On 24 March 2026, the Financial Conduct Authority (FCA) announced that it will set out its approach to motor finance redress on Monday 30 March 2026 shortly after markets close. This follows the FCA’s consultation on establishing a compensation scheme in October 2025.

In the first episode of our global Future of Payments mini-series, we are joined by EU colleagues who discuss the Payment Services Directive 3 and the Payment Services Regulation. Together, we explore five key topics that are front of mind for the industry right now – fraud, transparency and consumer protection, supervision, MiCA, and the all-important question of timing. Listen on Spotify Listen on Apple

On 23 March 2026, the Australian Prudential Regulation Authority (APRA) issued a consultation on the implementation of the Retirement Reporting Framework (the Framework).BackgroundIn November 2024, the Government announced a package of reforms in response to feedback on the superannuation in retirement consultation. This included the introduction of a new reporting framework on retirement outcomes to foster greater transparency and enable monitoring of member outcomes in retirement.The Framework is one of several Federal Government initiatives to uplift the retirement phase of superannuation. Following a Treasury-led consultation through 2025, the Government announced the final high-level design of the Framework on 23 February 2026. The purpose of the Framework is to enable monitoring of the outcomes delivered to members in retirement in a consistent and transparent way and support trustees to measure their progress in implementing the retirement income strategies required by the Retirement Income Covenant (Covenant). Data is expected to be collected by APRA, to provide insights on fund offerings and member outcomes, and help track progress with retirement phase uplift.ConsultationThe design specifications for the Framework that were released by the Government specify the indicators and metrics, and attributes for member cohorts, for the collection. However, these are expressed at a high-level, with the detailed implementation, including design of reporting standards and forms required to be undertaken by APRA.As such the consultation paper focuses on APRA’s approach to implementing the Framework and focuses on key concepts, indicators, metrics and member cohorts and attributes.Consistent with the application of the Covenant, APRA is proposing that the collection will apply to all Registerable Superannuation Entity (RSE) licensees. However, for the purposes of the Framework, APRA proposes that members that only have a defined benefit interest and may be excluded from the Covenant via subsection 52AA(3) of the Superannuation Industry (Supervision) Act 1993 (Cth), are excluded from the collection. Where the RSE licensee is a trustee of more than one RSE, the RSE licensee will need to separately provide the information required for each RSE within its business operations.For the Framework indicators, APRA proposes RSE-level data will be collected on services and offerings made available to members. The specific focus areas are alternative drawdown options, lifetime income products and personal financial advice services.Three Framework metrics will quantify how RSE licensees are supporting members by examining member behaviour across the retirement landscape, including the types of retirement products, including lifetime income products, held by members, drawdown levels and value of benefit payments and balance utilisation and actions taken when an account is closed. Member attributes such as age, sex type, members’ benefit bracket, product holdings, and retirement status indicator are used to define member cohorts in relation to the metrics. Collection at the member-cohort level allows metrics to be considered at an industry level, an RSE level and by various member segments.To implement the Framework’s indicators, metrics and attributes, APRA is proposing to: Issue a new Reporting Standard SRS 611.1 Retirement Member Profile. Revise the existing Reporting Standard SRS 607.0 RSE Business Model. Update associated definitions by revising the existing Reporting Standard SRS 101.0. APRA has issued drafts of these documents alongside the consultation paper.APRA is also proposing to revoke the existing SRS 610.0 Membership profile to streamline the overall reporting requirements.In addition, APRA has published a technical paper which contains tables that: Describe the formula that will be used to inform each indicator or metric. Map each data point in the calculation formula to the relevant reporting standard and corresponding column/item number. Outline the filters applied to isolate specific data demographics. Next stepsThe deadline for responding to the consultation is 3 June 2026.APRA will soon commence consultation on how to give effect to the collection and publication of the indicators and metrics. Data is expected to first be collected in 2027.APRA is targeting release of final reporting standards in Q3 2026 and first collection in Q4 2027. These dates are subject to ensuring due consideration of any material matters raised through consultation.APRA intends to publish data annually commencing in 2028.

On 23 March 2026, the Basel Committee on Banking Supervision (Basel Committee) issued a document containing a technical amendment on the standardised approach to operational risk.In June 2025, the Basel Committee issued a proposed technical amendment for consultation related to the standardised approach to operational risk. The technical amendment sought to clarify the treatment of “rental income from investment properties” under the business indicator, which is used as a key input in calculating operational risk capital requirements.The document now published sets out the final revised standard which the Basel Committee has agreed to implement by 1 April 2029. The revised text has also been incorporated into the consolidated Basel Framework (OPE – Calculation of Risk Weighted Assets for operational risk). Also, the Basel Committee has finalised a response to an FAQ on market risk and consequential amendments to related FAQs which have also been added to the Basel Framework and are set out in the document’s annex for information.

On 23 March 2026, the Financial Conduct Authority (FCA) published a statement which highlights risks when dealing with unregulated lenders.SummaryThe FCA set out that it is reminding regulated firms that they need to undertake proper checks when dealing with unregulated lenders, safe custody providers, money brokers and financial leasing companies, also known as ‘Annex 1’ firms.The FCA has highlighted, in particular, that: FCA powers are currently limited to looking at how these firms are meeting their anti-money laundering obligations and these firms are not subject to the wider FCA Handbook, that this regime is based on registration and is different from the authorisation regime under the Financial Services and Markets Act 2000, and that customers of Annex 1 firms are not able to access the Financial Ombudsman Service (FOS).   When dealing with Annex 1 firms, FCA regulated firms must do their due diligence to understand the firm’s business, including seeking direct confirmation from the firm of their registration status, conducting independent checks of the information they provide, and understanding and managing any risks.   The FCA will continue its proactive and reactive work in relation to the anti-money laundering standards observed by Annex 1 businesses.   In some cases, consumers have been encouraged to set up limited companies to access lending from Annex 1 firms and, in such cases, it is important these consumers understand they will not have access to the FOS if things go wrong.

