A year has passed since we last compared developments in financial services regulation in both the European Union (EU) and the United Kingdom (UK). This included where the respective jurisdictions were diverging and where they were progressing towards similar policy objectives, albeit with different approaches (for example, prescription versus outcomes-based regulatory regimes). This year, as we revisit these evolving topics, and cover the latest policy developments, we have split our update into three complementary articles. In this first article we look at technological and innovation related developments.&nbsp;

Ongoing Developments in Financial Services Regulation in the EU and UK - Part I

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Welcome to the latest article in our ‘Transformation is inevitable’ series, where we provide insights based on our on-going analysis of the complex, changing and ambitious regulatory policy environment, evolving customer and employee needs, as well as advancing technology.&nbsp;In our first two articles we looked at <a href="https://www.citigroup.com/global/insights/securities-services/transformation-is-inevitable-the-vista-for-asset-mangers" target="_blank" rel="noopener">the future of work and sustainable finance</a>, and the possible future direction of UK regulation now that the UK is no longer part of the European Union. In this, our third article, we look at the potential risks that may arise from the ever-increasing use of cloud outsourcing.

Transformation Is Inevitable  — The Risks of Cloud Concentration

The potential risks that may arise from the ever-increasing use of cloud outsourcing.

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Joining jurisdictions around the world, the UK has recognised that disrupting technologies and failures in the cryptoasset arena have highlighted the need for regulation, not just to protect investors and maintain financial stability, but also to recognise the changes technology has made to the financial services sector.&nbsp;
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In February 2023, the UK became one of the latest jurisdictions to set out plans to regulate cryptoassets and pave the way for a central bank digital currency.
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As with other jurisdictions, the aim is to regulate the use of disruptive technologies, thereby ensuring that new products fit into the current regulatory framework.
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This is a rapidly developing arena. Indeed, between writing this article and its publication, further rules and guidance have been issued by IOSCO, the SFC, and the International Institute for the Unification of Private Law.

In February 2023, the UK became one of the latest jurisdictions to set out plans to regulate cryptoassets and pave the way for a central bank digital currency.

Digital Assets: The Evolving Regulatory Environment

The Netherlands, like other jurisdictions, face challenges resulting from an aging population, hence the need for the new Wtp. The Wtp entered into force on 1 July 2023, and a transition period means that social partners, employers and pension providers will have until 1 January 2028 to amend pension schemes. The aim of the Wtp is to make corporate pensions more sustainable and workers with a company pension scheme will no longer face certainty in how much pension they will receive, as members will pay into individual accounts, with income levels more dependent on investment returns and individual contributions.

The Netherlands, like other jurisdictions, face challenges resulting from an aging population, hence the need for the new Wtp.
The Wtp entered into force on 1 July 2023, and a transition period means that social partners, employers and pension providers will have until 1 January 2028 to amend pension schemes.
The aim of the Wtp is to make corporate pensions more sustainable and workers with a company pension scheme will no longer face certainty in how much pension they will receive, as members will pay into individual accounts, with income levels more dependent on investment returns and individual contributions.

Pension Reform In The Netherlands — ‘Wet Toekomst Pensioenen’ 

The FCA states that PS23/16 contains its final rules and guidance to, amongst other things, improve trust and transparency to the market for sustainable investment products and help consumers to navigate the market for sustainable investment products.
The FCA adds that the package of measures contained in PS23/16 put consumers at its heart and was tested with over 15,000 people. It also follows the UK regulators&rsquo; Financial Lives Survey, which highlighted that a significant majority of adults surveyed would like to invest in a way that protects the environment or has a positive social impact.
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On 28 November 2023, the UK&rsquo;s Financial Conduct Authority (FCA) published its Policy Statement (PS23/16) &lsquo;Sustainability Disclosure Requirements (SDR) and Investment Labels&rsquo;.

UK FCA Confirm Sustainability Disclosure and Labelling Regime

<h4>Increasingly, regulators globally have become concerned about two aspects of open-ended funds&rsquo; liquidity. Firstly, that funds do not trade with investors in a manner that reflects the liquidity of their underlying portfolios and secondly, that the underlying portfolios are not as liquid as the regulators would expect them to be.</h4>
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This has led jurisdictions and international bodies to question the rules that they have, to date, applied.
In this article we look at the current work being undertaken to try and solve the problem of liquidity mis-match in open-ended collective investment schemes.
We look at the work undertaken by global bodies such as IOSCO and the FSB, as well as domestic regulators in Europe, The US, UK and Asia.
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Increasingly, regulators globally have become concerned about two aspects of open-ended funds&rsquo; liquidity. Firstly, that funds do not trade with investors in a manner that reflects the liquidity of their underlying portfolios and secondly, that the underlying portfolios are not as liquid as the regulators would expect them to be.

