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Quantum Updates 38 | March 2025

US SEC Reviews NYSE Arca’s Proposal to List Bitwise Dogecoin ETF Under Commodity-Based Trust Shares Rule

On 11 March 2025, the United States Securities and Exchange Commission (US SEC) published a notice inviting public comment on a proposed rule change submitted by NYSE Arca, Inc. The filing seeks approval to list and trade shares of the Bitwise Dogecoin ETF under NYSE Arca Rule 8.201-E, which governs Commodity-Based Trust Shares. The ETF would offer investors regulated access to Dogecoin, with all operational and custodial responsibilities clearly assigned to established institutional entities.

  • The Bitwise Dogecoin ETF is structured as a Delaware statutory trust, with Bitwise Investment Advisers, LLC as the sponsor and Delaware Trust Company as trustee.
  • Coinbase Custody Trust Company, LLC will act as the Dogecoin custodian, while Bank of New York Mellon will serve as the cash custodian, administrator, and transfer agent.
  • The Trust is not registered under the Investment Company Act of 1940 and does not qualify as a commodity pool under the Commodity Exchange Act.
  • As per the proposal, the ETF aims to provide direct exposure to Dogecoin while minimising operational costs. It will not engage in derivatives trading or use leverage, and it will maintain only a small cash reserve.
  • Daily NAV will be calculated based on the CF Dogecoin-Dollar Settlement Price, published by CF Benchmarks Ltd, ensuring price transparency.
  • The US SEC will evaluate the proposal within 45 days of its Federal Register publication, with the option to extend the review period by another 45 days.
  • Public comments are invited and may be submitted electronically through the US SEC’s portal or via mail, as part of the formal rule review process.

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Singapore and Viet Nam Strengthen Financial Innovation Cooperation with Upgraded MOU

On 12 March 2025, the Monetary Authority of Singapore (MAS) and the State Bank of Viet Nam (SBV) exchanged an upgraded Memorandum of Understanding (MOU) on Financial Innovation, furthering bilateral cooperation in digital finance, cross-border payments, and FinTech development. The upgraded MOU builds upon the original 2018 agreement, expanding its scope to cover digital innovation projects, regulatory cooperation, and payments integration.

  • MAS and SBV will jointly support FinTech innovation, regulatory sandbox initiatives, and the development of a conducive regulatory framework in Viet Nam.
  • With focus on cross-border retail payment connectivity, particularly enabling seamless QR code-based payments between the two markets.
  • The MOU enhances bilateral knowledge exchange and capacity building to align with international regulatory standards for digital finance.
  • Both central banks will facilitate greater interoperability between payment systems, improving financial inclusion and trade efficiency.
  • Regulatory support for FinTech firms will be prioritised to encourage responsible innovation and protect consumers across jurisdictions.
  • The agreement is in consonance with Singapore’s vision as a regional FinTech hub and positions Viet Nam for deeper participation in ASEAN’s digital finance landscape.

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Singapore and Viet Nam Strengthen Ties in Capital Markets and Digital Asset Regulation

On 12 March 2025, the Monetary Authority of Singapore (MAS) and the State Securities Commission of Viet Nam (SSC) signed a Letter of Intent (LOI) to enhance regulatory cooperation in capital markets and digital asset supervision. The agreement, exchanged during the official visit of Communist Party of Vietnam General Secretary To Lam to Singapore, reflects a shared commitment to regulatory alignment, market integrity, and sustainable cross-border investment.

  • The LOI promotes collaboration in financial oversight, focusing on capital markets regulation, digital asset supervision, and cross-border investment facilitation.
  • MAS and SSC will cooperate on capacity building, regulatory harmonisation, and financial crime prevention measures, including anti-money laundering (AML) and counter-terrorism financing (CFT).
  • Both authorities aim to share knowledge and align their regulatory frameworks with international standards to strengthen investor protection and market transparency.
  • The partnership lays the groundwork for increased regulatory integration and mutual enforcement cooperation between Singapore and Viet Nam.
  • The agreement supports sustainable development of the digital asset market, ensuring fair, transparent, and resilient capital markets.
  • The LOI upgrades the Comprehensive Strategic Partnership between the two countries.
  • MAS and SSC will engage through bilateral exchanges and regional forums to increase cooperation on regulatory innovation and financial stability.