On 23 March 2026, the Financial Conduct Authority (FCA) published information and examples of good and poor practice for firms designing consumer segments for targeted support.BackgroundThe FCA published its policy statement on targeted support in February 2025 and also stated that it would publish further detail to support firms in making judgements when designing consumer segments. As a result, it is now setting out practical examples to help firms make these judgements.Key examplesThe FCA highlighted relevant examples, including the following: Defining common characteristics: The FCA makes clear that firms have to judge how to design consumer segments at a sufficiently granular level while not needing to comprehensively consider the consumer’s circumstances or characteristics and, therefore, that the complexity of a situation is likely to be relevant to the type and/or number of common characteristics firms’ need to consider. For example, more complex situations will usually require a higher number, or more detailed set, of common characteristics, whereas it is likely to be possible to specify a suitable ready-made suggestion for a less complex situation based on fewer, or less detailed, common characteristics. Considering data held on a consumer: The FCA explains that it does not expect firms to consider all the data they hold on a consumer or for them to undertake detailed searches of individual customer transactions to capture wider data beyond that needed to align a consumer with the common characteristics of a consumer segment, but that they should consider what is readily accessible (or ought to be) to the specific business area providing targeted support. Using reasonable assumptions: The FCA highlighted, in relation to overreliance on assumptions, that the suitability of a ready-made suggestion will need to be assessed by reference to the shared financial support need or objective and, where relevant, common characteristics and that where information is material to suitability for the consumer segment (i.e. if an assumption was wrong, then there is a more than negligible risk that the recommendation would be unsuitable for the consumer segment) it should be reflected as a common characteristic.

On March 12, 2026, the Commodity Futures Trading Commission took two significant actions furthering the development of a regulatory framework for prediction markets. First, the CFTC issued a staff advisory outlining current regulatory expectations for listing and trading event contracts on prediction markets. Second, the CFTC published an advance notice of proposed rulemaking, signaling the intent to develop a comprehensive regulatory framework for these markets.Read our alert here.

BaFin has announced immediate changes to its administrative practice for attributing and disclosing voting rights. Although this change might lead to greater certainty for ESG collaborative engagement firms will still need to consider the implications for their ESG collaboration among institutional investors and review their internal policies and procedures.  By way of background, institutional investors often come to an agreement with each other in order to more effectively represent their positions on ESG topics vis-à-vis the companies in which they invest. However BaFin noted previously that such agreements can be classified as “acting in concert” and have unintended consequences.On March 20, 2026, the German regulator, the Federal Financial Supervisory Authority (BaFin), issued a supervisory notice announcing immediate changes to its administrative practice for attributing and disclosing voting rights under the German Securities Trading Act (WpHG) in light of the Court of Justice of the European Union’s judgment of February 12, 2026 (Case C‑864/24).In Case C‑864/24, the Court of Justice of the European Union held that the wording of Section 34(2) of the WpHG concerning “acting in concert” (AiC) is incompatible with European Union law insofar as it exceeds the scope of the Transparency Directive. According to the Court, a national provision that departs from the Transparency Directive by imposing a stricter attribution regime is permissible only where such a rule is directly connected with takeover bids, mergers, or other transactions affecting the ownership structure or control of companies.Effective immediately and until the German legislator amends Section 34(1) and (2) WpHG to align with EU law, BaFin will: Narrow the AiC attribution concept under Section 34(2) WpHG to the standard reflected in the Transparency Directive. Going forward, an AiC attribution under Section 34(2) WpHG will be recognized only where there is an agreement that binds the parties to pursue, on a long‑term basis, a common policy regarding the issuer’s management. Discontinue applying Section 34(1) sentence 1 nos. 3 and 5 WpHG as bases for voting-rights attribution for transparency purposes, because the Transparency Directive contains no corresponding attribution grounds. It should be noted that the respective administrative practice set out in BaFin’s Issuer Guidelines and in BaFin’s FAQs on the transparency obligations pursuant to Sections 33 et seq. of the WpHG no longer applies.At the same time, BaFin will continue to apply and interpret Section 30 of the German Securities Acquisition and Takeover Act (WpÜG) unchanged in proceedings under the WpÜG in conjunction with the provisions of the WpÜG Offer Regulation and, where applicable, the German Stock Exchange Act.

On 20 March 2026, the Financial Conduct Authority (FCA) published the terms of reference for its market study into later life mortgages.BackgroundThe FCA explained that it’s launching a market study to examine whether change is needed to enable the lifetime and retirement interest only mortgage sector to meet consumers’ changing needs.SummaryThe FCA highlighted that this market study will investigate challenges in this market, including: Understanding if the market can and will develop to meet the increased and differing needs of consumers in the future. Considering how the FCA can help it adapt and that, where change is needed, the FCA will focus on implementing solutions that let consumers easily access products and services which meet their needs and provide fair value. Considering whether action may be needed outside of the FCA’s remit and that it may make recommendations to other bodies, where relevant. Next stepsThe FCA expects to publish a progress update and proposed next steps by the end of 2026 and that it is inviting all stakeholders to share their views on the issues set out in these terms of reference, including supporting evidence where relevant, by 17 April 2026.

On 19 March 2026, the Financial Conduct Authority (FCA) published its approach document (version 7) on payment services and electronic money. The approach document describes the FCA’s approach to implementing the Payment Services Regulations 2017 and the Electronic Money Regulations 2011, and is aimed at businesses that are, or are seeking to become: authorised payment institutions or small payment institutions (collectively – PIs); authorised e-money institutions or small e-money institutions (collectively – EMIs; registered account information service providers (RAISPs); and credit institutions, which must comply with parts of the PSRs 2017 and EMRs when carrying on payment services and e-money business. The approach document amends version 6, from November 2024 of the FCA’s approach. This version includes updated guidance on exemptions from strong customer authentication, including the contactless payments exemption in Chapter 20.

