Knowledge Base
Practical reads on AI, fintech, and digital-asset regulation
Articles and alerts written by the Licentium team. Search by topic, author, or tag.
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Pensions Regulator Publishes AI Guidance for Pension Scheme Trustees, United Kingdom, 29 October 2026
The Pensions Regulator published guidance on 29 October 2026 setting out how trustees and scheme managers should govern artificial intelligence in occupational pension schemes. The guidance sets seven principles, states that AI does not alter trustees' existing fiduciary and legal duties, and holds trustees accountable for scheme processes whether those processes are run in house or by a third party provider.
SEC Staff Treats Canton Coin as a Digital Commodity, United States, 3 November 2026
The SEC's Division of Corporation Finance told Digital Asset Holdings on 3 November 2026 that it views Canton Coin as a digital commodity under the Commission's March 2026 crypto asset interpretation, and that it would not recommend enforcement action over programmatic minting of the coin by Super Validators, Validators and application providers without registration under the Securities Act or the Exchange Act.
FCA Introduces Video Guides for Cryptoasset Firms
The FCA has launched video guides to assist cryptoasset firms in the authorisation process under the new regulatory regime.
FCA Sentences Christopher Woolcott for Fraudulent Takeover Bid
The Financial Conduct Authority has sentenced Christopher Woolcott to a suspended prison term for orchestrating a £154 million fake takeover bid targeting Touchstone Exploration Inc.
SEC Staff Grants Rule 17f-2 No-Action Relief for Blockchain Fund Share Self-Custody, 12 August 2026
The staff of the SEC's Division of Investment Management issued a no-action letter to Franklin Templeton on 12 August 2026, stating that it would not recommend enforcement action under Section 17(f) of the Investment Company Act of 1940 and Rule 17f-2 where registered funds hold shares of an affiliated government money market fund in the custody of an affiliated transfer agent, and ownership is recorded in a system combining internal book entry with the Stellar blockchain. Twelve conditions attach to the position.
Bank of Thailand Opens Public Hearing on THB Stablecoin Supervision, Thailand, 19 October 2026
The Bank of Thailand opened a public hearing on its principles for supervising business operators connected with THB Stablecoin, running from 19 October to 17 November 2026. The document covers coin issuers and wallet providers, and sets out risk management, openness and interconnection with existing payment systems, and service efficiency as the three dimensions of supervision. Issuer numbers would be limited at the outset, while wallet providers meeting the criteria could apply for a licence in application rounds.
Advocate General Szpunar Opinion on AI Chatbots and Press Publishers' Rights, EU, 3 November 2026
Advocate General Maciej Szpunar delivered his opinion on 3 November 2026 in Like Company v Google Ireland (C-250/25), a reference from the Budapest Regional Court. He concluded that answers generated by an AI chatbot can engage a press publisher's reproduction right under Article 15(1) of Directive (EU) 2019/790, and that the right of making available to the public is generally infringed where the publication's form of expression is systematically recognisable. He treated the questions on model training as inadmissible.
ESMA and ECB Seek Nominations for Tokenisation Standards Group
The European Central Bank, European Commission, and ESMA are seeking nominations for a stakeholder group on tokenisation standards, with a deadline of 11 September 2026 for submissions.
EBA releases final methodology for 2027 EU-wide stress test
The European Banking Authority has published the final methodology and draft templates for the 2027 EU-wide stress test, which will begin in January 2027, requiring compliance from all regulated entities.
ECB, Commission, and ESMA Seek Nominations for Tokenisation Standards Group
The European Central Bank, in collaboration with the European Commission and ESMA, is seeking nominations for a stakeholder group focused on developing tokenisation standards in finance, with a deadline of 11 September 2026 for submissions.
EBA Publishes Factsheet on White Labelling
The European Banking Authority has released a factsheet on white labelling, guiding firms on compliance and risk mitigation in banking and payment services.
New York Enacts Chapter 368 Restricting AI Companion Features for Minors, 28 October 2026
Governor Kathy Hochul signed Senate Bill S9051B on 28 October 2026 as Chapter 368 of the Laws of 2026. The Act adds Article 48 to the New York General Business Law, sections 1800 to 1805, making it unlawful for an operator to provide specified artificial intelligence companion features to a covered user who is a minor, and requiring a reasonable age assurance method. The Attorney General may seek civil penalties of up to twenty-five thousand dollars per violation. Article 48 takes effect on 1 January 2027.
DHS Orders DeepSeek Products Excluded From Federal Civilian Systems, United States, 20 October 2026
The Department of Homeland Security published notice of an order excluding information technology products and services developed by Hangzhou DeepSeek Artificial Intelligence Co., Ltd from federal civilian agency procurements, and requiring removal of DeepSeek and DeepSeek-affiliate products from civilian agency information technology. The notice appeared at 91 Federal Register 66346 on 20 October 2026 under docket DHS-2026-0628, made under the Federal Acquisition Supply Chain Security Act of 2018 on a recommendation of the Federal Acquisition Security Council.
OCC Bulletin 2026-54 Guides Examiners on Bank Super Intelligence Use, United States, 4 November 2026
The Office of the Comptroller of the Currency issued Bulletin 2026-54 on 4 November 2026, setting out how its examiners should review the use of super intelligence by national banks, federal savings associations, and federal branches and agencies. The bulletin states that examiners should not treat super intelligence as a separate and distinct risk category and that banks are not required to define a separate super intelligence risk appetite. It states that it does not establish supervisory expectations for banks.
AMF announces webinars on Listing Act and AML compliance
The AMF will host two webinars on 6 November 2026, focusing on the Listing Act and AML compliance for financial firms.
UK Government Publishes Software Market Analysis
The UK government has released an analysis of the software market, detailing firms and their offerings. This report is relevant for firms involved in AI and technology development.
Crypto grants from Cayman foundations to Indian developers
A Cayman foundation proposes funding an Indian private limited company to develop open-source protocol software. Its agreement calls the payment a grant and contains milestones, spending restrictions, reporting, intellectual property (IP) provisions and termination rights. Before either party signs payment instructions, they must identify what the foundation receives and which Indian route permits the company to accept the funds.
Director replacement under a BVI VISTA trust
Token delegates have voted to ask a trustee to remove a director of a BVI crypto company and install a replacement. The trustee holds designated shares under a Virgin Islands Special Trusts Act (VISTA) trust. The founder disputes the instruction. Whether the replacement can proceed depends on the trust's office-of-director rules, the rights attached to its shares and the company's constitution.
Beneficial ownership of a memberless Cayman crypto foundation
A service provider asks who controls a foundation. The foundation has ceased to have members. Its founder retains appointment and veto powers, a professional delegate votes tokens for others, and several people sign treasury transactions. The founder proposes surrendering one appointment power while keeping a contractual approval right.
Cayman STAR trusts and token-holder enforcement
Calling token holders beneficiaries of a Cayman Special Trusts Alternative Regime (STAR) trust does not give them power to enforce its treasury promises. The trust’s appointed enforcer holds that standing. Holders need a separate legal basis to demand payment, obtain information or challenge an inactive enforcer. A token vote supplies none of those rights automatically. Trusts Act (2021 Revision), ss. 100–102.
EBA outlines next steps for supervisory reporting simplification
The European Banking Authority (EBA) plans to publish a final report on supervisory reporting simplification in December 2026, following industry feedback. This aims to reduce reporting costs while maintaining necessary supervisory information for all regulated entities.
EBA announces next steps for supervisory reporting simplification
The European Banking Authority (EBA) has outlined the next steps for simplifying EU supervisory reporting, extending implementation timelines based on industry feedback. Financial institutions subject to these requirements may see reduced compliance burdens.
Brazil EU adequacy when a fintech uses US AI subprocessors
A Brazilian fintech offers its service to EU customers using a US model API and an offshore support vendor. It handles both EU and Brazilian customer data. The company tells procurement that the Brazil EU adequacy decision removes transfer paperwork.
Emotion recognition in a Moroccan AI call-centre product sold to France
The EU AI Act prohibited practices rules make a proposed employee score the first decision in a sale. A Moroccan supplier offers a French financial-services call centre transcription, conversation-topic analysis and a score labelled employee stress or enthusiasm. The customer wants coaching and performance ranking. If the score infers employees' emotions from their voice characteristics, the supplier should remove that functionality from the French offer before supply. The customer must not deploy it for that purpose. (Regulation (EU) 2024/1689, Articles 2(1) and 5(1)(f).)
Indonesian tokenised bonds distributed through a Hong Kong intermediary
An Indonesian corporate group plans to issue tokenised debt through a Hong Kong securities distributor. Its technology provider will maintain the token register and wants transfers available through a separate website. For this Hong Kong tokenised securities offer, the first decisions concern the debtor, the ownership record and the businesses permitted to arrange transactions.
Can a Kenyan fintech data marketplace qualify as an EU data intermediary?
A Kenyan company plans to match EU businesses supplying datasets with fintech and AI buyers. It wants to charge transaction fees and use the exchanged data for its own credit analytics product. Those activities require different treatment under the EU Data Governance Act (DGA).
An ADGM private credit fund financing South African fintech loans
A South African fintech originates business loans and wants an Abu Dhabi Global Market (ADGM) private credit fund to finance selected exposures. It plans to keep servicing the loans and absorb an agreed first layer of losses. The ADGM manager would raise capital from professional investors.
When an Egyptian open-source fintech SDK supplier becomes a CRA manufacturer
An Egyptian developer publishes an open-source software development kit (SDK) and sells a supported binary under its own brand. A French fintech modifies that binary, bundles it into a customer product and expects the developer to handle all security duties.
Delisting a cryptoasset at an Irish CASP with customers in Brazil
An Irish cryptoasset service provider within a Brazilian group plans to remove one asset from trading and custody. Its other services will continue. Some customers cannot withdraw because their balances fall below a platform threshold or no receiving service supports the network. The company proposes automatic conversion at a rate it selects.
