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…

On December 3, 2025, the Securities and Exchange Commission (the “SEC”) issued an exemptive order to postpone the compliance deadline for Rule 13f-2 under the Securities Exchange Act of 1934 by two years.  The new deadline for compliance is January 2, 2028. Rule 13f-2 was adopted in October 2023 and compliance had already been extended…

Overview

On December 10, 2025, the United States Supreme Court will hear arguments in FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd. to resolve a circuit split and determine whether there is a private right of action for violations of the Investment Company Act of 1940, as amended (the “1940 Act”).

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 November 2025:

Asset Management / Wealth Management

17 November – Liquidity Management RTS: The European Commission has adopted Delegated Regulations containing regulatory technical standards (RTS) on liquidity management tools under the Alternative…