Fund Liquidity: Still a Global Cause for Concern

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Back in October 2021, the UK Government announced, at COP26, its intention &ldquo;to become the world&rsquo;s first net-zero aligned financial centre and announced that it would launch the Transition Plan Taskforce (TPT), with the mission of producing a gold standard Disclosure Framework for transition plans.&rdquo;
On 9 April 2024, the TPT launched its final set of transition plan resources which amongst other documents, included sector-specific transition plan guidance for asset managers and asset owners, amongst other sectors.
Learn about the TPT Asset Managers Sector Guidance, its potential cross-over with the Asset Owner Sector Guidance, and why these are relevant to your asset management business.

Back in October 2021, the UK Government announced, at COP26, its intention &ldquo;to become the world&rsquo;s first net-zero aligned financial centre and announced that it would launch the Transition Plan Taskforce (TPT), with the mission of producing a gold standard Disclosure Framework for transition plans.&rdquo;

Transition Planning for Asset Managers

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The UK Financial Conduct Authority (FCA) is consulting on extending Sustainability Disclosure Requirements (SDR) and investment labels regime to portfolio management services as part of a Consultation Paper (CP24/8) &lsquo;Extending the Sustainability Disclosure Requirements (SDR) regime to Portfolio Management&rsquo;, which was published on 23 April 2024.
The FCA estimates that its proposals will impact around 400 firms providing portfolio management services, consisting of a population of wealth managers, private banks, and asset managers (which collectively the FCA refer to as &ldquo;firms&rdquo; in CP24/8). All of which can operate different business models and different services.
The FCA says that how the rules are to be applied, depends on the nature of each firm&rsquo;s business model.

The UK Financial Conduct Authority (FCA) is consulting on extending Sustainability Disclosure Requirements (SDR) and investment labels regime to portfolio management services as part of a Consultation Paper (CP24/8) &lsquo;Extending the Sustainability Disclosure Requirements (SDR) regime to Portfolio Management&rsquo;, which was published on 23 April 2024.
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UK FCA Proposes Extending SDR to Portfolio Management

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The Alternative Investment Fund Managers Directive (AIFMD) was introduced in response to well publicised failures in governance that impacted European Union (EU) funds during the global financial crisis of 2008-09.
The aim of the AIFMD was to ensure minimum regulatory standards for the operation of management companies responsible for funds available for investment in the EU and not captured by the pre-existing Undertakings for Collective Investment in Transferable Securities (UCITS) Directive.
Over time the AIFMD has evolved to include fund specific regulation with the introduction of new rules governing loan originating alternative investment funds (AIFs).
In this article we explore these new fund rules, as well as some of the other changes to both the AIFMD and UCITS Directive, introduced by the amending directive that came into force on 15 April 2024.
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The Alternative Investment Fund Managers Directive (AIFMD) was introduced in response to well publicised failures in governance that impacted European Union (EU) funds during the global financial crisis of 2008-09.

The Changing Face of EU Investment Fund Regulation   

There is currently a global trend towards reducing settlement cycles with the general aim of lowering market risk, providing more stability, improving liquidity, and streamlining operations.
Some market participants have also considered the future landscape of &lsquo;atomic settlements&rsquo;, otherwise described as T+0.
In this article we start with the lead up to, and the point at which the U.S. changes to T+1 settlement went live. Following that, we look at the outcome of that change.
Finally, we look at what other jurisdictions such as the European Union, the UK and Australia may be proposing further down the line.

There is currently a global trend towards reducing settlement cycles with the general aim of lowering market risk, providing more stability, improving liquidity, and streamlining operations.
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The Sliding Scale for Global Settlement Cycles

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There are various definitions of greenwashing, but in the EU the ESAs have provided a common understanding of what this means.
Being a practice where sustainability-related statements, declarations, actions, or communications do not clearly and fairly reflect the underlying sustainability profile of an entity, a financial product, or financial services.
The European Securities and Markets Authority (ESMA) and the UK&rsquo;s Financial Conduct Authority (FCA) have therefore taken action,&nbsp;with the aim that fund managers are, amongst other things, acting honestly and fairly when marketing sustainable funds to investors.