On 11 March 2026, the Financial Action Task Force (FATF) issued a report, Understanding and Mitigating the Risks of Off-shore Virtual Asset Service Providers.The FATF has issued this report so that parties may better understand the risks of off-shore Virtual Asset Service Providers (oVASPs) with a view to identifying good practices in mitigating these risks. The report also presents good practices to detect, license or register oVASPs, as well as to enforce sanctions for non-compliance with anti-money laundering obligations and roll-out mitigating measures (e.g., reducing unregistered or unlicensed oVASPs’ ability to actively provide services in a market where they are not regulated). It concludes with possible recommendations for stakeholders and should be read alongside the FATF’s broader guidance and work on virtual assets.

In parallel with shifting foreign policy objectives and geopolitical change, we are seeing a wave of regulatory action concerning sanctions across the United States, Canada, the European Union and the United Kingdom. Our international trade and sanctions team outlines some of the key developments below, including enforcement and key jurisdictions targeted by authorities.United States Regulatory Developments: In a series of actions beginning January 2026, the Office of Foreign Assets Control of the US Department of the Treasury (OFAC) issued a suite of new Venezuela-related general licenses that collectively mark a significant evolution in U.S. sanctions policy toward Venezuela’s energy sector.  Notably, OFAC issued General License (GL) 46 in late January to authorize certain activities involving Venezuelan-origin oil (which was subsequently replaced by GL 46A in February), followed by GL 30B in February to facilitate port and airport operations, and on March 4 issued new guidance around GLs 48, 49, and 50A that opens additional pathways for due diligence, contingent contracting, and certain oil and gas sector operations, subject to conditions and exclusions.  At the same time, OFAC has continued to police sensitive transactions through targeted restrictions and interpretive guidance, including on resale of Venezuelan-origin oil to Cuba, signalling that U.S. policy is not a wholesale rollback of Venezuela sanctions but rather a controlled easing for specified commercial activity viewed by the U.S administration as consistent with current U.S. policy. In another notable development, the U.S. government used the Protecting American Intellectual Property Act (PAIPA) for the first time to sanction a Russia-based zero-day exploit broker, Sergey Zelenyuk, his company Operation Zero, and related affiliates for the acquisition and sale of stolen U.S. cyber tools and trade secrets that Treasury said were harmful to U.S. national security.  Treasury stated that the network acquired at least eight proprietary cyber tools developed exclusively for the U.S. government and select allies and paired the State Department’s PAIPA designations with OFAC cyber-related designations under E.O. 13694, as amended, as well as related SDN listings for associated individuals and entities.  This coordinated action is significant for companies with sensitive technology and IP because it shows that the U.S. government is prepared to treat major trade secret theft not merely as a criminal or civil enforcement matter, but as a sanctions issue where the theft is viewed as materially threatening U.S. national security or foreign policy interests.  More broadly, the action signals that PAIPA may become a more regular sanctions tool in high-impact IP theft and cyber-enabled misappropriation cases, particularly where stolen technology has dual-use, intelligence, or government-facing applications. Lastly, against a backdrop of heightened regional escalation, the Administration has continued to sharpen its Iran sanctions.  In January and February 2026, OFAC imposed additional sanctions on shadow-fleet vessels, operators, and illicit petroleum traders, and on February 25 Treasury sanctioned more than 30 individuals, entities, and vessels tied to Iranian petroleum sales, ballistic missile procurement, advanced conventional weapons production, and UAV-related networks.  Separately, on February 27, the State Department designated Iran as a “State Sponsor of Wrongful Detention,” underscoring the Administration’s willingness to pair traditional Iran program sanctions with newer detention-related authorities as part of a broader pressure campaign. At the same time, the Administration has adopted a revised approach to energy market disruption through the issuance of Russia GL 133.  On March 5, 2026, OFAC issued Russia GL 133 which authorizes transactions “ordinarily incident and necessary to the sale, delivery, or offloading” of Russian-origin crude oil and petroleum products (collectively, “products”) to India.  Notably, GL133 explicitly authorizes transactions where Russian-origin products are “produced by entities sanctioned” under certain Russian and Iranian sanctions programs, and/or loaded onto “vessels blocked” under these programs.  In a social media post on March 5, 2026, U.S. Treasury Secretary Bessent commented that GL 133 is designed as a “short-term measure” to “enable oil to keep flowing to market”, authorizing transactions “involving oil already stranded at sea”.  Enforcement: OFAC’s public enforcement docket in early 2026 has been limited in volume but clear in message.  To date, OFAC had announced two public civil enforcement actions totalling over five million USD, against IMG Academy and an individual who provided managerial services to Syrian companies.  The enforcement highlights suggest that OFAC remains focused less on novel theories than on core compliance failures, particularly dealings with blocked persons, inadequate screening, and the absence of risk-based controls even outside traditional financial-sector settings. In 2026, export control enforcement appears to be centred on high-end technology, China- and Russia-related diversion risk, and strong expectations for enterprise-wide compliance controls.  The U.S. Department of Commerce, Bureau of Industry and Security’s (BIS) early 2026 actions already reflect that emphasis: in February, BIS imposed a $252 million penalty on Applied Materials for unlicensed semiconductor-equipment exports involving a China Entity List customer, describing it as the second-highest BIS penalty ever and requiring audits and compliance certifications as part of the resolution.  The U.S. Department of Justice continued to pursue criminal cases tied to sensitive microelectronics and Russia-related procurement networks, including an 18  February  sentencing involving a scheme to export U.S.-origin sensitive microelectronics to Russia.  In 2026, we anticipate intensified scrutiny of semiconductor, AI, and other advanced‑technology supply chains; increased focus on indirect routing, foreign affiliates, and reexport or assembly pathways; and ongoing coordination between BIS and DOJ. Jurisdictions of interest For 2026, companies should expect OFAC and BIS to remain most focused on Russia, Iran, China, and Venezuela, with Cuba and North Korea continuing to present elevated baseline risk, and with increasing scrutiny on third-country diversion hubs used to route sensitive goods or funds. Canada Regulatory developments:Guidance documents: In November 2025 Global Affairs Canada (GAC) provided additional guidance on sanctions compliance and expanded its FAQ to help industry comply with the Canadian sanctions regime. The guidance offers limited additional direction on compliance program expectations and red flag indicators. See Norton Rose Fulbright Canada’s update for more details.Expanded sanctions against Russia under the Special Economic Measures (Russia) Regulations: The Government of Canada has continued to expand its sanctions on Russia, with a recent focus on combatting Russia’s shadow fleet and energy sector. These measures are designed to further increase the economic costs on Russia for its invasion of Ukraine by restricting Russia’s energy revenues and financial, including cryptocurrency infrastructure, while degrading Russia’s military capabilities. Lifting sanctions under the Special Economic Measures (Syria) Regulations: In February 2025, the Government of Canada lifted broad sectoral prohibitions relating to the import and export of goods, investment activities, and financial services. The amendments aim to ease barriers to economic activity and enable transactions in order to facilitate humanitarian-related and other transactions in Syria. The designation criteria were expanded to capture those persons tied to human rights abuses or activities undermining Syria’s stability. Under the amendments, Canada de-listed two individuals and 24 entities, and sanctioned 6 individuals identified as being involved in gross and systematic human rights violations. Enforcement: The Government of Canada has been gradually increasing its sanctions enforcement measuresFirst-ever criminal charges under the sanctions against Russia: Following a three-year investigation, an individual was arrested and charged in June 2025 for exporting banned technology to Russia contrary to Canada’s sanctions regime against Russia (the Special Economic Measures (Russia) Regulations).First-ever forfeiture proceeding under the Special Economic Measures Act (SEMA): The Government of Canada has launched its first sanctions forfeiture proceeding against a seized an Antonov aircraft, which is owned, held or controlled by two Russian entities that have been sanctioned by Canada. The aircraft has been at Toronto’s international airport since Russian airlines were prohibited from using Canadian airspace in February 2022. After issuing seizure orders in 2023 and again in early 2025, the Attorney General of Canada filed a Notice of Application on March 18, 2025, to forfeit the aircraft under SEMA’s property‑forfeiture mechanism. Uniquely, under this provision, Canada does not need to demonstrate that the aircraft was used in a sanctions violation, only that it is property of sanctioned persons. Establishment of a dedicated law enforcement entity: Canada has recently announced the establishment of a proposed federal Financial Crimes Agency dedicated to combatting sophisticated financial crimes, including money laundering. It is anticipated to launch in spring of 2026. Additional details will be announced in the near future Jurisdictions of interest:  Russia remains the main target of GAC. It is clear that Canada will continue to use sanctions as a foreign policy tool designed to help degrade Russia’s military capabilities and ability to generate energy-related revenues to fund its aggression against Ukraine. Further developments to Canada’s sanctions regime against Iran are anticipated as the Government of Canada’s reassesses its position in light of ongoing developments in the Middle East. On February 13, 2026, Canada amended the Special Economic Measures (Iran) Regulations to sanction seven individuals who were identified as having engaged in activities that undermine international peace, security or stability in a manner that is consistent with the policies of Iran.  