Dutch Central Bank Removes Deadline for Crypto Service Providers
The Dutch Central Bank has removed the deadline of 23 October 2026 for application forms related to crypto service providers, impacting compliance timelines under MiCA.
Can a Kenyan token project rely on MiCA's free-airdrop exception?
A Kenyan software project plans to distribute tokens to EU users before seeking an EU exchange listing. Users pay no purchase price, but must provide profile data and complete promotional tasks. A claim fee may also apply. Under EU crypto airdrop regulations, those conditions matter independently of the headline price.
MiCA best execution when an EU CASP uses affiliated UAE liquidity
An Irish crypto-asset service provider (CASP) in a South African group plans to route most customer orders to its UAE liquidity affiliate. The affiliate may fill orders from its own inventory or pass them to other venues. The Irish company says the affiliate offers the best price and proposes one general customer consent.
Texas biometric privacy requirements for a Brazilian KYC supplier
A Brazilian KYC supplier compares selfies with identity-document photographs, creates face-geometry templates and keeps them for fraud prevention. It also wants to use those templates to improve its model. Its Texas fintech customer assumes that its privacy notice and financial-sector status cover the arrangement.
MiCA sustainability disclosures for a Vietnamese token and its EU trading venue
A Vietnamese token project plans admission to trading in the EU. It uses a public network, buys estimated environmental metrics from a specialist vendor and markets its token as carbon neutral. The trading venue needs MiCA sustainability disclosures.
Founder token vesting and inside information before an EU listing
A founder allocation in an Indian-founded token project is due to vest shortly before an EU exchange listing and an unreleased commercial announcement. The team proposes an automatic transfer to a market maker, followed by sales under an existing treasury mandate. The crypto insider trading question arises before the first exchange trade. It concerns who knows what, what each transaction changes, and whether anyone uses that information to influence execution.
AI voice cloning rights for a South African supplier selling into the US
AI voice cloning laws affect what a supplier can sell with a reusable voice model. A South African supplier plans to record a performer for a Tennessee customer's automated announcements and advertising. The customer wants perpetual sublicensing, emotional style changes and reuse by affiliates. The recording agreement covers conventional audio production but says nothing about model training, generated speech or use after termination.
AMF warns against unregulated Forex and crypto-derivative actors in France
The AMF has issued a warning about unregulated entities in France offering Forex and crypto-derivative investments without authorization, highlighting potential financial risks for investors.
Law Commission Consults on Software and AI Product Liability, England and Wales, 8 October 2026
The Law Commission of England and Wales opened a consultation on 8 October 2026 on reform of the product liability regime in Part 1 of the Consumer Protection Act 1987. Its provisional proposals would treat software and AI systems as products in their own right, bring the design features and recommendation algorithms of social media and other online platforms within scope, and extend liability to online marketplaces. Responses are due by 14 January 2027.
Australian Treasury Consults on Crypto Asset Tax Transparency Draft Legislation, 15 October 2026
The Australian Treasury released exposure draft legislation on crypto asset tax transparency on 15 October 2026, with the consultation closing on 28 October 2026. The draft gives effect in Australian law to the OECD Crypto-Asset Reporting Framework, sets up domestic reporting on crypto asset transactions involving Australian residents, and updates the Common Reporting Standard. The Australian Taxation Office states that the measure is not yet law and that Australia's first exchange under the Crypto-Asset Reporting Framework is expected to commence in 2028.
Bafin imposes fines on CM Center Management GmbH and FCR Immobilien Aktiengesellschaft
Bafin has imposed administrative fines on CM Center Management GmbH and FCR Immobilien Aktiengesellschaft for violations of the German Securities Trading Act (WpHG).
US remittance errors when a Philippine payout partner fails
A US-facing remittance provider uses a Philippine partner to deliver funds. The sender has been debited, but the recipient receives too little or nothing. The providers dispute whether a local fee, an exchange-rate change or missing beneficiary information caused the failure.
European Commission launches AI toolbox for public administrations
The European Commission has introduced an AI toolbox to assist public administrations in implementing the Apply AI Strategy, providing practical tools and guidance for effective AI adoption.
European Commission launches Education and Skills package impacting AI regulation
The European Commission has initiated an Education and Skills package to address skills decline and teacher shortages, which may influence AI technologies in education.
FCA intervenes to protect consumers from disguised remuneration scheme repayments
The Financial Conduct Authority has restricted Ethica Resolve Limited's debt collection practices to protect consumers from repayment demands related to disguised remuneration schemes.
EBA publishes revised Guidelines on internal governance under CRD
The European Banking Authority (EBA) has published revised Guidelines on internal governance under the Capital Requirements Directive (CRD), reflecting changes from CRD VI and aiming to simplify regulations for banks across the EU.
A Brazilian SaaS company's UK bank account closure and payment continuity
Having a business bank account closed can interrupt subscription receipts and leave wages or refunds unpaid. A Brazilian-owned UK SaaS company faces that problem after receiving a closure notice for an account opened after April 2026. The bank also wants transaction explanations.
New York UCC Article 12 for a Mexican borrower's crypto collateral
A Mexican company plans to secure a Singapore lender's business loan with crypto held by a third-party custodian. The proposed loan, security and custody arrangements use New York law. The lender expects a crypto collateral control agreement to establish priority wherever enforcement occurs.
ACH return risk for a Colombian fintech collecting US business payments
A Colombian fintech collects invoices from US companies through a US sponsor and pays Colombian suppliers before the collection risk has ended. A customer disputes an Automated Clearing House (ACH) debit. The sponsor charges the fintech's reserve, although the product team has already marked the payment final.
Consumer Duty fair value in a Ghanaian fintech's UK wallet partnership
A Ghanaian fintech plans to supply the app and acquire customers for the retail wallet of a UK electronic money institution (EMI). The proposed revenues include a monthly subscription, a foreign exchange (FX) spread, inactivity charges and paid priority support. The EMI requires a Consumer Duty fair value assessment before approving the pricing.
ESMA updates Q&A on MiCA regulations for CASPs
ESMA has updated its Q&A section with clarifications on MiCA and DORA, impacting crypto-asset service providers and firms in digital finance.
FINMA Approves Switzerland's First Retail Bitcoin ETF With Risk Diversification Exemption, 20 October 2026
FINMA approved Switzerland's first retail fund investing directly in Bitcoin on 20 October 2026, classifying it as an other fund for alternative investments with a specific risk. The regulator granted an exemption from the risk diversification rules that would otherwise apply, citing Bitcoin's trading history and trading volume. Distribution stays subject to conduct rules at the point of sale under the Financial Services Act, and fund documents must set out the risks, including volatility and the risk of capital loss.
FCA Issues Warning on Quantum Computing Risks to Financial Sector
The Financial Conduct Authority (FCA) warns UK financial firms to prepare for post-quantum cryptography migration by 2028 to protect against quantum computing threats.
High Court Sets Applicable Law for Bitcoin Victim Claims, England and Wales, 12 October 2026
Mr Justice Turner has decided the applicable law issue in the Director of Public Prosecutions' civil recovery proceedings over Bitcoin seized from Zhimin Qian. Claims by alleged victims of the Tianjin Lantian Gerui scheme under section 281 of the Proceeds of Crime Act 2002 rest on contracts made in China, and Rome I points those questions to Chinese law. English law, as the law of the situs, decides whether Bitcoin is property and governs the proprietary questions arising once the Director asserted a claim to recoverable property in England.
AI-generated false citations, supervision and client confidentiality after Munir
The Upper Tribunal examined false authorities in two immigration proceedings in UK and R (on the application of Munir) v Secretary of State for the Home Department [2026] UKUT 81 (IAC). It held legal professionals responsible for checking submissions and supervising delegated work. Its decision also warned against uploading confidential client material to AI services. Those warnings require separate application of professional confidentiality, legal privilege and data protection rules. (Munir, [19]–[21], [36]–[40], [56]–[60].)
SEC Division of Examinations Publishes Fiscal Year 2027 Priorities, United States, 23 October 2026
The SEC Division of Examinations published its Examination Priorities for Fiscal Year 2027 on 23 October 2026. The document uses super intelligence in place of artificial intelligence, and names it as a focus across emerging financial technology, identity theft and privacy programmes, and systems compliance and integrity. Tokenisation of securities is listed for clearing agency and Regulation SCI reviews.
FTC Opens Section 6(b) Personalized Pricing Inquiry, United States, 28 October 2026
The Federal Trade Commission issued orders to nine companies on 28 October 2026 under Section 6(b) of the FTC Act, requiring each to report whether pricing for a product or service, or compensation for workers, varies by individual. The orders reach Delta, United, JetBlue, Lyft, Uber, DoorDash, Instacart, Target and Walmart. Recipients have 45 days from receipt to respond.
Irish Data Protection Commission Publishes AI Insights Report, Ireland, 25 September 2026
The Data Protection Commission published its AI Insights Report on 25 September 2026, setting out what Ireland's supervisory authority drew from overseeing AI products and services between 2021 and 2025. The Commission engaged with controllers on roughly 180 AI products and names Apple, Google, Meta, Microsoft, OpenAI, TikTok and X among the companies involved, reporting improvements in lawful basis, transparency, data minimisation and the protection of children. The report guides controllers rather than binding them.
Civil Justice Council Publishes AI Court Documents Final Report, England and Wales, 29 October 2026
The Civil Justice Council published its final report on the use of AI for the preparation of court documents on 29 October 2026, completing work begun by a working party co-chaired by Sir Colin Birss and Mrs Justice Joanna Smith. The report proposes a proportionate, risk-based approach that keeps professional responsibility at the centre and adds targeted safeguards where they are needed. It binds no one yet, because change would come through amendments to the Civil Procedure Rules and a new Practice Direction.
Federal Office of Justice imposes fines on two entities
The Federal Office of Justice has fined Asset-Backed European Securitisation Transaction Nineteen UG and IHS Nr. 2 GS GmbH €2,500 each for violations related to financial reporting obligations.