There are various definitions of greenwashing, but in the EU the ESAs have provided a common understanding of what this means.&nbsp;

Sustainability-Related Terms in EU and UK Funds’ Names

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On 31 December 2020, the United Kingdom of Great Britain and Northern Ireland (UK) ceased to be part of the European Economic Area (EEA) UCITS cross-border passporting regime.
In this article we look at the impact that decision had on EEA funds intending to market to UK investors, and the moves UK authorities have made to transition to a new regime for overseas funds operating in the UK.

The Overseas Funds Regime – The New Route to Market EEA UCITS Funds in the UK

The New Route to Market EEA UCITS Funds in the UK

On 31 December 2020, the United Kingdom of Great Britain and Northern Ireland (UK) ceased to be part of the European Economic Area (EEA) UCITS cross-border passporting regime.

The Overseas Funds Regime

Australia, along with other countries, is a member of the International Platform on Sustainable Finance (IPSF).
The IPSF offers a multilateral forum for policymakers in charge of developing sustainable finance regulatory measures. Its stated objective is to scale the mobilisation of private capital towards sustainable investments.
This article looks at how the Australian Government lays out its plans for a Sustainable Finance Roadmap, alongside the latest international developments in this space.

Australia, along with other countries, is a member of the International Platform on Sustainable Finance (IPSF).

Australia’s Sustainable Finance Roadmap Adds to the Latest International Developments

The financial services industry has often been at the forefront when it comes to the implementation of new technologies. From the rise of compact computers in the 1970s and the development of software packages that improved accuracy and efficiency, through the advent of the internet and home computing, to the dominance of mobile apps, the financial services industry is frequently in the vanguard.
So far, each innovation has been an incremental step, adapting existing processes to an evolving environment: paper ledgers become spreadsheets, cash and cheques are replaced by chip and pin, in-turn replaced by touch to pay. The latest technologies promise not an incremental step but &ldquo;disruption&rdquo;, tearing up the existing ways of doing things and replacing them with new tech that promises to be better, smarter, faster.
In this e-briefing we look at the latest global developments in the areas of fund tokenization, with contributions from Citi colleagues from around the world.

Click below to download the e-briefing. 

The financial services industry has often been at the forefront when it comes to the implementation of new technologies. From the rise of compact computers in the 1970s and the development of software packages that improved accuracy and efficiency, through the advent of the internet and home computing, to the dominance of mobile apps, the financial services industry is frequently in the vanguard.

The Path to Fund Tokenization – Global Developments

Following its publication in the Official Journal of the European Union on 27 December 2022, the Digital Operational Resilience Act (DORA) and the DORA Amending Directive entered into force on 16 January 2023 and will apply from 17 January 2025.DORA sets uniform requirements for the security of network and information systems of companies and organisations operating in the financial sector as well as critical third parties which provide Information Communication Technology (ICT)-related services to them, such as cloud platforms or data analytics services.DORA creates a regulatory framework on digital operational resilience whereby all firms need to make sure they can withstand, respond to and recover from all types of ICT-related disruptions and threats. These requirements are homogenous across all EU member states. The core aim is to prevent and mitigate cyber threats.In this e-briefing, we look at the background to DORA, the regulation itself, and the current status of the level two and three proposals as we approach DORA’s application in January 2025.

DORA: The EU’s New Regulatory Framework on Digital Operational Resilience

Following its publication in the Official Journal of the European Union on 27 December 2022, the Digital Operational Resilience Act (DORA) and the DORA Amending Directive entered into force on 16 January 2023 and will apply from 17 January 2025.

Enabling Issuers and Investors across the entire investment lifecycle.

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On 15 March 2025, the Financial Accountability Regime (FAR) will be extended to the insurance (including their non-operating holding companies) and superannuation industries in Australia, joining the banking industry, where the FAR has applied since 15 March 2024.
For the insurance and superannuation industries, the extended regime will impose a strengthened responsibility and accountability framework to improve the risk governance cultures of entities regulated by the Australian Prudential Regulation Authority (APRA), their directors and most senior executives.
In this e-briefing, we look at the latest developments, including APRA and the Australian Securities and Investments Commission's July information paper on 'FAR: Information for accountable entities.'

Click below to download the e-briefing.

On 15 March 2025, the Financial Accountability Regime (FAR) will be extended to the insurance (including their non-operating holding companies) and superannuation industries in Australia, joining the banking industry, where the FAR has applied since 15 March 2024.