European Union Regulatory developments: To date, the approach to enforcement of violations of EU sanctions has varied across EU Member States, which has weakened their overall effectiveness.To address this, the EU adopted Directive (EU) 2024/1226 (EU Sanctions Directive) in April 2024, which introduces, among others, harmonized minimum penalties for EU sanctions violations. However, implementation of the EU Sanctions Directive has also differed across EU Member States. Germany, for example, missed the May 2025 implementation deadline due to new elections and legislative discontinuity, which triggered infringement proceedings by the EU. Ultimately, Germany enacted the “Act on the Adjustment of Criminal Offences and Sanctions for Violations of Restrictive Measures of the European Union” (the Implementing Act) in January 2026, which has been in force since 6 February 2026. The Implementing Act significantly strengthens German foreign trade criminal law by expanding the catalogue of criminal offences, criminalizing specific circumvention conduct, upgrading numerous administrative offences to criminal offences, and extending criminal liability to certain forms of reckless behaviour involving dual‑use items. It also abolishes the former “48‑hour grace period”, substantially increases potential corporate fines to up to EUR 40 million, and introduces a framework for placing certain companies under public trusteeship within the meaning of Article 5aa (2f) lit. a) of Regulation (EU) No. 833/2014. The reform represents a major step towards harmonized enforcement of EU sanctions across the EU while simultaneously tightening criminal sanctions law for economic operators, which further elevates the importance of effective compliance risk management structures. For a more in-depth discussion on the implications for EU operators, please see our latest update here. Enforcement: Recent enforcement activity by national enforcement authorities clearly intensified with respect to EU sanctions. Consequently, we expect the volume of related criminal proceedings to steadily increase. In addition, Europol has reinforced its operational support to EU Member States with the establishment of a “Target Group Sanctions”, a new team within its European Financial and Economic Crime Centre dedicated to identifying and disrupting criminal networks involved in sanctions evasion. Launched in November 2025, the unit uses Europol’s intelligence, analytical and financial-tracing capabilities to help investigators uncover illicit trade routes, track financial flows and detect related criminal activities, such as money laundering, customs fraud and document forgery. Europol has also partnered with the European Anti-Fraud Office (“OLAF”) in “Project Transporter” which targets vehicle exports routed through third countries and suspected of being diverted to Russia or Belarus, responding to increasing misuse of forged documents and illicit financing. In January 2026, OLAF reported a successful joint operation uncovering more than 760 vehicles falsely declared as destined for Turkey but ultimately transported to Russia, leading to criminal proceedings in three EU Member States. Jurisdictions of interest: Although the EU failed to agree on new sanctions against Russia ahead of the four‑year anniversary of Russia’s invasion of Ukraine, Russia remains a central focus for EU regulators. Recent sanctions packages included, inter alia, a ban on imports of Russian liquified natural gas starting 1 January 2027 for long‑term contracts, and within six months of the entry into force of the sanctions for short‑term contracts. In addition, on 15 January 2026, the EU applied for the first time its new automatic and dynamic mechanism for adjusting the price cap on Russian crude oil. Furthermore, and in line with the UK’s approach, the EU’s stance on Iran continues to evolve. In January 2026, the EU adopted new sanctions in response to “serious human rights violations and Iran’s continued support for Russia’s war of aggression against Ukraine”. In February 2026, the EU also added the Islamic Revolutionary Guard Corps of Iran to its terrorist list. However, the current situation in Iran, and more broadly in the Middle East, is expected to continue shaping potential future EU measures. Increased convergence between sanctions and AML compliance: Irrespective of specific sanctions programs or targeted sectors, we are seeing an increased convergence between sanctions and anti-money-laundering (AML) risks and related compliance. Recent regulatory actions, particularly the inclusion of targeted financial sanctions risks within the scope of the new EU AML Regulation (EU) No. 2024/1624, underscore the EU legislator’s intention to promote a more integrated approach to risk management. Enforcement authorities also recognize the growing interconnection between sanctions and AML frameworks, reflected in closer cooperation in investigations. Notably, customs investigations into sanctions breaches are now frequently triggered by suspicious activity reports (SARs) submitted to the Financial Intelligence Units (FIUs). For companies, this development requires a strategic reassessment of internal processes to address these intertwined obligations and to mitigate associated risks. United Kingdom Regulatory developments:  The Office of Financial Sanctions Implementation (OFSI) has announced changes to its enforcement processes, notably including the introduction of:a settlement scheme  (those agreeing to settle will be eligible for a 20% discount off the baseline penalty),an early account scheme (which again attracts a 20% discount off the baseline penalty), and doubling the maximum penalty that OFSI can impose for a breach of financial sanctions – the maximum penalty will now be the greater of GBP 2 million or the total value of the breach.  OFSI has also called for evidence seeking industry’s views on the approach to ownership and control under UK sanctions regulations and how it is being “applied in practice”, which indicates an intention to grapple with an area that has attracted conflicting views from both industry participants and the English courts Enforcement:  UK authorities continue to engage in enforcement action:Financial sanctions: In November 2025, OFSI imposed a £160,000 fine on the Bank of Scotland for breaches of financial sanctions under the UK’s sanctions targeting Russia.  The Bank processed 24 payments to or from a personal current held by a UK designated person. Due to its voluntary disclosure of the breaches, the Bank was granted a 50% discount to the original penalty. OFSI recently published a blog on key lessons for industry arising from this enforcement action, including the importance of screening data and its configuration, the inherent risks arising from automated screening processes, emphasis on training content being tailored to the current geopolitical landscape, and demonstrating that voluntary disclosures can shape enforcement outcomes.Trade sanctions: The Office of Trade Sanctions Implementation recently commented that it has five “late-stage” investigations near potential enforcement actions. Export controls: His Majesty’s Revenue & Customs (HMRC) continues to pursue active enforcement, having recently (a) prosecuted an individual for illegally exporting military-classified rifle sights to Hong Kong SAR in February 2026 who received a short custodial sentence;  and  (b) fined an exporter approximately £620,000 for unlicensed exports of military goods. On 10 March, the UK government published a policy paper outlining its strategic approach to sanctions enforcement, outlining the respective roles and responsibilities of different regulatory responsibilities in the UK, providing an overview of licensing and reporting suspected breaches, its approach to civil and criminal enforcement, and outlining the four principles that drives its approach to sanctions enforcement (driving compliance, proportionality and fairness, transparency, and due process). The paper is available here. Jurisdictions of interest:   Russia remains a core focus for UK regulators, with nearly 300 new designations announced to mark the four-year anniversary of Russia’s invasion of Ukraine.  The UK’s position on Iran continues to evolve – in January 2026, the Foreign Secretary announced that it would be looking to impose further sanctions and other sectoral measures on Iran, including working together with its colleagues in Europe on potential sanctions packages. However, recent developments will likely impact the approach of the UK and the EU in the coming months. Areas of focus: In line with our last update, decentralised finance and digital assets continue to attract regulatory scrutiny. In January 2026, OFSI published a blog on the abuse of cryptoassets to facilitate sanctions evasion, noting that it had recently joined forces with the multi-agency Crypto Cash Fusion Cell (CCFC) to “target criminal funds linked to sanctions offences”. We have already seen a number of crypto-related enforcement actions in the US and expect the UK to continue increasing its focus in this area.

