Regulatory Updates

On 9 October 2025, the Swiss Financial Market Supervisory Authority (FINMA) issued Guidance 04/2025, announcing an extension of the transitional period for the exchange of collateral in certain over-the-counter (OTC) derivative transactions. The current transitional period, which was due to expire on 1 January 2026, will now be extended for an additional three years until 1 January 2029. The extension applies to transactions not cleared through a central counterparty authorised or recognised by FINMA to maintain regulatory equivalence and market stability in line with evolving global frameworks.

On 30 September 2025, the Swiss Financial Market Supervisory Authority (FINMA) Chair, Marlene Amstad, addressed the AMF–AEFR Conference on Technological Frontiers in Finance in Paris. The event was hosted by the Autorité des Marchés Financiers (AMF) and the Association Europe Finances Régulations (AEFR), featuring global regulators including Tuhin Kanta Pandey, Chair of the Securities and Exchange Board of India (SEBI), and Tuang Lee Lim, Assistant Managing Director of the Monetary Authority of Singapore (MAS) and Chair of the IOSCO Fintech Task Force. The discussion focused on the growing influence of artificial intelligence (AI) across financial markets and regulatory supervision. Amstad outlined FINMA’s findings from Swiss market surveys, the IOSCO SupTech Survey, and the global implications of AI for financial stability, governance, and international cooperation.

On 8 October 2025, the United States Securities and Exchange Commission (US SEC) postponed its scheduled Crypto Task Force Roundtable on Financial Surveillance and Privacy due to a lapse in federal appropriations. The event, originally set to take place at US SEC Headquarters in Washington D.C. from 1:00 PM to 4:00 PM ET on 17 october 2025, will be rescheduled to a later date. Registration had been open for in-person attendance, with a webcast option available to the public. Updated details on the agenda and participating panelists will be announced once a new date is confirmed.

On 30 September 2025, United States SEC Commissioner Hester M. Peirce addressed the Digital Assets Summit in Singapore, delivering remarks titled “Cultivating Confidence: The Role of Custody in Institutional Confidence – Public Trust and Oversight.” Commissioner Peirce spoke on the challenges of crypto custody and the urgent need for clarity in regulatory treatment of custodians. She emphasised that investor trust depends on effective and adaptable custody frameworks, not outdated prescriptions. The Commissioner discussed how restrictive regulatory steps, such as the US SEC’s Staff Accounting Bulletin No. 121 and the Special Purpose Broker-Dealer framework, hindered market participation. Peirce urged regulators to consider principles-based custody frameworks and recognise technological solutions like blockchain transparency and smart contracts. She reaffirmed that fostering investor confidence requires balancing regulatory oversight with commercial reality.

On 30 September 2025, the U.S. Securities and Exchange Commission (US SEC), through its Division of Investment Management, issued a no-action letter permitting state-chartered trust companies to act as custodians for crypto assets under the United States Investment Advisers Act of 1940 and the United States Investment Company Act of 1940. The relief allows investment advisers, registered investment companies, and business development companies to treat certain state trust companies as “banks,” provided they operate under state supervision and possess fiduciary authority. The decision triggered immediate dissent from US SEC Commissioner Caroline A. Crenshaw, who issued a strongly worded statement titled “Poking Holes: Statement in Response to No-Action Relief for State Trust Companies Acting as Crypto Asset Custodians.” Crenshaw warned that the new relief dilutes investor protections embedded in federal custody regulations and bypasses statutory due process, underscoring the need for formal rulemaking on digital asset custodianship.

The Financial Intelligence Unit of India (FIU-IND) ordered the blocking of access to 25 offshore crypto exchanges for failing to register under the Indian Prevention of Money-Laundering Act, 2002 (PMLA 2002). The enforcement action follows earlier notices issued to offshore platforms that had been serving Indian users without compliance with registration and anti-money laundering obligations.

On 25 September 2025, Lucy Castledine, Director of Consumer Investments at the UK Financial Conduct Authority (UK FCA), set out the regulator’s five-year strategy at the PIMFA Compliance Conference. She confirmed four priorities that will shape the regulatory landscape for 2025 and beyond: supporting growth, being a smarter regulator, embedding Consumer Duty, and tackling financial crime.

On 30 September 2025, the Australian Securities and Investments Commission (Australia ASIC) published an update and urged financial advisers, also known as relevant providers, to immediately review and update their information on the Financial Advisers Register (FAR). ASIC cautioned that based on current records, at least 3,459 relevant providers risk being unable to provide personal advice to retail clients after 31 December 2025. From 1 January 2026, advisers who do not meet the professional standards will be prohibited from providing personal financial advice under the Australian Corporations Act 2001. ASIC emphasised that urgent corrective action is required, particularly for advisers relying on the experienced provider pathway and those offering tax (financial) advice services.

On 18 September 2025, the Cayman Islands Monetary Authority (CIMA) released a Supervisory Information Circular outlining its approach to anti-money laundering (AML), counter-terrorist financing (CFT), counter-proliferation financing (CPF), and targeted financial sanctions supervision for Virtual Asset Service Providers (VASPs). The circular provides detailed insights into how CIMA conducts both on-site inspections and off-site monitoring, while also disclosing findings of deficiencies and enforcement actions taken against VASPs. CIMA’s risk-based supervisory methodology, provides for the integration of supervisory technology, and the obligations that all registered VASPs must meet under the Virtual Asset (Service Providers) Act (2024 Revision) and the Anti-Money Laundering Regulations (AMLRs).

On 17 September 2025, the Cayman Islands Monetary Authority (CIMA) announced the appointment of Dr. Petr Jakubik as the new Head of its Financial Stability and Statistics Division, effective 3 September 2025. With more than 25 years of international experience in financial stability, macroprudential supervision, and statistical development, Dr. Jakubik will lead the Authority’s work in financial stability research and oversee the compilation and dissemination of official statistics.

On 29 September 2025, the Monetary Authority of Singapore (MAS), together with DBS, HSBC, OCBC, UOB, SPTel and SpeQtral, published a technical report on the successful completion of a proof-of-concept (PoC) sandbox evaluating Quantum Key Distribution (QKD) for secure communications in the financial sector along with Quotes from the Industry. The sandbox followed a Memorandum of Understanding (MoU) signed in August 2024 and builds upon Singapore’s earlier post-quantum cryptography (PQC) experiment with Banque de France. The report highlights the potential of quantum-safe communications to strengthen cyber resilience in financial services against emerging quantum threats.

On 26 September 2025, the United States Securities and Exchange Commission (United States SEC) published [Release No. 34-104101; File No. SR-NYSEARCA-2025-73] titled “Notice of Filing and Immediate Effectiveness of Proposed Rule Change Relating to the Listing and Trading of Shares of the 7RCC Spot Bitcoin and Carbon Credit Futures ETF.” The notice states that NYSE Arca, Inc. filed the proposal under Section 19(b)(1) of the United States Securities Exchange Act of 1934 and United States SEC Rule 19b-4. The filing transitions the 7RCC Spot Bitcoin and Carbon Credit Futures ETF from its earlier authorisation under Rule 8.500-E (Trust Units) to the generic listing provisions of Rule 8.201-E (Generic). With the United States SEC granting immediate effectiveness, the ETF may now be listed and traded under the streamlined generic framework, reinforcing standardisation of crypto-linked and carbon-linked exchange-traded products in the United States.