Not So ‘Far’ Out – The Extended Financial Accountability Regime in Australia

e-briefing 

In recent years, Artificial Intelligence (AI) and Generative AI (Gen AI) have transitioned from the realm of science fiction to reality.
The concept of intelligent machines can be traced back centuries. But true AI development really started with Alan Turing&rsquo;s Test for computer intelligence and neural networks in the 1950s.
Fast forward to 2024 - where we are now familiar with many Gen AI powered tools that are on the market with capabilities to generate text, write code, create audio, make images and video on-demand.
Whilst society appears to be assimilating the use of such tools into everyday life, this is not necessarily the case for financial services firms, as there are certain regulatory and ethical guardrails to be followed.
In this e-briefing we look at Gen AI, why it matters, its potential, some use cases, alongside the&nbsp; evolving global regulatory environments.

In recent years, Artificial Intelligence (AI) and Generative AI (Gen AI) have transitioned from the realm of science fiction to reality.

Doing the Right Thing for Business and Society - Generative AI

Data. In everyday life we are constantly consuming it. On a conscious level, we are trying to make use of that information for the task at hand, discounting the inessential and focusing on the essential.&nbsp;In business, the collection, storage, and use of data follows the same principles. An approach which aims to harness data and technology in perfect harmony.&nbsp;Large volumes of data are valuable. But as data volumes, processing and consumption demands continue to rise exponentially, businesses that manage data are exposed to a host of challenges.&nbsp;In this e-briefing we look at how firms such as asset managers, insurers, and banks, along with regulators, must therefore consider these ‘flip sides’ and continuously determine how to overcome these challenges, whilst making the best use of their data.<o:p> </o:p>

Data. In everyday life we are constantly consuming it. On a conscious level, we are trying to make use of that information for the task at hand, discounting the inessential and focusing on the essential.<o:p></o:p><o:p> </o:p>

The Flip Sides of Data – A Strategic Asset and a Potential Risk

<h5>On 19 December 2024, the UK Financial Conduct Authority (FCA) published its consultation CP24/30: A New Product Information Framework for Consumer Composite Investments (CCI CP).</h5>&nbsp;Under the current rules for the PRIIPs KID and UCITS KIID, introduced when the UK was still in the European Union, people buying investments like investment funds are supplied with standardised documents covering prescribed information.But now the FCA is proposing to replace the regimes it onshored with a system which is intended to be simpler and flexible, and tailored to the UK.Under the proposals, new product information requirements should help consumers understand the products they are buying while giving firms flexibility to innovate. In this e-briefing we look at the FCA’s proposals in more detail.

On 19 December 2024, the UK Financial Conduct Authority (FCA) published its consultation CP24/30: A New Product Information Framework for Consumer Composite Investments (CCI CP).<o:p></o:p>

The FCA Moves Forward with its New Product Information Regime – Consumer Composite Investments

On 11 October 2027, the financial markets of the European Union (EU), United Kingdom (UK), and Switzerland and Liechtenstein, will, or are considering moving to a T+1 settlement cycle, bringing them into line with other financial centres that have already commenced or completed the move.With both EU and UK governments calling for greater inward investment, either to boost growth, finance digital, green and social transition, or just encourage greater retail investment in securities markets, reducing the time it takes to settle trades is seen as key to meeting these aims.&nbsp;In reducing the settlement cycle, markets in the EU, UK, and Switzerland and Liechtenstein will join jurisdictions already operating T+1, such as China, India, the United States and Canada.&nbsp;Following extensive consultation and industry feedback, the UK government and European Commission plan to amend their respective versions of the Central Securities Depository Regulation to provide legal certainty so as to ensure T+1 settlement is implemented on 11 October 2027.&nbsp;This date has been selected to give market participants time to update and adapt systems and processes.&nbsp;Joining the EU and UK, the Swiss Securities Post-Trade Council (swissSPTC) has also recommended that the transition to a T+1 Settlement Cycle for the domestic markets in Switzerland and Liechtenstein should occur in October 2027. SIX, the operator of the Swiss exchange, has committed to gaining adjustments to the Rule Book of SIX Swiss Exchange to accommodate the change of the settlement cycle at the appropriate time.In this article we consider each of the European proposals in more detail in terms of background leading up to the proposals, suggested approaches, along with actions still to be taken.

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On 11 October 2027, the financial markets of the European Union (EU), United Kingdom (UK), and Switzerland and Liechtenstein, will, or are considering moving to a T+1 settlement cycle, bringing them into line with other financial centres that have already commenced or completed the move.