On 13 March 2026, the Financial Conduct Authority (FCA) published the findings of its review into firms’ approaches to consumer understanding under the Consumer Duty (the Duty).BackgroundThe FCA explains that consumer understanding is an outcome under the Duty and that its requirements and expectations in relation to this are in PRIN 2A.5 and Chapter 8 of its Finalised Guidance (FG22/5).The FCA further explains that these examples of good and poor practice are provided to help firms learn from each other and support improvements in consumer understanding across the market but that they are not intended to create new regulatory requirements but that firms should use these insights to assess their own approach and identify where improvements may be needed to meet their obligations under the Duty. Key findingsThe FCA set out the following key findings: Using insight to identify where customers struggle: good practice included firms analysing insights from multiple sources, including call listening, complaints, chat transcripts, website analytics, drop-off data (customers who start but do not complete a specific process) and surveys and then reviewing this evidence regularly and prioritising meaningful improvements rather than simply making cosmetic changes. Testing communications with real customers: good practice included testing both before and after changes to communications and that firms use proportionate tools such as surveys, comprehension checks, A/B testing (before and after) and feedback from frontline interactions as part of this and then verify whether changes improve customer understanding and adapt based on the results. Communicating clearly, simply and accessibly: an effective approach included using plain language, clear structure, visual hierarchy and layered content and firms should place essential information upfront, highlight risks and exclusions early, and support those who need alternative or accessible formats. Designing journeys and tools that support understanding: that well-designed customer journeys incorporated calculators, videos, walkthroughs and summaries and that these tools should be tested to make sure they genuinely help customers and refined based on user evidence. Supporting customer with characteristics of vulnerability: an effective approach is to identify needs early, adapt communications accordingly and embed vulnerability considerations into governance, training and testing, which includes testing with vulnerable cohorts and ensuring accessibility throughout journeys. Clear, fair and balanced financial promotions: a good approach aligned with the Duty makes sure promotional content is balanced, accessible and easy to understand and that firms should give risks equal prominence to benefits, avoid jargon and test that key messages are properly understood. Governance and oversight: good practice included clear ownership of the consumer understanding outcome and that firms maintain defined governance, review management information regularly, track actions, and make sure decisions lead to improvements.