FCA Addresses Loan Repayment Demands Related to Disguised Remuneration Schemes
The Financial Conduct Authority (FCA) has issued a statement on repayment demands for loans linked to disguised remuneration schemes, highlighting concerns about their regulatory status and potential unenforceability.
AMF Issues Recommendations on Money Market Fund Liquidity Management
The AMF has published recommendations on liquidity management for money market funds and a synthesis of SPOT controls for SCPI client communications, impacting asset management firms and collective investment schemes.
European Commission consults on voluntary Code of Conduct for online fraud
The European Commission is consulting stakeholders on a potential voluntary Code of Conduct to combat online fraud and scams, impacting payment institutions and other entities involved in online transactions.
FCA Releases Survey on Investor Awareness of Pressure Tactics
The Financial Conduct Authority (FCA) has published survey data revealing UK investors' low recognition of pressure tactics in investment promotions compared to horror films, highlighting a need for increased awareness and education.
Binance security incident: legal view
Facts, assumptions and legal consequences across principal jurisdictions
UK crypto promotions by Kenyan creator agencies
A Kenyan agency recruits creators, edits campaign content and receives engagement or referral fees from a crypto exchange seeking UK users. Each creator introduces another publisher, channel and opportunity to alter the message. The agency must establish who prepares and communicates each promotion before assigning responsibility in its contracts.
Turkish gambling affiliates promoting British operators
A Turkish affiliate network proposes promoting a British-licensed gambling operator and earning referral fees. The intended audience is in Great Britain, while staff and publication activity may remain in Türkiye. The first decision concerns where those people create, approve and publish the promotions. The operator's licence answers a different question: which gambling activities that operator may provide to British customers.
Malta B2B licensing for an Indian gaming analytics supplier
An Indian vendor supplies dashboards and analytics to a gaming business in Malta. The operator wants an extension that influences game outcomes or maintains records essential to regulatory supervision. The proposed change affects the vendor’s legal role, its production access and the permissions needed before deployment.
Argentine game supply to Brazil after the betting prohibition
An Argentine studio develops online games and updates their logic. Its proposed Brazilian counterparty contracts with players. That allocation requires separate decisions about operating permission, the certified product, continuing support and the studio's Argentine activities.
Music NFT licences for Nigerian platforms selling to US fans
A Nigerian music platform sells NFTs connected with a recording and defined fan benefits. The commercial decision is what the buyer can actually do: stream the track, download it, display artwork or receive money. Each function determines the permissions, payment obligations and buyer terms required before distribution.
Licensing a UAE brand for a Moroccan NFT collection sold in the UK
A Moroccan creative studio commissions artwork, licenses a UAE brand and offers the collection to UK buyers. Its collection terms promise display rights or defined commercial use. The transaction depends on those promises being supported by the artist agreements, brand licence, platform arrangements and payment route.
UK launch choices for a South African BNPL business
A South African business offers deferred payment at merchant checkout. It can fund purchases and own the customer's debt, or supply software to a lender that makes the credit decision and owns the receivable. Those choices allocate different permissions, customer duties and cross-border obligations.
UK business wallets for a Ghanaian fintech under an EMI principal
A Ghanaian fintech supplies the brand, software and customer support for business wallets. A UK electronic money institution issues the e-money and maintains the customer balance. The fintech also wants to onboard customers and quote foreign exchange. Those additional functions need an activity-by-activity allocation before the branded service launches.
Prefunding an EEA stablecoin card programme from Mexico
A Mexican programme company supports cards funded through stablecoin conversion. Its European issuer must settle card transactions in fiat and requires prefunding against that obligation. The company therefore needs to agree both the amount of available settlement cash and its rights when the issuer draws, blocks or returns the reserve.
UK to Kenya remittances with stablecoin settlement
A UK customer pays pounds to send Kenyan shillings to a recipient in Kenya. Regulated providers collect the payment and deliver the payout. A Kenyan platform coordinates the service and proposes a stablecoin between those endpoints.
German CASP custody chains involving Brazilian providers
An EU crypto-asset service provider based in Germany is assessing a Brazilian provider that controls part of its key or recovery process. The CASP contracts with clients. Assets may share wallets, and both firms maintain records. The proposed client custody agreement selects German law.
Moving EU crypto customers from a Turkish exchange to a French CASP
A Turkish exchange plans to move its existing EU customers to a newly authorised group company in France. The customers need new contractual arrangements, an identified custodian and a supported route for their assets and records. The group must also decide who handles unresolved orders, withdrawals and complaints.
Mauritius staking platforms serving UK customers
A Mauritius platform proposes to arrange staking for UK customers and may appoint a custodian. The commercial decision concerns who contracts with customers, who controls their assets and what the platform promises to return. A service that operates validators, a custodian that stakes client assets and a pooled investment product require different legal work.
Outsourced AI AML alert triage from Kenya for UK fintechs
A Kenyan RegTech vendor operates AI that prioritises a UK fintech's money-laundering alerts and prepares investigation summaries. The fintech retains its nominated officer and compliance function. The commercial decision concerns how much investigation work the supplier can perform, which decisions remain with the firm, and whether the proposed service and data flows are lawful.
Cyber Resilience Act reporting for AI SDKs in EU fintech apps
A Brazilian developer licenses a software development kit, or SDK, to an EU fintech. The fintech embeds a distributed component in its app, and a vulnerability is found in that component. The immediate decisions concern the affected software, evidence of exploitation, the parties’ product roles and any consequences for financial services or personal data.
AI credit scoring contracts for UAE banks and South African suppliers
A South African vendor supplies a model and scoring service to a bank regulated by the Central Bank of the UAE, or CBUAE. Support staff and some processing remain in South Africa. The bank decides whether to lend.
AI model change control for Malaysian suppliers to Singapore banks
A Malaysian supplier provides an AI agent to a Singapore bank. The bank approves a pilot using a named model and limited tools. The supplier then proposes a different model provider and broader operational use.
MCP server permissions for Indonesian suppliers serving UK fintechs
An Indonesian supplier connects an AI agent to a UK fintech through a Model Context Protocol (MCP) service. One tool credential permits both reading records and initiating an operational action. The intended workflow requires human approval, but the credential scope does not enforce that condition.
EU AI Act provider duties for a Vietnamese API sold under a French brand
A Vietnamese supplier provides a proprietary AI API. A French company integrates it into its product, chooses the advertised purpose and sells access under its own brand. Calling the agreement a resale contract leaves the principal legal decision unresolved: which entity develops and supplies each regulated model or system?
Training a Moroccan vendor’s AI on an Irish bank’s customer prompts
A Moroccan AI supplier provides a service to an Irish bank. It wants to retain prompts and outputs to train or improve its model. Those inputs can contain personal data and bank-confidential information. The bank has approved processing needed to deliver the service, but has not approved this separate reuse.
AMF publishes SPOT controls report and issues warning on unregulated actors
The AMF has published a synthesis of its SPOT controls regarding client communications related to real estate investment companies and issued a warning against unregulated actors in the forex and crypto-asset markets.
US Treasury Proposes COINS Act Outbound Investment Rule Prohibiting Super Intelligence Investments, 22 October 2026
The US Department of the Treasury issued a Notice of Proposed Rulemaking on 22 October 2026 to implement the Comprehensive Outbound Investment National Security Act. The proposal expands the Outbound Investment Security Program, replaces the notification route for artificial intelligence transactions with a prohibition on investment in entities developing super intelligence systems in countries of concern, and adds biotechnology as a prohibited sector. Comments close on 7 December 2026.
UK DSIT Publishes Artificial Intelligence Sector Study 2025
The UK Department for Science, Innovation and Technology has released the 'Artificial Intelligence Sector Study 2025', analyzing firms developing AI products and services in the UK, which may impact compliance and regulatory frameworks.
European Commission announces Smart City Expo World Congress 2026
The European Commission will host the Smart City Expo World Congress 2026 from 3-5 November 2026, focusing on AI adoption in urban planning and management.
FCA Secures High Court Undertakings Against HTX for Non-Compliance
The Financial Conduct Authority has secured High Court undertakings against HTX to prevent unlawful promotion of crypto services to UK consumers, following legal action initiated in October 2025 due to repeated non-compliance with financial promotion rules.
ESMA publishes newsletter with updates on MiCA proposals
ESMA's latest newsletter includes updates on MiCA proposals and the appointment of Carlo Comporti as Chair, effective 1 November 2026.
EBA advises on simplifications to Taxonomy disclosures
The European Banking Authority (EBA) has published its response to the European Commission’s Call for Technical Advice regarding the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation, focusing on simplifications for credit institutions and investment firms.
Canada Publishes Proposed Stablecoin Regulations for Comment, 24 October 2026
The Government of Canada published proposed Stablecoin Regulations in the Canada Gazette, Part I, on 24 October 2026, opening a 60 day comment period. The draft would require daily reserve coverage in the reference currency, redemption at par within three business days, a cap of one per cent on redemption fees, and registration with the Bank of Canada, which would supervise issuers and administer monetary penalties. Paying yield for holding a stablecoin would be prohibited.
OCC Issues Final GENIUS Act Payment Stablecoin Rule, United States, 21 October 2026
The Office of the Comptroller of the Currency issued its final rule implementing the GENIUS Act on 21 October 2026, creating a new 12 CFR part 15 that covers reserve assets, redemption, capital, risk management, custody and the supervision of foreign payment stablecoin issuers. The rule takes effect on 18 January 2027. Bank Secrecy Act, anti-money laundering and sanctions obligations sit outside it and are reserved for a separate rulemaking conducted with the Treasury Department.
UKIPO Refuses Emotional Perception AI Patent Application on Inventive Step, United Kingdom, 1 October 2026
The UK Intellectual Property Office has refused patent application GB1904713.3 in the name of Emotional Perception AI Ltd. In decision BL O/0894/26 of 1 October 2026, hearing officer Mr S Brown held that producing a semantically better file is not a technical result, so the training details of the neural network could add no technical character and were left out of the inventive step assessment. The remaining features were obvious over common general knowledge and the application was refused under section 18(3) of the Patents Act 1977.
