK autumn budget eroded some of the optimism seen after its announcement on Wednesday....By: IR Global
[Video] 10 For 10: Top Compliance Stories For the Week Ending December 13, 2025
Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings you the compliance stories you need to know to end your busy week. Sit back, and in 10 minutes, hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance,...By: Thomas Fox - Compliance Evangelist
Leveraged Lending Guidance Withdrawn by OCC and FDIC
On December 5, 2025, the Office of the Comptroller of the Currency (“OCC”) and Federal Deposit Insurance Corporation (“FDIC”) rescinded guidance on leveraged lending activities by banks. The rescissions should come as a welcome relief to the banking industry, allowing banks to better apply enterprise-wide risk management programs to this type of lending and potentially create additional competition in the private credit loan market....By: Mayer Brown
The UK’s New Anti-Corruption Strategy – Linking Growth to a Tougher Enforcement Agenda
There is a clear sense that the current UK Government wants to put criminal justice reform back on the agenda – and economic crime is a big part of that. Fraud and corruption plainly cost the UK economy huge sums, yet successive governments have struggled to get to grips with either. Chronic under-resourcing of key enforcement agencies such as the UK Serious Fraud Office, relative to their international counterparts, is clearly part of the problem....By: Hogan Lovells
When Privacy Rules Meet Fund Finance, December 2025 - The New Regulation S-P Amendments and What They Mean for Lenders in Fund Finance
The SEC's 2024 amendments to Regulation S-P introduce the most comprehensive update to federal privacy and data security standards for SEC-regulated institutions since the rule was adopted. While the amendments are directed at investment advisers, registered funds, broker dealers, and transfer agents – not lenders – fund finance deal teams are already seeing the effects....By: Cadwalader, Wickersham & Taft LLP
Mr. Worldwide: FINRA’S Rule 8210 Reminder to Broker-Dealers
FINRA lacks subpoena power. In lieu, Rule 8210 is the backbone of its self-regulatory framework. Failure to comply or providing incomplete or untruthful responses can lead to severe sanctions, including expulsion for firms and bars for individuals....By: Gray Reed
New York Enacts 2022 UCC Amendments Creating New Regime for Digital Assets Under State Law
New York has now joined with 32 other states and the District of Columbia in enacting the 2022 amendments to the Uniform Commercial Code (UCC) promulgated by the American Law Institute and the Uniform Law Commission. The amendments become effective in New York on June 3, 2026....By: Morgan Lewis
Cryptoassets: OFSI’s Sanctions Threat Assessment
The UK has a number of sanctions that can be engaged by crypto-related activities. Most notably, its asset freeze restrictions prohibit making funds or economic resources available to, or dealing with the funds or economic resources of, those subject to UK asset freeze measures. This means that transferring crypto-assets to, or receiving them from, designated persons can breach UK sanctions; in addition, in certain circumstances facilitating such a transfer would also breach UK sanctions....By: Hogan Lovells
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