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 January 2026:

Asset Management / Wealth Management

2 February – Client Categorisation: The United Kingdom Financial Conduct Authority’s (“FCA”) consultation paper (CP25/36) on its proposals to amend the client

The new Administration has a clear mandate to provide a securities regulatory pathway for crypto, but it had been unclear whether the SEC would take the initiative in building a framework for crypto regulation, or whether legislation making its way through Congress would steal the momentum.  What is taking shape is a blend of the

  • FinCEN has now adopted its previously‑proposed two‑year delay in the effective date for the investment adviser AML rule (including the requirements to establish AML programs and file SARs) until January 1, 2028.
  • FinCEN also reaffirmed its intent to use this period to further review and tailor the rule, and it

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