European Commission Publishes First AI Act Harmonised Standard EN 18286, EU, 12 October 2026
The European Commission has published the reference of EN 18286:2026 in the Official Journal, the first harmonised standard cited in support of the EU AI Act. Commission Implementing Decision (EU) 2026/2274 of 12 October 2026 lists the standard in its Annex and entered into force on the day of publication, 14 October 2026. The standard covers quality management systems for providers of AI systems, including post-market monitoring, and opens the presumption of conformity route under Article 40 of Regulation (EU) 2024/1689.
UK DSIT Publishes Privacy Notice for Tech Town Business Survey 2026-2027
The UK Department for Science, Innovation and Technology has published a privacy notice for the Tech Town Business Survey for 2026-2027, detailing personal data usage and compliance with data protection regulations.
FCA reports Bullseye Financial Ltd entered administration
On 23 October 2026, Bullseye Financial Ltd entered administration, with Robert Young and Matthew Haw appointed as joint administrators. The FCA advises customers to contact the administrators for support and to be wary of scams.
Dutch Authority for the Financial Markets updates requirements for crypto service providers
As of 23 October 2026, crypto service providers must include invoice details for assessment fees in their application forms.
Software escrow for South African AI supplied to an Irish bank
A Cape Town AI supplier offers source-code escrow to an Irish bank that depends on its fraud-alert service. The bank needs a way to continue operating after supplier failure, but the software also depends on licensed model technology and cloud services. A workable arrangement requires a recoverable deployment, permission to operate it and an alternative when a necessary dependency cannot survive the supplier.
AI debt collection from India and the UK authorisation boundary
A Pune company supplies an AI debt collection system to a UK consumer-credit lender authorised by the Financial Conduct Authority (FCA). The system drafts reminders, schedules contacts and proposes repayment options, while the lender approves customer communications and decides forbearance. The supplier wants a later version to contact borrowers and negotiate within lender-set limits. The recommended first release keeps collection activity with the lender; the supplier-operated version needs a different permission and operating structure.
Crypto Travel Rule failures between a Brazilian provider and an Irish CASP
A Brazilian virtual-asset provider wants to transfer business customers' crypto-assets to an Irish crypto-asset service provider, or CASP. The assets reach the receiving address with incomplete originator information and a legal-entity name that does not match the recipient account. The sender demands immediate release because the blockchain transfer is final. The Irish receiver should hold customer availability while it resolves the identities and missing data, then make a documented release or return decision.
Deepfake detection from Malaysia for UK payment-fraud controls
A Kuala Lumpur supplier analyses live customer-call audio and optional video for a UK payment institution. Its deepfake detection score initially goes to a trained fraud team, while the supplier seeks training samples and later voiceprint matching. The launch decision concerns which data uses and payment controls the parties can lawfully support.
Parametric insurance from a Kenyan trigger engine for UK commercial cover
A Nairobi weather-data company supplies the rainfall and flood model behind a UK insurer’s commercial property cover. The company proposes a fixed licence fee, while the insurer contracts with policyholders and bears the insured risk. The initial supplier agreement should preserve that allocation and define the effect of the trigger calculation. The policy and service terms should explain how claims proceed if the feed is wrong or unavailable.
AI recruitment from Morocco and the conditions for a French launch
A Moroccan supplier develops French- and English-language recruitment software for its first EU customer, an employer in France. The application is hosted in the EU, while engineering and support staff in Morocco have controlled access to candidate data. The proposed product combines scheduling, CV extraction, candidate ranking, interview-question generation and shortlist recommendations, with the employer taking the employment decision.
RWA tokenization of Kenyan export invoices for Singapore investors
A Kenyan trade-finance startup wants Singapore accredited investors to finance a USD export invoice due in 120 days. RWA tokenization should begin with one enforceable receivable and a restricted issue of secured notes. A dedicated Singapore company offers the clearest proposed division of rights, provided the invoice transfer, Kenyan financing activity and Singapore distribution each satisfy their own legal conditions.
SEPA direct debit software from Morocco for EU merchants
A Casablanca software company supplies invoicing and recurring-billing tools to French merchants. It proposes SEPA direct debit collections through each merchant's European payment service provider (PSP), while charging a separate software fee. The first release should keep each merchant as creditor, with its own identifier and settlement account. A partner's proposal for one shared creditor identifier and pooled account requires a different collection structure, with its own permissions and refund obligations.
Crypto asset recovery in Singapore after a Nigerian company's treasury theft
A Lagos business that supplies fintech software holds its operating reserves in USDT and wants to recover an allegedly diverted balance. Its outsourced finance manager lives in Singapore and allegedly sent company assets to addresses she controls. Singapore proceedings offer a credible route if the company can establish ownership, connect the manager to the transfers and identify assets or records within an effective enforcement route. Its first decision is whether the evidence and likely recoverable value justify urgent protection and the costs of litigation.
Crypto market making from Türkiye on EU trading platforms
An Istanbul company plans to quote buying and selling prices on an independently operated EU cryptoasset platform. It will trade its own capital through an API and receive venue fee rebates under a liquidity agreement. The company can remain outside authorisation under the EU Markets in Crypto-Assets Regulation (MiCA) if it provides no regulated service to clients. The proposed route also depends on the instruments traded and Türkiye's separate conditions for platform liquidity businesses.
Verification of payee services from the Philippines for EU payment providers
A Manila technology company wants to supply a verification of payee API to an Irish payment institution. Its software compares a proposed beneficiary name with account-holder data and returns a match, close match, no match or unavailable result. The commercial decision is whether to supply technology through an established routing and verification provider or undertake those scheme functions itself, while preserving the payment providers' legal responsibilities.
European Commission accepts Temu's action plan for Digital Services Act compliance
The European Commission has accepted Temu's action plan to address its breaches of the Digital Services Act (DSA). This decision indicates the Commission's ongoing enforcement of the DSA and its commitment to ensuring compliance among digital service providers.
European AI Office announces event on product cybersecurity
The European AI Office has scheduled an event titled 'Product Cybersecurity: Making CRA a Reality' for 11 December 2026, focusing on the intersection of product cybersecurity and the Cyber Resilience Act, impacting AI systems.
Pennsylvania Enacts Artificial Intelligence Deceptive Advertising Act as Act 99, United States, 22 October 2026
Pennsylvania Governor Josh Shapiro approved Senate Bill 806 on 22 October 2026, enacting it as Act 99 of 2026 under the short title the Artificial Intelligence Deceptive Advertising Act. Section 4(a) requires an advertiser to carry a clear and conspicuous disclosure where synthetic content creates a false consumer perception about the nature, origin or authenticity of advertised goods or services. Section 6 sets commencement at 60 days after approval, on 21 December 2026, and Section 5(c) caps the civil fine at 3,000 dollars.
Central Bank of Ireland launches MiCAR Title II Notification Portal
The Central Bank of Ireland will require submitters of certain crypto-assets to use the new MiCAR Title II Notification Portal for submissions, modifications, and related notifications.
Crypto payroll for UK employers using an Argentine platform
An Argentine fintech proposes an optional stablecoin feature for UK employers with UK-resident employees working in Great Britain. The platform would receive instructions, arrange conversion and send tokens to an employee's chosen wallet. The preferred design pays the employee's GBP salary first, then permits a separate purchase, while requiring a distinct decision about the Argentine company's regulated functions.
FCA imposes restrictions on six Annex 1 firms in the UK
The Financial Conduct Authority (FCA) has imposed voluntary restrictions on six unregulated lenders due to concerns over their anti-money laundering controls and procedures. These restrictions limit the firms' ability to take on new customers or conduct new business.
DePIN regulation in the EU for Thai hardware and node rewards
This decentralised physical infrastructure (DePIN) venture involves a Thai company designing connected computing nodes for sale to EU operators. Operators contribute capacity for business customers through a managed network. The founders are considering token rewards, a token sale for expansion and exchange trading. The strongest initial design separates device sales and fiat payment for computing work, with optional customer credits confined to an existing service and assessed separately under Thai law.
Open source AI license terms for a Vietnamese model supplier entering the EU
A Vietnamese developer plans to license a modified foundation model to an EU software integrator. The buyer wants downloadable model weights for a business customer-support product, with a hosted API as a separate option. The developer can offer commercial redistribution only if its upstream permissions, fine-tuning data rights and compliance documents support the promised use. A permissive base licence can support that transaction, but the supplier must establish the rights and responsibilities for its own release.
AI copyright in game assets supplied from South Africa to a US publisher
A South African game-art studio supplies a US publisher with drawings, edited AI imagery and substantially generated assets. The publisher requests an exclusive worldwide assignment, US registration cooperation and an uncapped non-infringement indemnity. The studio should offer different rights for different contributions, replace assets whose commercial purpose requires unsupported exclusivity, and arrange the South African exchange-control route before the operative transfer.
MPC wallet recovery and MiCA custody for an Indonesian EU launch
An Indonesian developer wants to offer EU consumers a wallet with social login and help recovering access after losing a device. The user, a service co-signer and a recovery provider hold separate signing shares. The launch decision turns on who safeguards those shares and who can replace the user's authority, including through coordinated recovery. Keeping assisted recovery points towards an authorised EU custody operation unless the design gives the providers a demonstrably narrower role.
A Mexican fintech acquisition of a Lithuanian EMI
A Mexican payment technology company proposes to buy every share in a Lithuanian electronic money institution. The group wants European business accounts, SME customers connected with Latin America and changes to the existing technology. An existing EMI license makes acquisition worth examining, provided the buyer can lawfully hold the investment and preserve the acquired company's ability to serve customers. The recommendation is to proceed conditionally, with the Lithuanian company remaining the regulated provider.
EU equity crowdfunding for a Colombian fintech
A Colombian software company wants EU investors to subscribe for new shares through an authorised crowdfunding platform. The company is a sociedad por acciones simplificada, or SAS, supplying B2B fintech technology without holding customer funds or issuing a token. The decision is whether its existing shares can support the campaign, or whether changing the company structure would solve a specific legal obstacle.
