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UK FCA Marks Operational Resilience Deadline: Regulated Firms Must Now Embed Resilience as a Strategic Imperative

On 15 April 2025, Suman Ziaullah, Head of Technology, Resilience and Cyber at the United Kingdom Financial Conduct Authority (UK FCA), offered a forward-looking perspective on the future of operational resilience, following the sector-wide compliance deadline of 31 March 2025. UK FCA concluded the final stage of its operational resilience framework, reaffirming that the journey now moves beyond compliance into cultural transformation. In a reflective commentary which underlined that while regulated firms have met the mandatory deadline, the true test lies in how well they anticipate and respond to disruptions that could cause intolerable harm to consumers and markets. The message is clear that the operational resilience must now be integrated into the very design, strategy, and governance structures of firms and not treated merely as a regulatory raincoat. Ziaullah, through a metaphor of being caught unprepared in the rain, emphasised that operational resilience is not about...

MIAX Sapphire Advances Rule Change with US SEC to Launch Options on VanEck Spot Bitcoin ETF

On 15 April 2025, the US Securities and Exchange Commission (US SEC) published a notice of proposed rulemaking (File No. SR-SAPPHIRE-2025-18) submitted by MIAX Sapphire, LLC, seeking approval to amend Exchange Rule 402 to permit the listing and trading of options on the VanEck Bitcoin Trust. This filing represents a significant step in broadening access to regulated crypto-derivative instruments within the United States and forms part of a competitive response to a contemporaneous application lodged by Cboe Exchange, Inc. The proposal, grounded in the United States Securities Exchange Act of 1934, offers a structured legal justification for expanding options trading to include spot Bitcoin-based exchange-traded funds (ETFs), specifically the VanEck Bitcoin Trust. MIAX Sapphire seeks to include the Trust under Exchange Rule 402, which sets the “Criteria for Underlying Securities” eligible for options trading. The VanEck Bitcoin Trust, structured as a commodity-based ETF, holds Bitcoin...

Christina Choi’s Speech at Hong Kong Web3 Festival 2025: HK SFC’s Strategic Commitment to Web3 Ecosystem

On 7 April 2025, Ms. Christina Choi, Executive Director of Investment Products at the Hong Kong Securities and Futures Commission (HK SFC), delivered a keynote address titled “Fuelling the Web3 and Digital Asset Ecosystem in Hong Kong” at the Hong Kong Web3 Festival. The speech marks a pivotal moment in articulating the regulator’s evolving vision for the region’s digital asset future, firmly anchored in pragmatism, regulatory clarity, and investor protection. In her opening remarks, Ms. Choi used a poignant anecdote involving a floppy disk mistaken as a 3D-printed “save button” by her son to illustrate the exponential pace of technological change, a prelude to emphasising the promise and disruption of Web3. Framing blockchain as the new technological frontier akin to the floppy disk’s transformation of data portability, Ms. Choi affirmed that the HK SFC views Web3 not as a fleeting trend, but as a foundational shift in the financial landscape. Ms. Choi reaffirmed that the HK SFC, in...

US SEC Commissioner Raises Investor Protection Concerns at Crypto Trading Roundtable

On 11 April 2025, United States Securities and Exchange Commission (US SEC) Commissioner Caroline A. Crenshaw delivered remarks at the second session of the Crypto Task Force Roundtable titled “Between a Block and a Hard Place: Tailoring Regulation for Crypto Trading.” Framing the session in terms of its implications for investor protection and regulatory adaptation, Commissioner Crenshaw voiced concern over the structural vulnerabilities in crypto trading platforms, particularly in how these platforms interact with retail investors and manage core trading functions without formal oversight. Commissioner Caroline A. Crenshaw’s remarks focused on bridging the regulatory disconnect between investor expectations and the operational reality of crypto asset trading platforms. Emphasising the multi-functional roles played by these platforms including: brokerage, custody, and clearing; Crenshaw stated that, unlike their traditional finance counterparts, many of these entities operate...

US SEC Issues Disclosure Guidance for Crypto Asset Offerings and Registrations

On 10 April 2025, the United States Securities and Exchange Commission (US SEC), through its Division of Corporation Finance, published a detailed interpretive statement titled Offerings and Registrations of Securities in the Crypto Asset Markets. The statement provides comprehensive staff views on the application of existing federal securities law disclosure requirements to offerings and registrations of securities within the crypto asset markets. This initiative forms part of the US SEC’s broader regulatory effort, led by Acting Chairman Mark T. Uyeda and the Crypto Task Force, to create a clear and consistent disclosure regime for market participants involved with crypto-related securities. The statement serves as a non-binding interpretive document outlining the expectations and common issues the Division has observed in the review of United States Securities Act and Exchange Act filings. It aims to clarify applicable disclosure requirements for issuers engaged with crypto...

US SEC Disclosure Guidance Signals Shift Towards Clarity in Crypto Asset Offerings

On 10 April 2025, the United States Securities and Exchange Commission (US SEC) took a significant step towards regulatory transparency with the Division of Corporation Finance’s release of a detailed interpretive statement on Offerings and Registrations of Securities in the Crypto Asset Markets. Commissioner Hester M. Peirce, in a public statement titled Let’s Talk Disclosure, welcomed the development as part of the agency’s investor protection mission. While the guidance does not attempt to redefine whether a crypto asset qualifies as a security, it provides practical compliance-focused insight on the nature and scope of disclosures required under federal securities laws when securities are offered or registered in connection with crypto networks, applications, and related operations. This development marks a crucial moment for regulatory certainty in the digital asset space. As the crypto industry continues to mature, the absence of tailored disclosure frameworks has been a...