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Singapore Issues Joint Advisory on AI-Driven Scams Targeting Businesses

On 12 March 2025, the Singapore Police Force (SPF), Monetary Authority of Singapore (MAS), and Cyber Security Agency of Singapore (CSA) jointly issued a public advisory warning businesses of a sophisticated scam trend involving AI-generated deepfakes. The advisory aims to create awareness in the rise in fraudulent video calls impersonating company executives and government officials, with the aim of inducing unauthorised corporate fund transfers and harvesting sensitive data.

  • Scammers are using AI-powered tools to manipulate video calls and impersonate senior corporate figures, MAS officials, or prospective investors.
  • Victims are targeted via unsolicited WhatsApp messages and invited to video meetings—typically on Zoom—where the fraudsters digitally mimic known individuals.
  • Once engaged, the fraudsters request fund transfers under false pretences, including fake business transactions, project financing, or investments.
  • Victims are further deceived by impostors posing as legal counsel, providing fabricated documents such as NDAs and Board Resolutions.
  • Employees are urged to verify any suspicious instructions through secure, internal channels, particularly when requests involve financial transfers or sensitive data.
  • Businesses should be vigilant of signs of digital manipulation during video calls, including inconsistent audio, facial features, or unnatural video quality.
  • Organisations are advised to strengthen internal controls, educate staff handling corporate funds, and avoid sharing NRIC, passport, or other sensitive data with unverified sources.
  • MAS reiterates that it does not request banking information or direct fund transfers from individuals or businesses.
  • Suspected fraud must be immediately reported to law enforcement and banks to prevent financial loss; ScamShield Helpline (1799) and website (www.scamshield.gov.sg) are key resources.

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UK FCA Revises Enforcement Transparency Proposals and Confirms Next Steps

On 12 March 2025, the United Kingdom Financial Conduct Authority (UK FCA) issued an update on its enforcement transparency proposals, confirming that it will not proceed with plans to change the disclosure threshold from “exceptional circumstances” to a broader “public interest” test. The decision follows stakeholder concerns over reputational harm and due process in investigations involving regulated firms.

  • The UK FCA confirmed it will maintain the current threshold for announcing investigations into regulated firms, limiting disclosures to exceptional circumstances only.
  • The regulator will proceed with measures that received industry support, including reactive confirmations of investigations already public, public notifications about unregulated firms or regulated firms operating outside the perimeter, and anonymised summaries of active investigations.
  • A final policy implementing these supported changes will be published by the end of June 2025, with a focus on improving consumer protection without compromising fairness in ongoing investigations.
  • Chief Executive Nikhil Rathi emphasised that the FCA is accelerating enforcement timelines and ensuring changes are consensus-driven and consumer-focused.
  • Separately, the UK FCA and PRA have decided not to proceed with proposals on diversity and inclusion requirements for regulated firms at this stage, citing extensive feedback and upcoming legislative developments.
  • The FCA will also delay updates on non-financial misconduct enforcement until further review is completed, with a dedicated policy update expected by mid-2025.

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UK FCA Chief Nikhil Rathi Supports Government’s Plan for Payment Systems Regulator Reform

On 12 March 2025, Mr. Nikhil Rathi, Chief Executive of the United Kingdom Financial Conduct Authority (UK FCA), issued a statement welcoming the UK Government’s announcement regarding reform of the Payment Systems Regulator (PSR). The move seeks to streamline regulatory oversight of the payments sector in response to its evolving landscape, with the UK FCA committing to support a coordinated and efficient transition.

  • Mr. Rathi acknowledged the PSR’s significant contributions to improving safety, competition, and innovation in UK payment systems.
  • He endorsed the government’s timing, citing the need for regulatory simplification following improvements in coordination and responsibility clarity.
  • The UK FCA will work with the government, the Bank of England, and industry stakeholders to determine the scope and process for transferring PSR powers.
  • Mr. Rathi emphasised a smooth transition, stating that the FCA is ready to incorporate PSR expertise and continue driving regulatory progress.
  • The statement reflects the FCA’s intention to uphold payment sector integrity and maintain momentum in modernising financial infrastructure.

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US CFTC Withdraws Staff Advisory on Swap Execution Facility Registration Requirement

On 13 March 2025, the United States Commodity Futures Trading Commission (US CFTC) published Letter No. 25-05, officially announcing the withdrawal of CFTC Letter No. 21-19: Staff Advisory on Swap Execution Facility Registration Requirement (SEF Registration Advisory), a Staff Advisory issued in 2021 concerning Swap Execution Facility (SEF) registration. It takes immediate effect and aims to reduce regulatory uncertainty while preserving core SEF registration obligations under the United States Commodity Exchange Act (CEA) and CFTC regulations.