All Aboard the Train Bound for T+1: Next Stop, October 2027

Money laundering continues to be a significant global challenge for financial institutions, especially as criminals adopt increasingly sophisticated methods to launder the proceeds of crime.In 2025 and beyond, financial institutions must continue to adapt to evolving regulatory pressures, and emerging crime trends, as well as further consider technological solutions to mitigate these risks.In this article we look at some of the most recent legislative changes which firms should be aware of.

Money laundering continues to be a significant global challenge for financial institutions, especially as criminals adopt increasingly sophisticated methods to launder the proceeds of crime.

Anti-money Laundering Evolution in 2025 and Beyond

If you are a parent, you will be only too familiar with the childish refrain, ‘are we there yet’ – often repeated on any journey, regardless of length. The same may be heard as regards sustainability regulation, which has been at the forefront of regulators agendas for the last six years or so.This article looks to answer that question, ‘Are we there yet?’&nbsp;Well, the answer to that specific question is still ‘no’, and to be able to expand on why, we need to root our journey back in 2024 and project forwards to 2025 and beyond.Our latest article looks at regulations which are due to enter key milestones during 2025, along with what is still to come in terms of further regulatory developments, with the potential to impact a variety of industry segments.By nature of its subject matter, our latest piece is broad in terms of coverage looking at:<ul style="list-style-type:disc;"><li>ESG Ratings Regulations,</li><li>Global sustainability reporting,</li><li>Ongoing developments in the EU and UK around the potential to simplify sustainability regimes such as the EU SFDR, UK SDR, and due diligence obligations for the entire value chain,</li><li>ESG risks,</li><li>Residual ESG considerations arising from the use of AI and digital assets,</li><li>Early indications for potential ESG regulatory changes in the US,</li><li>Net zero and transition planning, and</li><li>An evolving focus on nature.&nbsp;</li></ul>As companies move through 2025/2026, we look at how the ESG landscape is characterised by both challenges and opportunities.&nbsp;Companies must remain vigilant and adaptable, embracing integrated and strategic approaches to ESG and sustainability (including in relation to the terminology used) to ensure business resilience.&nbsp;By staying informed and proactive, organisations can navigate the complexities of ESG, and sustainability matters and position themselves for long-term success in an ever-evolving global environment. &nbsp;

If you are a parent, you will be only too familiar with the childish refrain, ‘are we there yet’ – often repeated on any journey, regardless of length. The same may be heard as regards sustainability regulation, which has been at the forefront of regulators agendas for the last six years or so.

Sustainability Regulations: Are We There Yet?

The global environment continues to be filled with risks and uncertainties relating to future US policy proposals, global growth prospects, evolving geopolitical tensions and technological development.&nbsp;Asia-Pacific regulators remain alert to these global challenges, responding in an agile manner whilst also seeking opportunities and creating policy headroom.As the continuing trend of wealth creation in Asia drives demand for more sophisticated savings and investment offerings, regulators across Asia are increasingly focused on regulations that are designed to cater to this demand while also keeping a watchful eye on protecting investor interests.&nbsp;This is coupled with a greater focus on operational resiliency and risk management and evolving geopolitical developments.&nbsp;To learn more about regulatory trends and priorities in Asian markets such as Hong Kong, Singapore, South Korea and Australia over the next couple of years, across different market segments, covering topics such as:<ul style="list-style-type:disc;"><li>Combatting AML;</li><li>Sustainability;</li><li>Digital assets and tokenization;</li><li>Capital requirements;</li><li>Latest funds’ developments;</li><li>Corporate governance;</li><li>Artificial Intelligence;</li><li>Operational risk and continuity planning;</li><li>Data transformation;</li><li>Valuation guidance and liquidity risk management; and geopolitical risks.&nbsp;</li></ul>

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The global environment continues to be filled with risks and uncertainties relating to future US policy proposals, global growth prospects, evolving geopolitical tensions and technological development.&nbsp;

