Welcome to the FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK, EU and U.S. financial services regulation.

Key developments in December 2025:

Asset Management / Wealth Management

18 December – AIFMD 2.0 Liquidity Management Tools: European Securities and Markets Authority (“ESMA”) published an amended version of its guidelines on…

Overview

On January 8, 2026, the Federal Communications Commission (FCC) announced a landmark settlement with the Marlink, a satellite and ground station operator, marking the first-ever enforcement of a Team Telecom national security mitigation agreement. Initiated after a referral from the Department of Justice’s National Security Division (DOJ), the investigation revealed that Marlink violated the…

On January 7, 2026, the Securities and Exchange Commission (the “SEC”) proposed updates to the definition of “small entity” for purposes of the Regulatory Flexibility Act (the “RFA”). Although the proposed changes, if adopted, would not directly affect the regulatory burden of any entity, over the long term, they could have a substantial impact on…

On 15 December 2025, HM Treasury took a significant step towards establishing a UK regulatory regime for cryptoassets by laying the draft ‘Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2005’ (the “Draft Order”) before Parliament.

The Draft Order aims to set the statutory foundation for a new UK cryptoasset regulatory regime…

Overview

On December 19, 2025, the Commodity Futures Trading Commission (the “CFTC”) issued a no‑action letter (the “No‑Action Letter”) that permits many private fund managers registered with the Securities and Exchange Commission (the “SEC”) to forgo registering with the CFTC as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) or to withdraw existing CPO/CTA…

Legislation that will subject non-US companies that publicly report in the U.S. to short-swing profits liability rules under Section 16 of the Exchange Act is embedded in the annual defense funding bill that has passed in the House and goes to the Senate as early as next week.  The requirement would apply to companies that…

On 9 December 2025, negotiators from the European Parliament (EP), the Council of the European Union (the Council) and the European Commission reached a provisional political agreement on the final text of their “Omnibus” package amending the Corporate Sustainability Reporting Directive (CSRD).

Though the final text is not yet published, the publicly-available press-releases confirm a…

Background

On 8 December 2025, the United Kingdom’s Financial Conduct Authority (“FCA”) published a consultation paper (CP25/36) on amending its rules on client categorisation and conflicts of interest (the “Consultation Paper”).

The Consultation Paper is seeking to reset how firms distinguish between retail and professional clients, as the rules currently stem…

On December 2, 2025, Brian Daly, Director of the Securities and Exchange Commission (the “SEC”) Division of Investment Management (the “Division”), delivered remarks to the American Bar Association outlining the Division’s top priorities under his leadership: deregulation, modernization, democratization, and artificial intelligence (“AI”).

Daly noted that the Division’s agenda will largely be driven by the…