On 12 March 2026, the European Securities and Markets Authority (ESMA) published its report on the retail investor journey. The report follows an ESMA call for evidence (CfE) that sought to gather stakeholder input on key aspects of the investor experience, with a particular focus on the investor protection requirements under the Markets in Financial Instruments Directive II (MiFID II). The report consists of a discussion of the feedback ESMA received, as well as an outline of different areas where further engagement may be warranted.ESMA’s report should be read within the context of the European Commission’s (Commission) Savings and Investment Union (SIU) initiative. Through different legislative and non-legislative initiatives listed under the March 2025 SIU Action Plan, the Commission aims to create more integrated EU capital markets and channel more savings towards investments to finance the EU’s climate and competitive transition. In addition, the European Parliament and the Council reached a compromise on the text of the Retail Investment Strategy (RIS) in December 2025 and formal adoption and publication of the legal texts is expected later this year. The findings of the ESMA CfE will inform the European Supervisory Authority when developing technical advice on initiatives aimed at enhancing retail participation in EU capital markets.Barriers to retail investmentChapter 3 of the report provides an overview of the feedback that ESMA received. The chapter provides an overview of the key barriers respondents identified, as well as proposed measures to remove them. The main takeaways are set out below. Non-regulatory barriers: CfE respondents held divergent views on the principal non-regulatory obstacles to retail investment in the EU. Consumer organisations cited low market trust, high fees, and limited product comparability, while industry participants emphasised insufficient financial literacy, regulatory complexity, and cultural or behavioural considerations. Another group of stakeholders noted that the weight of these factors differs across Member States. Suggested remedies include strengthening financial education, streamlining regulatory requirements, reforming pension frameworks to incentivise capital markets participation, and implementing tax reforms. Speculative and volatile investments among young investors: Respondents broadly agreed that younger investors show a marked tendency towards speculative and volatile products, motivated by expectations of high investment returns, social media influence, accessibility, and the perception of lower costs. A lack of confidence in traditional financial institutions and an inclination towards decentralised products were also identified as relevant factors. Recommendations include enforcing compliance by financial influencers with EU and national requirements, robust application of the Markets in Crypto-Assets Regulation (MiCA) framework, and expanding the investment options available to younger investors. Disclosures: Disclosure as a principle commands broad support among respondents. However, respondents considered its practical impact to be weakened by the sheer volume, complexity, fragmented nature, and technical language of the information provided. Some existing requirements were viewed as inadequately adapted to the digital environment. Opinions on the utility of the Key Information Document (KID) varied. Several respondents considered MiFID II costs and charges disclosures to be unnecessarily complex, limiting their comprehensibility for retail investors. Anti-money laundering (AML) and counter-terrorist financing (CTF): AML and CTF requirements are not widely regarded as an impediment to retail investment in the EU. Nonetheless, respondents flagged inconsistencies in firms’ implementation practices, leading to duplicative information requests and inadequate communication to retail investors regarding the purpose of such requests. Several respondents advocated for the further harmonisation of AML and CTF standards at EU level. Tax: Both direct and indirect tax-related obstacles to retail investment growth were identified. Direct barriers stem from disparities in taxation and reporting requirements across EU jurisdictions, whilst indirect barriers relate to jurisdiction-specific tax incentives favouring particular products. Recommendations include simplifying and harmonising tax and reporting obligations, issuing clear guidance on cross-border tax requirements for retail investors, and creating an EU Savings and Investment Account to support cross-border retail investment. Regulatory disclosures and marketing material: Only a few parties responded to the questions under this section of the CfE, which focused on whether industry practices provide transparent and meaningful information to investors and whether certain marketing and contractual documentation create unintended barriers to informed investment decisions. The respondents that did provide feedback mentioned the feeling that there is an overload of information coming from disclosures, contracts and marketing information, which does not support retail investors in easily digesting the information. Firms could take steps to make contracts and terms and conditions more accessible by using plain language and visualisation, and by conducting user testing before implementing any changes to their documentation. Suitability assessment: The suitability assessment is recognised as a fundamental safeguard, yet respondents viewed it as administratively onerous and time-intensive for clients. Firms reported difficulties in keeping client information current, with the incorporation of sustainability preferences adding a further layer of complexity. Proposals include finalising the Sustainable Finance Disclosure Regulation review to bring greater clarity to product categories and aligning them with the suitability-preference framework, alongside simplifying the collection and updating client preferences. Appropriateness assessment for non-advised services: The appropriateness assessment enjoys widespread support among respondents, who agree that it serves to enhance retail investors’ awareness of product-related risks without materially impeding access to investment services. Crowdfunding: Respondents highlighted that retail investors engaging in crowdfunding projects tend to underestimate the frequently high-risk and illiquid nature of crowdfunding investments. They propose to address the issue by improving the quality of disclosures accompanying crowdfunding projects and by enhancing crowdfunding service providers’ due diligence on project owners to reduce the risk of fraud. Other topics: A recurring theme was that the current regulatory framework is excessively oriented towards investor protection at the expense of client choice, with respondents advocating a more proportionate balance between risk and reward. Several industry participants further emphasised the importance of regulatory stability in fostering investor confidence. Follow-up actionsThe final chapter of the report sets out how ESMA intends to utilise the outcomes of the CfE in its future work programme. In particular, it will draw upon stakeholder recommendations in developing its technical advice under the RIS. Among other planned actions, ESMA intends to streamline disclosure requirements through its Level 2 work by enhancing the clarity and timing of disclosures, calibrating periodic reporting obligations, and promoting a digital-first approach. ESMA will also update its Level 2 and Level 3 measures on suitability and appropriateness, encouraging the wider adoption of digital tools and exploring further proportionality measures for simpler products and distribution models.