Curacao gaming license requirements for an Armenian casino platform
An Armenian software company has developed an online casino platform. Its owners are comparing their own Curaçao operator with a white label casino arrangement in which an existing licensee contracts with players. Great Britain is a proposed future market, and the commercial decision turns on who controls the gambling business and which countries that business may serve.
Supplying AI contract review from Brazil to English law firms
A Brazilian legaltech company wants to sell hosted AI contract review to law firms regulated by the Solicitors Regulation Authority (SRA) in England and Wales. Solicitors review the drafting before advising clients, while Brazilian support staff may access documents and the supplier proposes product improvement unless customers opt out. The defensible starting product requires firm control of legal work, restricted use of client material and enforceable supplier obligations. The proposed improvement default should change before live client documents enter the service.
Electronic bills of lading as bank collateral between Bahrain and Singapore
A Bahraini trade-document platform proposes electronic bills of lading (eBLs) for an exporter shipping goods to a Singapore buyer. A Singapore bank is considering trade finance against the shipment, with the carrier and commercial parties participating in the platform. The bank needs a transferable bill, an effective security interest and a delivery process it can enforce when the exporter or platform fails.
ESMA publishes interim MiCA register and measures for crypto-assets regulation
ESMA has released a compilation of level 2 and level 3 measures related to the Markets in Crypto-Assets Regulation (MiCA), including an interim register for crypto-assets and service providers, effective until 2026.
AMF and ACPR Warn on Unauthorized Forex and Crypto Investments
The AMF and ACPR issued a public warning about unauthorized investment offerings in Forex and crypto-asset derivatives in France, aiming to protect the public from financial risks.
Bafin imposes fines for notification failures under WpHG
Bafin has imposed two administrative fines of €6,000 each on an individual for failing to comply with the German Securities Trading Act (WpHG) notification requirements. The fines were issued on 21 October 2026, following the individual's failure to submit required voting rights notifications in October 2025.
European Commission issues joint statement on PHP vulnerabilities
The European Commission, along with ENISA and other agencies, urges organizations to address critical PHP vulnerabilities immediately to enhance cybersecurity measures.
ESMA updates Q&As on market structure under MiFID II, MAR, and SSR
The European Securities and Markets Authority (ESMA) has streamlined its Questions and Answers (Q&As) related to market structure under MiFID II, MAR, and SSR as part of its Simplification and Burden Reduction initiative.
EBA extends consultation deadlines due to website maintenance
The European Banking Authority has extended some consultation deadlines following website maintenance due to critical security flaws. Firms engaged in regulatory consultations should monitor EBA communications for updates on new deadlines.
ESMA announces new data reporting requirements for CASPs under MiCA
ESMA has mandated that National Competent Authorities will request order book data in a new JSON format starting six months after 28 November 2025, impacting Crypto-Asset Service Providers.
AMF and French Authorities Propose MiCA Regulation Revisions
The AMF, ACPR, and Banque de France have published joint proposals to revise the MiCA regulation, impacting crypto-asset service providers and token issuers in France and the EU.
FCA Publishes AI Good and Poor Practice for Financial Services, United Kingdom, 19 October 2026
The Financial Conduct Authority published AI in financial services: good practice and areas for improvement on 19 October 2026, drawing on supervisory work and its AI Lab testing programmes. The document sets out illustrative examples measured against existing Handbook obligations, including the Consumer Duty, PRIN, SYSC and the Senior Managers and Certification Regime. It creates no new requirements. An editorial amendment to chapter 4.1 followed on 20 October 2026.
European Commission initiates regulatory dialogue on out-of-court dispute settlement mechanism
The European Commission has begun a regulatory dialogue regarding the out-of-court dispute settlement mechanism under the Digital Services Act, involving Very Large Online Platforms and Digital Services Coordinators.
AMF and French Authorities Propose MiCA Regulation Revision
The AMF, ACPR, Banque de France, and French Treasury proposed revisions to the MiCA regulation, set for release on 21 October 2026, impacting crypto-asset service providers in France and the EU.
A 2026 guide to company jurisdictions for heavy data processing
A company that collects and analyses personal data at scale faces three separate tests when it chooses where to incorporate. They are the data protection law that binds a company formed there, the international lists that banks and counterparties screen against, and the cost of forming, running and banking the company. This guide applies those tests to 24 jurisdictions in Asia, the Middle East, the Atlantic and Caribbean, the Pacific and West Africa. Every jurisdiction here without a private-sector data protection law in force has thin banking, currency controls or both.
SEC Approves Cboe Binary Options on Issuer KPIs, United States, 13 October 2026
The Securities and Exchange Commission granted accelerated approval on 13 October 2026 to a Cboe Exchange rule change permitting the listing of binary options on key performance indicators that issuers report in their earnings filings. Release No. 34-106659, File No. SR-CBOE-2026-061 adds Rules 4.80 to 4.84, fixes a one dollar exercise settlement amount, sets expiry on the issuer earnings disclosure date and caps positions at 25,000 standard contracts per expiration. Chairman Paul Atkins recorded that the order neither addresses nor forecloses CFTC jurisdiction over KPI contracts.
MAS Issues Guidelines on AI Risk Management for Financial Institutions, Singapore, 7 October 2026
The Monetary Authority of Singapore issued its Guidelines on Artificial Intelligence Risk Management on 7 October 2026, following the public consultation it ran in November 2025. The Guidelines apply to all financial institutions and all forms of AI technology, and take effect on 7 October 2027. Institutions may phase implementation, with the expectations in Sections 3 to 4 applying from 7 October 2027 and those in Sections 5 and 6 by 7 October 2028. MAS has said it will consult the industry in 2027 on further guidance for agentic AI.
Bafin imposes fine on Nomura Holdings Inc. for WpHG breach
On 15 October 2026, Bafin fined Nomura Holdings Inc. €320,000 for failing to submit voting rights notifications during UniCredit S.p.A.’s takeover bid for Commerzbank AG in May and June 2026.
South African validators supplying crypto staking services to an Irish custodian
A hypothetical South African validator business wants to operate Ethereum infrastructure for an Irish crypto-asset service provider (CASP) authorised to hold customers' cryptoassets. The proposed contract leaves customer relationships and withdrawal credentials with the Irish custodian. The service can be structured as technical outsourcing, but the custodian must retain effective asset control and the signing system must enforce the supplier's limited role. Customer compensation after a validation failure remains a separate question from the supplier's contractual liability.
South African bullion for a Dubai gold token issuer
A hypothetical South African bullion business wants its gold to support a token issued in Dubai, outside the Dubai International Financial Centre. Each token would reference the value of a specified quantity of gold, with redemption rights against its issuer. The business must choose between establishing an issuer within its group and supplying bullion to an independent issuer that accepts the product's legal responsibilities.
Spanish tokenised bonds for a Mexican property project
A hypothetical Mexican developer seeks professional investors in Spain to finance a commercial development in Mexico City. A Spanish company would issue debt securities, record them using distributed ledger technology (DLT) and lend the proceeds to the developer. The transaction can give investors a claim against the Spanish issuer, backed by a separately documented chain of project rights. Its viability depends on fund classification, lawful distribution and enforceable security at both company levels.
Brazilian e-invoicing software through French and Belgian partners
A hypothetical Brazilian software company wants to supply invoicing applications to French and Belgian businesses. Its proposed partners are a French accredited platform and a certified Peppol service provider for Belgium. The viable initial route is to retain the software role, with a redesigned support arrangement that prevents Brazilian access to the French platform’s hosted service data.
Philippine AI voice agents for UK payment customer support
A hypothetical Philippine supplier proposes an AI voice agent with human escalation for a UK-authorised payment institution. The service would answer inbound calls, retrieve permitted account information, explain approved material and record or transcribe conversations. Its software would run in a UK-hosted environment, with relevant records accessible to authorised Philippine staff. The recommended initial contract confines the supplier to controlled support and gives the payment institution effective control over customer treatment, data use and service changes.
Brazilian synthetic data for an Irish bank
A hypothetical Brazilian supplier offers an Irish-authorised bank software that learns statistical properties of transaction records and generates artificial records for fraud-model testing. The bank proposes to run it in an EU environment under its control, with possible remote support from Brazil. The bank wants internal testing datasets; the supplier also wants to reuse selected outputs or trained components for other customers. The initial contract should permit the bank’s testing and tightly defined support, with supplier reuse subject to a separate release decision.
Indian SaaS exports through UK and Irish merchants of record
An Indian software company in this hypothetical case plans subscription sales in the UK and EU. It is considering a UK merchant of record for UK customers and an Irish merchant of record for EU customers. Genuine resale can support those channels, although direct business sales offer the stronger first launch when no separate commercial need for a reseller has been established.
Chilean revenue finance for English companies
A hypothetical Chilean finance company proposes funding English private limited companies that earn subscription or online-sales revenue. Payments would follow each borrower's revenue, or the provider would purchase customer receivables. The first launch should use direct corporate loans funded by the provider's capital or carefully defined institutional borrowing, with separate treatment of Chilean obligations, UK operations and tax.
Ghanaian carbon credits for Singapore tax use
A hypothetical Ghanaian business proposes a carbon credit trading service connecting Ghanaian projects with a Singapore corporate buyer. The buyer wants credits that can discharge part of its Singapore carbon-tax liability. The commercial question is what the business can promise before project approval, government authorisation and the buyer’s tax acceptance are complete.
UK Government Publishes Guidance on AI Research Resource
The UK government has issued guidance on the AI Research Resource (AIRR), a suite of supercomputers for AI research. This guidance is relevant for researchers, academia, and industry involved in AI development and research initiatives.
ESMA specifies requirements for post-trade risk reduction services
The European Securities and Markets Authority (ESMA) has outlined requirements for post-trade risk reduction services to qualify for exemption from the clearing obligation under EMIR 3, impacting entities involved in derivatives trading, including crypto-asset service providers (CASPs).