Asia-Pacific Regulatory Priorities for 2025 – Predictable Unpredictability 

Post the UK’s departure from the European Union (EU), we entered a realm of UK/EU financial services regulation, which has lost its harmonised nature, which included relying on passporting rights across EU Member States.&nbsp;UK policy makers were now free to take advantage of their expanded rule making powers whilst the EU continued to chart its collective path.&nbsp;Since then, successive UK governments have called for policy makers to prioritise growth in the UK economy, while in the EU, the European Commission has launched the Savings and Investments Union, aimed at creating better financial opportunities for EU citizens, while enhancing the EU’s financial system’s capability to connect savings with productive investments.&nbsp;In this article we look at the current approaches to financial services regulation by the EU and UK, noting any divergence, and looking at whether emerging differences are progressing towards similar outcomes or different policy objectives.&nbsp;We look at the latest and planned regulatory developments in the EU and UK, impacting a variety of financial services firms. These include:&nbsp;<ul style="list-style-type:disc;"><li>MiFID II/MiFIR;</li><li>EU PRIIPS vs UK CCIs;</li><li>EMIR;</li><li>UCITS Directive;</li><li>Eligible Assets Directive;</li><li>Money Market Funds;</li><li>AIFMD;</li><li>ELTIF vs LTAF;</li><li>Loan Originating AIFs;</li><li>T+1; and</li><li>Short Selling Regulations.</li></ul>We also look at how the EU and UK have been managing divergence through the introduction of the Joint EU-UK Financial Regulatory Forum.

Post the UK’s departure from the European Union (EU), we entered a realm of UK/EU financial services regulation, which has lost its harmonised nature, which included relying on passporting rights across EU Member States.&nbsp;

Continental Drift: Financial Services Regulation in the EU and UK

Expectations for U.S. based investment companies’ narrative disclosures continue to evolve from a regulatory and best practices perspective. As a result, boards of trustees, investment advisers and other service providers must remain informed to enable transparency and compliance. This article highlights key areas of focus based on recent regulatory changes, risk alerts and enforcement activity.Disclosure requirements for registered investment companies (including mutual funds and exchange traded funds, or “funds”) have expanded in recent years, driven by regulatory changes and heightened expectations for transparency.&nbsp;Implementing robust disclosure practices is essential for helping to maintain a strong culture of compliance, mitigating legal and reputational risks, and upholding the core principle that investors should have access to full and fair disclosures.This article explores recent evolutions in narrative disclosure requirements that apply to funds, highlighting key areas of focus for compliance while providing insights on how company policies can be updated to adapt to the regulatory landscape.&nbsp;It further explores:&nbsp; •&nbsp;&nbsp;&nbsp;&nbsp;SEC Exams and Disclosures •&nbsp;&nbsp;&nbsp;&nbsp;SEC FY 2025 Exam Priorities •&nbsp;&nbsp;&nbsp;&nbsp;2024 Risk Alert Observations and Disclosures •&nbsp;&nbsp;&nbsp;&nbsp;Recent regulatory changes impacting funds’ disclosure obligations •&nbsp;&nbsp;&nbsp;&nbsp;Tailored shareholder reports and disclosure of material fund changes •&nbsp;&nbsp;&nbsp;&nbsp;Shareholder reporting amendments •&nbsp;&nbsp;&nbsp;&nbsp;Proxy voting and share ownership •&nbsp;&nbsp;&nbsp;&nbsp;Names Rule •&nbsp;&nbsp;&nbsp;&nbsp;Artificial Intelligence •&nbsp;&nbsp;&nbsp;&nbsp;CybersecurityAdopting a well-structured and proactive approach to disclosure processes can mitigate compliance risks and demonstrate a commitment to transparency, accuracy and sound governance practices.

Expectations for U.S. based investment companies’ narrative disclosures continue to evolve from a regulatory and best practices perspective. As a result, boards of trustees, investment advisers and other service providers must remain informed to enable transparency and compliance. This article highlights key areas of focus based on recent regulatory changes, risk alerts and enforcement activity.

Say What? Keeping Current with U.S. Fund Disclosures

Assets invested in the global Exchange Traded Fund (ETF) industry reached a new record high at the end of May 2025 – standing at USD16.27 trillion. In this article we consider what led the way in terms of latest trends and look at:<ul style="list-style-type:disc;"><li>ETF characteristics;</li><li>Active ETFs and their associated product development journey (including disciplinary devices and regulatory considerations such as transparency and naming conventions);</li><li>ETF liquidity benefits over mutual funds;</li><li>The global spread of ETF products;</li><li>Examine the potential benefits, and possible issues, associated with dual share class ETFs;</li><li>Citi as an ETF partner; and&nbsp;</li><li>Look to what the future may hold.</li></ul>Overall, ETFs will continue to evolve, addressing demographic trends such as the rise in digitally-savvy investors, anticipated regulatory changes, and an increased focus on wealth accumulation.