On 12 March 2026, the Financial Conduct Authority (FCA) published the findings of its review of mortgage advice, fees and charges, and affordability assessments by second charge mortgage intermediaries and lenders.The findings are primarily relevant to firms who advise on, or provide, second charge mortgages. But aspects of it may also be of interest to other firms in the wider mortgage market.The FCA found examples of good practice across both intermediaries and lenders. But it also found evidence of some poor practices that can create a risk of poor customer outcomes. In particular: Standards of advice, particularly for debt consolidation, could be improved. Affordability assessments could be more robust. Intermediaries and lenders could improve the way they work together to deliver good customer outcomes. Firms’ record keeping was sometimes incomplete. Intermediary fees were higher than for first charge mortgages, and hard to compare. The FCA provides detailed findings on the above.Next stepsThe FCA: Expects second charge firms and their boards to consider its findings within the context of their firm and take appropriate action to address relevant issues and help make sure customers are achieving good outcomes. Is communicating directly with the firms included in its review about the remedial action it expects them to take. The FCA will continue to monitor firms through its supervisory work. Where appropriate, the FCA will follow up to make sure they are considering the points raised to drive improvements across the second charge sector. Throughout its work, the FCA will continue to consider its full range of regulatory powers. Is also considering policy changes to further support good customer outcomes for customers consolidating debt. For example, through work on protecting vulnerable customers in the Mortgage Rule Review. 

On 12 March 2026, the Financial Conduct Authority (FCA) issued its latest Regulatory Priorities report which covers mortgages.Regulatory Priorities reports replace portfolio letters and are published annually. They act as a guide for firms’ boards and chief executives and pull together all that the FCA is doing in a particular area.The FCA’s mortgages priorities this year include: Improving consumer outcomes under the Mortgage Rule Review. The FCA wants to enable the mortgage market of the future to be a market that can adapt, innovate, and meet consumer needs and expectations, from first-time buyers to those in later life. The FCA expects firms to: Engage with the Mortgage Rule Review and the later life mortgage market study. Share with it any barriers, challenges and risks to delivering innovation in products and services. Encouraging responsible lending and supporting mortgage borrowers in financial difficulty. The FCA expects firms to monitor their affordability assessments to ensure they remain appropriate and deliver good consumer outcomes, including when they are broadening access to mortgages. The FCA expects firms to: Monitor and oversee their affordability assessments to ensure they remain appropriate and deliver good consumer outcomes, including when firms are broadening access. Second charge lenders should review the findings of the FCA’s recent supervisory work on second charge mortgages to ensure that their affordability assessments are robust, and expenditure assessments are realistic for their customers. Support their customers through financial difficulty, including offering appropriate forbearance. Ensuring the quality of advice. The FCA wants to see advisers in intermediary firms and lenders recommending products that are suitable for consumers’ needs. The FCA expects firms to: Make sure advisers recommend products that are suitable for consumers’ needs, including those who are consolidating debt or borrowing into later life. Test consumer outcomes across the customer journey. Second charge advice firms should review the findings of the FCA’s work on second charge mortgages and ensure they are delivering good outcomes. All firms providing advice should review the elements of the findings that relate to record-keeping and quality assurance. Other areas of focus include: Mortgage and home finance lenders and administrators, and intermediaries. Mortgage intermediaries and incentives. Mortgage intermediaries and appointed representatives. Operational resilience. Senior Managers and Certification Regime. AI.