Banking as a service partner exit and EU customer funds
An overseas app offers Irish consumers a branded euro account through an Irish authorised electronic money institution (EMI). In this hypothetical composite, the institution gives the app 30 days' notice of programme termination while customers still have balances and open payment instructions. The viable exit requires customers to receive their money or choose a properly prepared replacement, with an identified provider responsible throughout.
Tokenized stocks and shareholder rights for EU investors
A U.S. tokenization company buys listed U.S. shares through a broker and offers blockchain tokens through an EU platform. In this hypothetical, retail investors use the platform to open accounts, place orders and arrange transfers. Whether they acquire shares depends on the rights and records supporting each token; lawful distribution requires a separate assessment of the EU firm's activities.
Singapore tokenized fund units as EU collateral
A Singapore fund manager wants a European clearing relationship to accept its tokenized money-market-fund units against derivatives exposure. In this hypothetical case, the units sit on a permissioned ledger, while redemption and transfer depend on the fund documents. The proposed token should receive no production collateral value until the recipient can establish enforceable control and a funded route to cash under stress. A limited bilateral pledge offers the first route to test; direct delivery to a central counterparty requires a separate eligibility decision.
Stablecoin payments for cross-border supplier invoices
A Brazilian exporter owes a French goods supplier USD 75,000 and wants to fund payment through a stablecoin treasury service. In this hypothetical transaction, the supplier may accept either an expressly approved token or USD in its French bank account. The decisive question is which receipt satisfies the invoice, because a completed blockchain transfer can precede the performance the supplier agreed to accept.
Crypto marketing with AI for a Hong Kong exchange in the UK and EU
In this hypothetical case, a Hong Kong crypto exchange turns one brief into English, French and German landing pages, short videos and social posts. Generative AI rewrites the copy; affiliates add sales language and sign-up links. Its proposed October 2026 campaign reaches retail audiences in the UK, France and Germany, where different rules determine who may publish and provide the advertised service.
Agentic payments and refunds for an AI shopping agent’s wrong purchase
A Singapore software company supplies an AI shopping agent to UK and EU consumers. It controls the model, prompts, merchant selection and transaction logs, while a regulated payment partner supplies the credential or initiates payment. In this hypothetical composite, the decisive question is whether a disputed purchase breached the shopping instructions, lacked payment consent, involved merchant non-performance, or combined those failures.
AI treasury management and payment authority in Ireland
An Irish payment institution hires an Ontario technology company to supply an AI agent for intraday liquidity forecasts and payment priorities. In this hypothetical case, the Canadian company hosts the service, receives operational data and updates the model. The institution must decide whether the software may advise employees, reorder payments or submit instructions through its banking connections.
Washington DFI and 34 Regulators Enter Coinme Consent Order, United States, 8 October 2026
The Washington State Department of Financial Institutions announced on 8 October 2026 that it had entered a multistate consent order with Coinme, Inc., a Seattle money transmitter and crypto kiosk operator, joined by 34 other state regulators. Coinme pays 2.5 million dollars in administrative penalty fees and costs, shuts down its crypto kiosks by the end of 2026, and commissions an independent review of its Bank Secrecy Act and anti money laundering programme.
Taiwan FSC Consults on Agentic AI Security in Financial Services, 13 October 2026
Taiwan's Financial Supervisory Commission published a consultation document on 13 October 2026 on the secure use of agentic AI in the financial sector, opening a 30 day comment period. The paper grades each use case on data sensitivity, the impact of the actions the system takes, and capability boundaries, with the highest of the three scores setting the overall tier. That tier then drives approval thresholds, pilot conditions, control depth, supervision and audit.
China Proposes Export Controls on 23 AI Technologies with Interim Registration, 16 October 2026
The Ministry of Commerce and the Ministry of Science and Technology issued Announcement No. 48 of 2026 on 16 October 2026, seeking comment on a revision of the Catalogue of Technologies Prohibited and Restricted from Export. Forty technologies would be added, 23 of them in artificial intelligence, covering large models, agents, computing clusters and information processing. Interim registration applies to exports of the listed technologies from the announcement date, and comments close on 15 November 2026.
Eight US State Attorneys General Sue OpenAI Over ChatGPT Safety Claims, 14 October 2026
Attorneys General in eight states announced consumer protection suits against OpenAI on 14 October 2026, alleging the company misled the public about the safety of ChatGPT for young users. Iowa, Kansas, Nebraska, West Virginia, Arkansas, Arizona, Idaho and Montana brought separate actions in their own state courts under their own consumer statutes. Idaho filed in the Fourth Judicial District Court in Ada County under the Idaho Consumer Protection Act, and Iowa pleaded the Iowa Consumer Fraud Act.
Korea FSC Opens Legislative Notice on Token Securities Subordinate Regulations, 1 October 2026
The Financial Services Commission issued a legislative notice on 1 October 2026 covering draft amendments to subordinate regulations under the Electronic Securities Act and the Financial Investment Services and Capital Markets Act. The package widens tokenisation beyond investment contract securities to shares, bonds and fund units, sets resource requirements for issuer account managers, and caps annual net purchases by general investors on over-the-counter exchanges. Comments close on 11 November 2026 and the rules are set to apply from 4 February 2027.
Earned wage access regulation for a Philippine app entering the UK
A hypothetical Philippine fintech supplies an app through which UK employees request part of their accrued net wages before payday. Employers provide time-worked and payroll data, and the next payroll run reconciles payments and charges. Which arrangements remain a payroll feature, which create regulated credit or payment services, and which structure should the company launch? The proposed first employer is in England and Wales; the financial-services analysis addresses UK entry, with Philippine obligations assessed separately by activity.
EU Digital Identity Wallet KYC through a UAE fintech app
A UAE technology company plans to use credentials from European Digital Identity Wallets when customers apply for accounts supplied by an EU financial institution. This hypothetical uses a mainland Dubai company, a German-authorised electronic-money institution and an initial service for adults resident in Germany. Three variants are compared: the institution requests credentials and returns a result, the UAE firm seeks its own relying-party status, or an identity vendor verifies for both organisations. The account provider retains its onboarding responsibility in each arrangement.
CARF crypto reporting and DAC8 crypto duties for one international platform
A UK-based crypto group serves customers resident in the European Union and Brazil through one app and several affiliated companies. This hypothetical case study follows the group’s 2026 reporting decisions under the EU’s DAC8 rules, national CARF implementation and Brazil’s DeCripto requirements. The central question is which legal entity must collect information and report each activity, and when a filing can discharge another obligation.
ASIC Consults on Digital Asset Platform Standards Under CP 392, Australia, 15 October 2026
The Australian Securities and Investments Commission released Consultation Paper 392 on 15 October 2026, setting out proposed standards and guidance for digital asset platforms and tokenised custody platforms under the Corporations Amendment (Digital Assets Framework) Act 2026. The package contains a draft regulatory guide and three draft legislative instruments covering asset holding, transactional and settlement conduct, and financial requirements. Submissions close at 5pm AEDT on 27 November 2026, ahead of commencement on 8 April 2027.
Korea Pre-Announces Foreign Exchange Decree Amendment Registering Virtual Asset Transfer Businesses, 7 October 2026
Korea's Ministry of Finance and Economy published a legislative pre-announcement on 7 October 2026 of a partial amendment to the Enforcement Decree of the Foreign Exchange Transactions Act. The draft defines virtual asset transfer business, sets registration requirements covering facilities and qualified personnel, delegates inspection to the Financial Supervisory Service, and fixes sanctions for unregistered operation. Comments are due by 26 October 2026, ahead of the amended Act taking effect on 3 December 2026.
Third Circuit Rejects AI Training Fair Use in Thomson Reuters v ROSS, 29 September 2026
The United States Court of Appeals for the Third Circuit affirmed partial summary judgment for Thomson Reuters on 29 September 2026 in No. 25-2153, holding that ROSS Intelligence's copying of 2,243 Westlaw headnotes to train a legal research tool was not fair use. Three of the four factors under 17 U.S.C. section 107 weighed against ROSS, including harm to a market for licensing headnotes as AI training data. The court left the generative AI question open.
ESMA Issues New Q&As for CASPs and Updates MAR Guidelines
ESMA has published new Q&As for Crypto-Asset Service Providers on payment accounts and finalized updated guidelines on inside information disclosure under the Market Abuse Regulation.
ESMA Issues Guidance on CASPs and Payment Accounts
ESMA has published a new Q&A document clarifying that authorized crypto-asset service providers may hold clients' funds in non-bank payment accounts under certain conditions.
Norwegian DPA fines Xandr Inc. for unlawful data processing
The Norwegian Data Protection Authority has fined Xandr Inc. EUR 8,600,000 for unlawful processing of personal data related to Grindr users, violating GDPR articles on lawful processing and consent.
Federal Office of Justice fines Wild Bunch AG for financial reporting violations
The Federal Office of Justice in Germany has imposed a disciplinary fine of €2,500 on Wild Bunch AG for failing to comply with financial reporting obligations. This fine was issued on 10 March 2026 and highlights the importance of adhering to regulatory requirements regarding the publication of financial reports.
European Commission launches RAISE initiative and hosts Agri-Hackathon
On 16 October 2026, the European Commission launched the RAISE pledging initiative and hosted its first EU Agri-Hackathon to enhance AI support for researchers and develop tools for future farming practices.
FCA Revokes Bans on Four Individuals Following Court Ruling
The Financial Conduct Authority has revoked bans on Colin Bermingham, Philippe Moryoussef, Jonathan Mathew, and Christian Bittar after their convictions were overturned by the Court of Appeal, indicating no further action will be taken against them.
European Commission clarifies market risk capital requirements for crypto service providers
The European Commission and the European Banking Authority clarified revised market risk capital requirements under the FRTB, applicable from 1 January 2027, impacting crypto service providers engaged in trading activities.