Assets invested in the global Exchange Traded Fund (ETF) industry reached a new record high at the end of May 2025 – standing at USD16.27 trillion. In this article we consider what led the way in terms of latest trends and look at.ETF characteristics; Active ETFs and their associated product development journey (including disciplinary devices and regulatory considerations such as transparency and naming conventions); ETF liquidity benefits over mutual funds; The global spread of ETF products; Examine the potential benefits, and possible issues, associated with dual share class ETFs; Citi as an ETF partner; and&nbsp; Look to what the future may hold.Overall, ETFs will continue to evolve, addressing demographic trends such as the rise in digitally-savvy investors, anticipated regulatory changes, and an increased focus on wealth accumulation. &nbsp;

ETFs: Passive or Active – The World is Your Oyster!

In this article we focus on a holistic approach to growth across various markets, in particular the European Union (EU) and UK as they work towards the pursuit of growth friendly policies, whilst also looking at the approaches of other jurisdictions, such as Hong Kong, Australia and the U.S.EU In the EU, we cover the journey of the European Commission (Commission) and its Capital Markets Union, through to the more recent introduction in March 2025 of the Commission's Savings and Investment Union, which is intended to seek to offer EU citizens broader access to capital markets and better financing options for companies.UK In the UK, we look at the expanded remit for growth that the Government has given the Financial Conduct Authority (FCA), amongst other regulators. The FCA also has a new secondary international competitiveness and growth objective, so we look at how it is approaching growth versus investor protection considerations.Expanding on this, we also look at the recent Mansion House Accord, aimed at securing better financial outcomes for Defined Contribution savers.Hong Kong and Australia Further afield, in Hong Kong and Australia, while we do not see the emergence of wider growth agendas, both jurisdictions have individual policies in place where growth can take hold in their respective financial frameworks.U.S. And finally in the U.S., with a new administration and new Chair of the Securities and Exchange Commission (SEC), we look at how the latter intends to get the SEC back to its roots, which includes promoting innovation.

In this article we focus on a holistic approach to growth across various markets, in particular the European Union (EU) and UK as they work towards the pursuit of growth friendly policies, whilst also looking at the approaches of other jurisdictions, such as Hong Kong, Australia and the U.S.

Regulatory Expectations and a Pivot to Growth: A Global View

Your financial data is everywhere, but could it be better utilized? You may already be familiar with the term ‘open banking’ – a simple, secure way for individuals to share data on their cash accounts with service providers to help move, manage, and make more of their money. So, it is no wonder that regulators are looking at proposals to make even more financial data widely available.&nbsp;In this article, we look at proposals for frameworks for financial data access, currently under consideration in the European Union and the United Kingdom, as well as considering the potential implications for impacted firms.

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Your financial data is everywhere, but could it be better utilized? In this article, we look at proposals for frameworks for financial data access, currently under consideration in the European Union and the United Kingdom, as well as considering the potential implications for impacted firms.

Are You 'Open' to Sharing More of your Financial Data?

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On 16 May 2025, the Fund Market Inquiry submitted its interim report on measures to strengthen the competitiveness of the Swedish funds markets, including a review of the rules on redemption frequency in mutual funds and special funds, to the Swedish Minister for Financial Markets.Originally instigated by the Swedish government on 14 December 2023, the interim report focuses on modernizing Swedish fund legislation to enhance the competitiveness and resilience of its local funds market.In this article we look at the recommendations and the potential impact they could have on the regulation of investment funds in Sweden. &nbsp;

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On 16 May 2025, the Fund Market Inquiry submitted its interim report on measures to strengthen the competitiveness of the Swedish funds markets, including a review of the rules on redemption frequency in mutual funds and special funds, to the Swedish Minister for Financial Markets. Originally instigated by the Swedish government on 14 December 2023, the interim report focuses on modernizing Swedish fund legislation to enhance the competitiveness and resilience of its local funds market.

Sweden Looks to Create a Stronger Fund Market

<ul><li>2026 looks to be the year where global financial services regulation begins to pivot</li><li>Regulators in the APAC region are actively implementing new frameworks for virtual assets, tokenised securities and blockchain integration, seeking to balance innovation with investor protection and market integrity</li><li>Authorities are also strengthening supervision in areas like AI, private markets, data transparency and operational resilience, evidenced by comprehensive reviews and inspections across the featured economies</li><li>And governments are pursuing strategies to foster economic growth through significant financial market reforms, including South Korea’s entry into the World Government Bond Index and initiatives in Hong Kong and Singapore to expand retail access to private market funds and promote tokenisation</li></ul>

Overall, the Asia Pacific region is demonstrating a proactive and strategic approach to modernising its financial regulations to accommodate emerging technologies and global economic shifts.In this article we touch on key trends arising from the global economy, evolving geopolitics and regulation. This is followed by a deeper dive on trends that are currently tracking across specific Asia Pacific regions – namely, South Korea, Australia, Hong Kong and Singapore.