On 12 March 2026, the Financial Conduct Authority (FCA) issued its latest Regulatory Priorities report which covers retail banking.Regulatory Priorities reports replace portfolio letters and are published annually. They act as a guide for firms’ boards and chief executives and pull together all that the FCA is doing in a particular area.The retail banking priorities for this year include: Access to cash and essential banking services. Among other things the FCA states that firms’ digital transformations must avoid causing foreseeable harm to retail customers, especially those less digitally capable. The FCA expects firms to: Fill significant gaps in local cash access services in accordance with the Access to Cash sourcebook (where the firm is designated under the regime). Avoid causing foreseeable harm to retail customers when implementing digital-first transformations, including by analysing customer need and making sure any proposed alternatives are in place and accessible before a branch closure. Comply with the basic bank account regulations (where the firm is designated), making it easy for eligible consumers to apply. Ensure financial crime controls do not lead to unnecessary or overlong account freezing. Good outcomes from products and services. The FCA has seen firms make good progress driving positive outcomes under the Consumer Duty. The FCA reminds firms that they should keep developing their data for monitoring retail customer outcomes, so they can see where further action is needed to support consumers in pursuing their financial objectives and avoid causing them foreseeable harm. The FCA also states that for retail customers, under the Consumer Duty, firms should: Keep improving their data and management information dashboards for monitoring and assessing consumer outcomes, and their governance over these. Take action where need is identified to support consumers in pursuing their financial objectives and to avoid causing them foreseeable harm, including for those in vulnerable circumstances, financial difficulties, or where fair value is not being provided. Keep consumer outcomes front and centre when designing and delivering products or services, especially new, innovative or AI-based ones. Fighting fraud and other financial crime. Firms must monitor their fraud, money laundering and other risks, and continuously refine their defences. The FCA expects firms to: Help consumers understand fraud risks and support victims fairly. Monitor and mitigate the risks firms and consumers face, refining defences and control frameworks and promptly and effectively remediating any weaknesses. Keep improving systems and controls, to combat bad actors’ evolving tactics and technologies. Learn from FCA outputs and keep investing in resources and controls, including advanced technology such as AI where appropriate. Operational resilience and data security. Firms should identify emerging risks and critical third-party dependencies, refining action plans to address vulnerabilities and remain within important business service impact tolerances. The FCA adds that firms should continue building operational resilience and data security by: Identifying emerging risks to resilience, incorporating these in scenarios and testing to refine action plans for remediating vulnerabilities and remaining within impact tolerances. Continuing to evolve and improve cyber protection and information protection strategies, with tested recovery plans to mitigate harms from cyberattacks and third-party failures. Managing any live issues within impact tolerances, managing the impact on customers and communicating effectively with them. Participating in cross-industry initiatives where appropriate, to help improve system-wide resilience and recovery strategies. Other areas that the FCA will be focussing on include: Business banking outcomes. Innovations in retail banking. Motor finance commission review. Senior Managers and Certification Regime.

The Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) and the Dutch Central Bank (De Nederlandsche Bank, DNB) have updated their Simplified Fine Procedure (Procedure vereenvoudigde afdoening boetezaken). This procedure allows for simplified settlement of a fine imposed by AFM or DNB. It was originally introduced by the AFM, which already applies it for four years.The supervisory authority determines whether a case is suitable for simplified settlement. Financial undertakings may also express interest in the procedure, but the simplified procedure is not a right of the undertaking. AFM or DNB ultimately decides whether the procedure can be applied, as certain cases may not be suitable for this procedure. The simplified fine procedure works best when the facts of the case are clear, the financial institution is cooperative and both AFM/DNB and the financial undertaking benefit from a quick and definitive resolution.This procedure is attractive for financial institutions because cooperation results in a 15% reduction of the total fine. At the same time, the undertaking waives its right to objection (bezwaar) and appeal (beroep).If the institution accepts the offer for a simplified fine procedure, the supervisor issues an abbreviated fine decision and publishes the fine. Payment by the financial institution closes the matter definitively.The press releases of the DNB and AFM including the Simplified Fine Procedure can be found here and here (Dutch only).

On 11 March 2026, there was published in the Official Journal of the EU (OJ), Commission Implementing Regulation (EU) 2026/519 of 10 March 2026 amending the implementing technical standards laid down in Implementing Regulation (EU) 2021/622 as regards the frequency of reporting and the information to be reported. Commission Implementing Regulation (EU) 2021/622 is being amended to reflect changes to the minimum requirement for own funds and eligible liabilities (MREL) framework in the information to be transmitted to the European Banking Authority.  The amendments to Regulation (EU) 2021/622 are addressed to resolution authorities and do not involve significant changes in substantive terms. The Commission Implementing Regulation enters into force on the twentieth day following its publication in the OJ (31 March 2026).

The Capital Market Authority (CMA) has approved the Instructions of Simplified Investment Funds, introducing a new regulatory framework designed to create highly flexible, lower‑cost investment vehicles. This represents a structural shift in how funds may be formed, managed, and operated in Saudi Arabia.Key Provisions Eligible Investors: Units of Simplified Investment Funds may only be offered to institutional clients and must be managed by a CMA‑licensed fund manager. Notification Process: The former 15‑day offering application review requirement has been replaced with a streamlined pre‑offering notification to the CMA. Custodian Requirement: Funds structured as Special Purpose Entities are no longer required to appoint a custodian. Contractual Flexibility: Fund managers are granted expanded flexibility to determine key terms, including termination rights, unit class characteristics, reporting, amendments to fund term, and unitholder meeting requirements. This framework draws from international best practices and aligns closely with alternative fund models used in other developed jurisdictions.Why This MattersThe CMA’s objective is clear: reduce friction, remove unnecessary regulatory barriers, and empower fund managers to design structures that genuinely meet institutional investor needs—particularly in private equity and venture capital.Removing the 15‑day review period and eliminating the custodian requirement for SPE‑based funds reduces time and cost, without sacrificing investor protection in an institutional‑only environment. The enhanced contractual flexibility brings Saudi fund structuring closer to global alternative investment standards.By the end of Q4 2025, investment fund assets in Saudi Arabia reached SAR 884.45 billion, representing growth of 26.5% from SAR 699.06 billion in Q4 2024. The Simplified Investment Fund framework is poised to accelerate this momentum by unlocking new structures and attracting sophisticated capital.TakeawayFund managers, institutional investors, and advisers should examine the Instructions closely. While the framework offers significant flexibility, it places corresponding emphasis on strong governance, robust documentation, and informed investor engagement.