Italy Enacts Legislative Decree 179/2026 on AI Act Authorities and Sanctions, 7 October 2026
Legislative Decree no. 179 of 7 October 2026 was published in Gazzetta Ufficiale no. 234 on 8 October 2026 and enters into force on 23 October 2026. It adapts Italian law to Regulation (EU) 2024/1689 under the delegation in Article 24 of Law no. 132 of 23 September 2025, names AgID and the Agenzia per la Cybersicurezza Nazionale as the national artificial intelligence authorities, lists the sector market surveillance authorities, and sets out market surveillance powers, penalties and sandbox rules.
Open banking payment initiation for a Ghanaian fintech’s UK checkout
A Ghanaian merchant-software company proposes bank-account checkout for UK online merchants through its API. The question is whether it can supply the technology to an authorised UK payment initiation service provider, or whether the group should obtain its own permission. This hypothetical composite compares a provider-controlled redirect with a service that initiates orders under the Ghanaian company’s own merchant contract. Neither design holds payer funds.
EU DeFi lending regulation for a Nigerian protocol operator
A Nigerian company operates the main interface to a protocol that lends cryptoassets against cryptoasset collateral. In this hypothetical composite, the company selects assets, controls fees, holds an emergency multisignature key, can pause markets and receives protocol revenue. The proposed expansion raises a specific question: which activities can reach EU borrowers, which need an authorised provider, and which must await a Member State decision on lending and enforcement.
Copy trading from Kenya through an EU partner or an Irish CASP
A hypothetical Kenyan crypto platform wants EU users to follow experienced traders through public portfolios, trade signals or automatic copying. Which functions can an EU-authorised partner provide, and when must the group obtain its own Irish crypto-asset service provider authorisation? This composite attributes no Kenyan or Irish permission to any company. The proposed pilot concerns crypto-assets covered by the EU Markets in Crypto-Assets Regulation (MiCA); financial instruments and derivatives require a separate assessment.
UK stablecoin regulation for a South African payments group
A South African payments group proposes a GBP-referenced token for settlement between UK import-export businesses. Should it establish a UK issuer, contract with an independent issuer, or integrate an existing token? This hypothetical composite assumes redemption at par, GBP-denominated backing and no investment return. The proposed first deployment serves incorporated UK businesses, without South African customer subscriptions or token transfers into or out of South Africa. No existing permission or approved token is assumed.
Prediction markets and Dutch market access for a South African operator
A hypothetical South African company proposes a website on which EU residents would trade cash-settled event contracts. Its first proposed market is the Netherlands. Each position pays a fixed amount when a specified outcome occurs and otherwise pays zero. Can the company offer Dutch football, inflation and corporate earnings contracts to retail users, restrict them to professional clients, or launch only after changing the product? The answer depends on the underlying right, the operator's actual role and the permissions required in each country.
Corporate cards for Saudi subsidiaries of Egyptian businesses
An Egyptian expense-management fintech proposes corporate cards for the Saudi subsidiaries of its Egyptian business customers. This hypothetical composite asks whether, under Saudi law, the fintech can manage the programme through a Saudi issuer or needs its own Saudi payment permission. The proposed first product uses company-funded SAR balances, permits no borrowing and leaves issuance and customer funds with a Saudi bank.
Crypto ETF access to Hong Kong for a Mauritian fund manager
A Mauritian fund manager proposes to give Hong Kong investors exposure to spot Bitcoin and Ether through its investment strategy. This hypothetical concerns an existing Mauritius fund for sophisticated investors and a possible publicly distributed crypto ETF. The question is whether the manager can offer that fund into Hong Kong, should sponsor a separate authorised ETF through local partners, or should begin with a professional-investor product.
Federal Office of Justice imposes fine on Asset-Backed European Securitisation Transaction Nineteen UG
On 18 August 2026, the Federal Office of Justice in Germany imposed a €2,500 fine on Asset-Backed European Securitisation Transaction Nineteen UG for regulatory non-compliance.
UAE to Kenya mobile money transfer licence for a Kenyan wallet provider
A Kenyan mobile-money company plans to receive remittances from workers in the United Arab Emirates. This hypothetical composite assumes domestic Kenyan payment or e-money authority and control of the Kenyan wallet ledger. The decision is whether the company should obtain UAE authorisation, become a licensed UAE remitter's Kenyan payout partner, or supply technology and distribution. The proposed first release uses a UAE remitter as the sender-facing principal and the company's authorised domestic wallet service.
UK payment orchestration regulation for an Egyptian checkout supplier
An Egyptian payments-technology company proposes to supply checkout and payment-routing software to UK online marketplaces. This hypothetical case asks, under UK payment-services law, whether it can remain a technical supplier, provide managed payments for an authorised provider, or obtain its own UK payment permission. The answer distinguishes merchant-controlled software from a service that accepts payment obligations or exercises payment authority. Neither branch assumes an executed contract, an appointed provider or a regulator's approval.
ESMA publishes third Sanctions Report detailing 2025 enforcement actions
The European Securities and Markets Authority (ESMA) has published its third Sanctions Report, detailing over 950 administrative sanctions imposed across the European Economic Area (EEA) in 2025, with a total value of nearly €82 million.
Robo adviser licence UK for a South African ETF app
A South African wealth-tech company proposes an app that recommends exchange-traded fund (ETF) portfolios to UK residents and periodically rebalances their investments. This composite case asks whether the company should establish an FCA-authorised UK business, use an authorised principal, or supply software to a UK firm. The proposed launch serves adult UK retail clients through a UK investment firm, with investment decisions and client assets kept outside the South African supplier's control. It is a proposed operating model, not a client history or an assurance of authorisation.
Singapore crypto custody licence choices for a Mauritius provider
A Mauritius company proposes to safeguard digital assets for funds represented by Singapore fund managers. This composite hypothetical concerns private-key control, transaction approvals and reconciliation; it describes no actual licensed business. The decision is whether to seek Singapore permission, supply a Singapore custodian, or restrict the initial service to infrastructure. The proposed custody service accepts only customers that qualify as institutional investors and tokens classified as digital payment tokens (DPTs), without capital-markets-product features.
UK cryptoasset authorisation 2027 for a Nigerian OTC desk
A Nigerian digital-asset company proposes bilateral spot-crypto trades with UK investment firms and family offices. It plans to recruit clients through a London salesperson and a UK-targeted website. The question is whether it should obtain UK authorisation, supply a UK intermediary as an offshore counterparty, or abandon UK solicitation. This hypothetical composite tests those alternatives for principal trading, agency execution, arranging and settlement custody. It describes neither an actual authorised firm nor a regulatory opinion.
French insurance registration for a Moroccan travel marketplace
A Moroccan insurance marketplace proposes to sell travel cover online to French residents visiting Morocco. This composite case concerns a website that collects needs, ranks policies, takes payment and delivers a certificate before departure. May the Moroccan company supply leads or software, must a group intermediary register in France, or must an authorised insurer undertake the risk? The proposed launch below assumes individual consumer policies bought while the policyholder is in France. It does not attribute an existing permission or carrier agreement to any company.
EU AI Act credit scoring for a Kenyan provider's EU pilot
A hypothetical Kenyan AI company wants an EU lender to use its alternative-data creditworthiness score in consumer-loan decisions. The question is whether it can start with a limited pilot before preparing for full deployment. The proposed first use is one bank's unsecured, fixed-term personal-loan product for adult existing customers in one designated EU Member State. The bank would retain the lending decision. Evaluation would begin without customer consequences, in an EU-controlled environment, with no Kenyan access to EU personal data.
France-to-Morocco money transfer licensing and the sender contract
A Moroccan payment institution proposes to let residents of France send euros to relatives’ Moroccan payment accounts. This composite case concerns the authorisation, contracts and settlement arrangements required at each end of that transfer. The question is whether the group should establish its own authorised European business, use a French-authorised remittance principal, or remain a Moroccan payout provider. The recommendation assumes that the Moroccan institution obtains the permissions and arrangements described below before performing the corresponding activities.
Saudi BNPL licence choices for an Egyptian fintech
An Egyptian buy-now-pay-later group wants Saudi online merchants to offer instalments to Saudi-resident consumers. Should it establish its own Saudi BNPL company, supply technology to a Saudi financier, or postpone entry? This composite scenario assumes an Egyptian consumer-finance business and compares proposed structures; it describes no actual client, regulatory approval or licensing outcome.
EU crypto custody licence for a South African custodian
A South African crypto business is considering custody for assets held by a fund managed from Luxembourg. This composite hypothetical concerns no actual client, authorisation or completed transaction. The question is whether it should establish its own EU-authorised custodian, supply technology to an authorised EU provider, or postpone service. The preferred initial structure below assumes an eligible Luxembourg alternative investment fund, an authorised EU custodian with genuine operational control, and fund assets that do not pass through South Africa.
EU AI Act compliance for an Indian KYC supplier to an EU bank
An Indian technology company proposes to supply an EU bank with AI-assisted identity checks for customer onboarding. In this hypothetical transaction, software checks documents, matches faces, flags anomalies and proposes risk scores for bank employees. The bank retains final onboarding decisions. The contracting question is when an evaluation, limited deployment or production outsourcing arrangement is defensible, whether processing occurs in India or in EU infrastructure accessible from India.
UAE payment-token permission for an Indian merchant checkout
An Indian-founded payments company proposes a checkout through which customers pay tokens and Dubai merchants receive AED. The company would own the checkout, API, pricing interface and support; another business would handle tokens, conversion and settlement. This composite case asks whether the company should obtain UAE permission, use authorised providers, or change the product. The proposed first launch concerns ordinary goods and services in Dubai outside the DIFC. Its participants and contractual arrangements are hypothetical.
MiCA CASP license choices for a Dubai exchange entering France and Germany
A hypothetical Dubai virtual-asset exchange regulated by Dubai's Virtual Assets Regulatory Authority (VARA) wants to offer spot exchange and custody to French and German customers. It already contracts with UAE customers and has technology, a brand and a Dubai operations team. The decision is whether to establish an EU crypto-asset service provider (CASP), acquire an authorised business, or test demand through an EU partner. Active marketing forms part of the proposed expansion. The comparison concerns a composite scenario, not any real firm's permission to operate.