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2026 looks to be the year where global financial services regulation begins to pivot.

Navigating the Economic and Regulatory Landscape in 2026: Opportunities and Challenges in Asia Pacific

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Over a decade in the making, the journey toward fully integrated EU capital markets began with the Capital Markets Union Action Plan in 2015. Despite significant legislative progress, fragmentation, regulatory divergence, and cross-border barriers have persisted.&nbsp;Renewed calls for action followed in 2019, 2020, 2023, and 2024 — culminating in the launch of the Savings and Investments Union (SIU) in March 2025 and the EU’s Market Integration and Supervision Package (EU MISP) in December 2025 (which is a cornerstone of the SIU).

<ul><li data-list-item-id="e82449d22e2f65145292cb7bb433e50b0">The EU's Market Integration and Supervision Package (EU MISP) is a landmark legislative reform package launched in December 2025 as a core component of the Savings and Investment Union (SIU), designed to dismantle cross-border barriers in EU capital markets through automatic passporting, a central ESMA data platform, a depositary passport and simplified intra-group rules for UCITS and AIFs</li><li data-list-item-id="e6cb2f8e4d932a749e7ce460c6c2169ff">EU MISP is the most significant capital market integration initiative since MiFID II and MiFIR, directly addressing the fragmented regulatory landscape that increases compliance costs, delays market access and limits the ability of asset managers to scale cross-border fund distribution across EU Member States</li><li data-list-item-id="ecffbe0cf8aecd039eeef39a26e693e14">Following the EU Parliament ECON Committee's publication of draft reports in June 2026 and a political commitment to the "One Europe, One Market" Roadmap, the European Parliament and Council are targeting a political agreement by end-2026 with phased implementation running from mid-2027 to mid-2029</li></ul>

Over a decade in the making, the journey toward fully integrated EU capital markets began with the Capital Markets Union Action Plan in 2015. Despite significant legislative progress, fragmentation, regulatory divergence, and cross-border barriers have persisted.&nbsp; Renewed calls for action followed in 2019, 2020, 2023, and 2024 — culminating in the launch of the Savings and Investments Union (SIU) in March 2025 and the EU’s Market Integration and Supervision Package (EU MISP) in December 2025 (which is a cornerstone of the SIU).

 Capital Market Harmonization: The EU's Market Integration and Supervision Package

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A year has passed since we last compared developments in financial services regulation in both the European Union (EU) and the United Kingdom (UK). This included where the respective jurisdictions were diverging and where they were progressing towards similar policy objectives, albeit with different approaches (for example, prescription versus outcomes-based regulatory regimes).&nbsp;This year, as we revisit these evolving topics, and cover the latest policy developments, we have split our update into three complementary articles. In this first article we look at technological and innovation related developments.&nbsp;

<ul><li data-list-item-id="eb5704655c11300a3326f8790044ea809">This article tracks the latest developments in EU and UK financial services regulation across digital innovation themes including central bank digital currencies (CBDCs), stablecoin regulation, crypto-assets under MiCA and the FCA regime, fund tokenisation using distributed ledger technology (DLT) and AI and cybersecurity frameworks</li><li data-list-item-id="e916eb370664146e705f7509c940d2bca">As the EU and UK pursue divergent yet often complementary regulatory approaches to digital finance, asset managers and fund operators face an evolving and increasingly complex compliance landscape spanning MiCA, DORA, the EU AI Act and new UK frameworks such as FRAME and the FCA's crypto-asset regime</li><li data-list-item-id="ec6577824789de38b21b2fc828cd4ebce">Key regulatory milestones to watch include the EU's digital euro interinstitutional negotiations targeting year-end 2026, the UK's decision on the digital pound and next steps on the crypto-asset authorisation gateway opening in September 2026 and the FCA's FRAME consultation closing in September 2026 ahead of final rules expected in the first half of 2027</li></ul>

Trustee & Fiduciary Regulatory Insights

IN THIS SERIES

Ongoing Developments in Financial Services Regulation in the EU and UK - Part I

Capital Market Harmonization: The EU's Market Integration and Supervision Package

Navigating the Economic and Regulatory Landscape in 2026: Opportunities and Challenges in Asia Pacific

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