  • Originally issued on 29 September 2021, the SEF Registration Advisory clarified when certain entities engaging in swap trading might be required to register as SEFs.
  • The Division of Market Oversight (DMO) determined that the advisory created ambiguity for market participants, particularly those involved in bilateral or one-to-many trading, voice-executed swaps, and non-mandated trades under Section 2(h)(8) of the CEA.
  • Entities registered in other regulatory capacities (e.g., as CTAs or introducing brokers) also faced confusion about their SEF obligations.
  • With the withdrawal of Letter No. 21-19, market participants are no longer subject to the advisory’s interpretative guidance.
  • However, the withdrawal does not change statutory or regulatory SEF registration requirements; firms must continue to assess their registration obligations based on the CEA and CFTC rules.
  • The DMO encourages entities seeking clarity on SEF registration to consult with CFTC staff directly.

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UK FCA Rejects Zeux Limited’s Crypto Registration Over Money Laundering Risks

On 17 March 2025, the United Kingdom Financial Conduct Authority (UK FCA) rejected Zeux Limited’s application for registration as a cryptoasset exchange provider under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). The refusal was based on significant deficiencies in Zeux’s anti-money laundering (AML) systems and its inability to meet regulatory standards necessary to operate in the UK’s cryptoasset sector.

  • Zeux Limited submitted its crypto registration application in June 2022 but failed to implement effective AML risk management practices required under MLRs 2017.
  • The UK FCA cited the firm’s failure to identify and document money laundering and terrorist financing risks and its lack of engagement with the UK’s National Risk Assessment.
  • Key compliance shortcomings included inadequate customer risk assessments, absence of enhanced due diligence procedures, and failures in suspicious activity reporting (SAR).
  • The regulator concluded that Zeux’s deficiencies could expose the public to significant harm through unchecked money laundering or sanctions evasion.
  • The UK FCA reiterated that registration under MLRs is mandatory for all cryptoasset exchange providers and that only applicants with robust AML frameworks will be approved.
  • Firms seeking registration are requested to engage with the UK FCA’s pre-application support and demonstrate full understanding of statutory AML obligations.

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US CFTC Warns Against AI-Driven Financial Scams in New Advisory on Generative AI Fraud

On 19 March 2025, the United States Commodity Futures Trading Commission (US CFTC) published an advisory titled “Criminals Increasing Use of Generative AI to Commit Fraud.” The advisory, issued by the Office of Customer Education and Outreach (OCEO), elaborates on how criminals are leveraging generative AI tools to commit increasingly deceptive financial fraud. It draws attention to deepfakes, AI-enhanced trading scams, and the manipulation of digital content to impersonate individuals or create false platforms. The advisory cites an FBI public service announcement that warns of AI’s increasing use in relationship investment scams and identity fraud.

  • Fraudsters are using AI-generated voices, images, and video content to manipulate victims through realistic deepfake identities and social engineering tactics, particularly in online romance and investment scams.
  • AI-powered tools are employed to generate forged government IDs, bank statements, and financial records to deceive individuals and institutions.
  • Scammers are manipulating live video calls using apps that alter facial features and voices in real time, undermining traditional authentication checks.
  • Malicious actors are deploying advanced language models to enhance grammar and localisation on fraudulent websites, reducing detection through linguistic red flags.
  • Criminals outside the US are increasingly targeting American residents by exploiting AI to bypass cultural and language barriers, thereby expanding cross-border fraud schemes.
  • AI-enabled trading scams involve platforms impersonating licensed brokers or exchanges, tricking users into depositing funds that are then stolen or redirected to illicit wallets.
  • The US CFTC advises consumers to inspect digital content closely for inconsistencies—such as unnatural facial expressions or distorted hands—listen for tonal anomalies in speech, and question the authenticity of unsolicited communications.
  • Individuals are urged to avoid sharing personal or financial details with unverified online entities and to refrain from transferring cryptocurrency to parties met exclusively online.
  • The advisory encourages victims to report AI-generated fraud to the CFTC via cftc.gov/complaint or the FBI via ic3.gov.

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