Commissioner Crenshaw Warns Against Misleading Stablecoin Classification: Legal, Financial and Systemic Risks Overlooked in US SEC Divison’s Staff Statement

On 04 April 2025, Commissioner Caroline A. Crenshaw of the United States Securities and Exchange Commission (US SEC) issued a pointed critique titled “Stable” Coins or Risky Business? of the Division of Corporation Finance’s statement on Stablecoin crypto regulation, particularly its classification of certain USD-stablecoins as non-securities. Crenshaw challenges the legal basis and factual assumptions and stating as potentially dangerous precedent being set in underestimating risks and overstating investor protections in a market increasingly dependent on intermediaries. Crenshaw’s According to her, these stablecoins are uncollateralised, uninsured, largely inaccessible to retail investors for direct redemption, and susceptible to runs and challenges the US SEC staff’s analysis concluding that certain USD-stablecoins are not securities. She argues that the staff’s reasoning omits critical risk factors, misrepresents redemption mechanisms, and fails to satisfy the legal standards...

US SEC Division of Corporation Finance Issues Interpretive Statement on the Regulatory Classification of Certain Stablecoins

On 04 April 2025, the United States Securities and Exchange Commission (US SEC) through its Division of Corporation Finance released a statement on stablecoins offering clarity on the legal characterisation of certain fiat-backed crypto assets. In its interpretative document titled Statement on Stablecoins, the Division articulated that specific types of stablecoins, defined as "Covered Stablecoins", do not constitute securities under the federal securities laws when issued and redeemed under prescribed conditions. This clarification emerges amidst a broader institutional movement spearheaded by the US SEC’s Crypto Task Force, reflecting a growing commitment to bring regulatory precision to crypto asset markets. The Statement on Stablecoins forms part of the US SEC's evolving efforts to delineate the boundary between financial innovation and statutory obligations under the United States Securities Act of 1933 and the United States Securities Exchange Act of 1934. The US SEC’s...

Rahul Varma Appointed Acting Director of US CFTC’s Division of Market Oversight

On 02 April 2025, the United States Commodity Futures Trading Commission (US CFTC) announced the appointment of Rahul Varma as the Acting Director of its Division of Market Oversight (DMO) who has over a decade of regulatory experience and a proven track record in market surveillance and intelligence, Varma steps into this critical leadership role at a time when the integrity and transparency of US commodity markets are under renewed global focus. Rahul Varma began his career at the US CFTC in 2013 as Associate Director for Market Surveillance within the DMO, overseeing sectors such as energy, metals, agriculture, and soft commodities. In 2017, he played a foundational role in establishing the Market Intelligence Branch, later serving as its Acting Deputy Director. In 2024 he was appointed Deputy Director and consolidated Market Intelligence and Product Review branches, at the intersection of data analytics, product innovation, and regulatory policy. Prior to joining the US CFTC,...

US SEC Publishes Texas Stock Exchange Application for National Securities Exchange Status

On 4 April 2025, the United States Securities and Exchange Commission (US SEC) published a notice notifying the receipt and commencing the review of an application by Texas Stock Exchange LLC (TXSE) for registration as a national securities exchange under Section 6 of the United States Securities Exchange Act of 1934. This notice, published and documented in SEC Release No. 34-102773; File No. 10-249, invites public comment and takes up the notice to scrutinise for US SEC to evaluate TXSE’s compliance with federal securities laws. TXSE initially filed its Form 1 application on 31 January 2025, followed by Amendment No. 1 on 02 April 2025, by which they updated the exhibits and detailed operational information. The US SEC’s Division of Trading and Markets is reviewing the submission to determine whether the proposed exchange satisfies all applicable statutory and regulatory requirements for national securities exchanges under the Exchange Act. According to the application, TXSE...

US SEC notifies the Agenda for Roundtable on Tailoring Crypto Trading Regulation on 11 April 2025

On 7 April 2025, the United States Securities and Exchange Commission (US SEC) announced the agenda and confirmed panelists for the upcoming roundtable titled “Between a Block and a Hard Place: Tailoring Regulation for Crypto Trading.” The event will take place on 11 April 2025 at the US SEC’s headquarters, in Washington, D.C., and will be hosted by the Crypto Task Force for crypto regulatory clarity. The event is open to the public, both in person and online, and will run from 1:00 p.m. to 5:00 p.m. EDT. Attendees can submit suggestions and questions either via email to crypto@sec.gov during the event or through note cards available at the venue. A live webcast will be accessible at www.sec.gov without the need for registration, though advance registration is required for those attending in person. The agenda will open with remarks by Richard Gabbert, Chief of Staff of the Crypto Task Force and Senior Advisor to the Acting Chairman, followed by Acting Chairman Mark T. Uyeda,...

US CFTC DMO & DCO Withdraws its 2018 Advisory with Respect to Virtual Currency Derivative Product Listings

On 28 March 2025, the United States Commodity Futures Trading Commission (US CFTC) announced that US CFTC Division of Market Oversight (DMO) and US CFTC Division of Clearing and Risk (DCR) have formally withdrawn CFTC Staff Advisory No. 18-14, titled Advisory with Respect to Virtual Currency Derivative Product Listings. The withdrawal, effective immediately, was set out in CFTC Letter No. 25-07, issued on 27 March 2025, titled ‘Withdrawal of CFTC Staff Advisory No. 18-14 with Respect to Virtual Currency Derivative Product Listings’ which states that the Advisory with Respect to Virtual Currency Derivative Product Listings is no longer necessary given the evolution of the virtual currency derivatives market and Crypto Taskforce developments. The 2018 Advisory was originally issued on 21 May 2018 to clarify the DMO and DCR’s expectations in their review of new virtual currency derivatives proposed for listing by Designated Contract Markets (DCMs), Swap Execution Facilities (SEFs), or...

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