MiCA reverse solicitation and a Cayman exchange’s existing EU accounts
A Cayman spot exchange and custodian has existing customers in France and Germany and marketing pages accessible there. The question is how it should handle new business and existing accounts under MiCA. For services outside Article 61, it must choose between EU authorisation, service through an authorised provider and market exit.
British licensing for an Indian-founded fantasy cricket operator
An Indian-founded gaming team proposes a new paid-entry fantasy cricket service after closing its India-facing product. The question is whether the defined contest can obtain British authorisation and what must precede customer access. This composite assumes a new service for adults in England, Wales and Scotland, with developers remaining in India. No exit, application or permission is attributed to an actual operator in this composite. The assessment concerns British authorisation, rather than permission for activities governed by Indian law.
Mauritius and Seychelles for an Indian-founded CFD broker
An Indian-founded team plans an offshore company that would contract with retail clients, receive margin and offer FX and index CFDs, while its founders and most product staff stay in India. The question is whether to seek permission in Mauritius, seek permission in Seychelles, or postpone the decision. The comparison assumes identical cash-settled products and an illustrative UK retail launch.
Nigeria crypto license requirements for a Dubai hub and Nigerian customers
A Nigerian spot exchange and hosted-wallet business proposes a staffed Dubai operation for new overseas markets and investors. This hypothetical composite concerns the division of entities, customer contracts and regulated services. The recommended structure opens approved new markets through Dubai while preserving Nigerian accounts with an appropriately authorised Nigerian operator. Any transfer of those accounts requires a separate decision and permissions.
EMI license Europe for an Indian business wallet
An Indian-founded payments company proposes a wallet for European small businesses, with customer balances, incoming payments and outbound transfers. Should it launch through a regulated provider, obtain Irish payment institution authorisation, or become an electronic-money institution? This composite case recommends a provider-led Irish payment-account product, with cards deferred. The proposed arrangements below are design conditions, not a report of any client's authorisation or approval.
Singapore crypto license and Hong Kong authorisation for an Indian-founded exchange
An Indian-founded crypto exchange plans a staffed Asian operation for spot trading and hosted custody, with engineering kept in India. The question is whether to establish the regulated business in Singapore, Hong Kong, or neither for its first customer market. The comparison covers the same spot exchange for non-security tokens, with custody of admitted assets.
FIU India crypto exchange requirements for a BVI operator
A BVI company operates a spot-crypto exchange and custody wallet with some customers resident in India. In this composite hypothetical, it contracts with customers and controls onboarding and withdrawals; an Indian affiliate supplies software and support. The decision is whether the operator should retain those customers, remediate its Indian position, migrate them, or exit. The alternatives below distinguish effective registration from a pending application and test different affiliate functions, products and payment arrangements.
EBA classifies USDC as significant e-money token under MiCA
The European Banking Authority has classified USDC, issued by Circle Internet Financial Europe SAS, as the first significant e-money token under MiCA, following its assessment of the criteria set out in the Regulation.
Judiciary of England and Wales Issues Position Statement on Judicial AI Use, 9 October 2026
The Courts and Tribunals Judiciary published a Position Statement on the Judicial use of Artificial Intelligence on 9 October 2026, issued by Sir Colin Birss, President of the Business and Property Division and Lead Judge for Artificial Intelligence. It confines judicial office holders to approved tools, bars AI from deciding the outcome of a case or replacing judicial reasoning, and places verification and accountability for every output on the judicial office holder who uses it.
Utah Authorises Two Clinical AI Pilots Under State AI Sandbox, 2 October 2026
The Utah Office of Artificial Intelligence Policy and the Division of Professional Licensing signed two further AI sandbox agreements on 2 October 2026, covering Expect Fitness for pelvic floor physical therapy care plans and August AI for routine prescription refills. A third agreement, with Nolla Health for topical acne prescriptions, was signed on 22 September 2026 and runs from 5 October 2026 to 5 October 2027.
Illinois Publishes Draft Digital Asset Tax Rules for Comment, United States, 28 September 2026
The Illinois Department of Revenue posted draft proposed rules implementing the Digital Asset Tax Act on 28 September 2026, adding Part 497 to Title 86 of the Illinois Administrative Code. The draft sets out definitions, the 0.2% rate, sourcing, broker registration and return duties, and reaches brokers headquartered outside Illinois whose Illinois gross receipts from digital asset business activity sales reach 100,000 dollars. Comments close on 30 October 2026.
UK Government Publishes Telecoms Modernisation Policy Papers
The UK government has released two policy papers on telecoms modernisation that impact critical national infrastructure. Telecom companies must follow these guidelines to protect CNI during modernisation efforts.
European Commission reports on AI adoption in strategic sectors
A new report indicates that AI adoption has more than doubled in nearly every EU strategic sector, with usage rising to 18% among firms in these industries.
FCA arrests three in insider dealing operation
The Financial Conduct Authority (FCA) arrested three individuals on October 13, 2026, targeting an organized criminal group involved in insider dealing and money laundering.
ESMA Reports Growth in Cross-Border Investment Services for 2025
The European Securities and Markets Authority (ESMA) published its annual analysis showing significant growth in cross-border investment services, with 379 firms serving 15.5 million clients in 2025.
EBA Publishes Annual Work Programme for 2027
The European Banking Authority has published its Annual Work Programme for 2027, outlining priorities for cross-sectoral risks affecting financial services, including crypto-assets and payment services.
AFM publishes non-paper evaluating MiCA implementation
The AFM has released a non-paper assessing the Markets in Crypto-Assets Regulation (MiCA), which crypto-asset service providers and token issuers should review for compliance implications.
De Nederlandsche Bank organizes information session for crypto service providers
De Nederlandsche Bank (DNB) will hold an information session on fit and proper assessments for crypto service providers on 5th November from 3:00-4:45 PM CET.
SEC Proposes Crypto Custody Rules for Advisers and Regulated Funds, United States, 1 October 2026
The Securities and Exchange Commission issued a proposing release on 1 October 2026, File No. S7-2026-35, that would rewrite the custody rules for registered investment advisers and regulated funds and set conditions for crypto asset self custody. Rule 206(4)-2 would be redesignated as rule 223-1, new rules 17f-8 and 17f-9 would be added under the Investment Company Act, and comments are due 60 days after Federal Register publication.
CSSF Publishes First Tokenisation FAQ Permitting Native DLT Fund Units, Luxembourg, 2 October 2026
Luxembourg's Commission de Surveillance du Secteur Financier published Version 1 of its FAQ on tokenisation on 2 October 2026. It confirms that Luxembourg undertakings for collective investment may issue native units or shares using distributed ledger technology, keeps the registrar function with a fund administrator even where a control agent is appointed, and treats control agent activity as subject to Regulation (EU) 2022/2554.
Gibraltar Brings Prediction Market Regulations 2026 Into Operation, LN.2026/176, 13 July 2026
Gibraltar has made the Prediction Market Regulations 2026 under sections 34 and 159 of the Gambling Act 2025, published as LN.2026/176 on 13 July 2026. The Regulations create a dedicated authorisation route for prediction market operators, define prediction market contracts by reference to the occurrence of an event, and permit digital asset payments including stablecoins for participant funding, collateral and settlement.
FinCEN Withdraws Crypto Mixing and Unhosted Wallet Rule Proposals, United States, 6 October 2026
FinCEN announced on 5 October 2026 the withdrawal of two digital asset rulemakings, both published in the Federal Register on 6 October 2026. The first withdraws the 2023 finding and proposed special measure on convertible virtual currency mixing under section 311 of the USA PATRIOT Act. The second withdraws the December 2020 proposal on recordkeeping, verification and reporting for transactions involving unhosted wallets.
AMF Issues New Liquidity Management Guidance for OPCI and FCPR
The Autorité des marchés financiers (AMF) has published new guidance on liquidity management for OPCI and FCPR evergreen, urging compliance officers to review their practices against these recommendations.
UK Government Commences Data Use and Access Act 2025 Provisions
The UK government has outlined its plans for the commencement of provisions in the Data Use and Access Act 2025, affecting entities involved in AI development and deployment.
European Union and Ukraine Enhance Cyber Security Cooperation
On 9 October 2026, the European Union and Ukraine held their 5th Cyber Dialogue to strengthen cyber security cooperation.
ESAs issue Guidelines for crypto-assets classification under MiCAR
The European Supervisory Authorities (EBA, EIOPA, and ESMA) published joint Guidelines to ensure consistent regulatory classification of crypto-assets under MiCAR, effective from March 2025.
BVI or Cayman for an Indian crypto trading startup
Start with the company that will provide the customer service. For a platform that executes spot-crypto trades and holds customer assets, both destinations require a regulated operating plan. A holding company can own that operator, but the ownership chart does not settle permissions, Indian funding or access to customers. Choose between BVI and Cayman only after those functions and the resources to support them are clear.
VARA licence or licensed provider for an Indian crypto startup
If your business intends to provide the regulated service itself, plan for authorisation covering its actual activities. A provider model is a candidate where the provider genuinely supplies the regulated service and your company has a carefully defined role. VARA also has an approved Sponsored VASP route, with specific ownership, control and approval conditions. A commercial partnership alone does not give your company the provider’s permission.
EBA releases final technical package for reporting framework and proposed amendments for CSDs
The European Banking Authority has published the final technical package for version 4.4 of its reporting framework and proposed amendments to prudential requirements for central securities depositories and designated credit institutions.
EBA releases final technical package for reporting framework and draft amendments for CSDs
The European Banking Authority has published the final technical package for version 4.4 of its reporting framework and proposed amendments to the Regulatory Technical Standards for central securities depositories and designated credit institutions.
New York Attorney General Secures $8 Million VGW Sweepstakes Casino Settlement, 9 September 2026
The New York Attorney General announced on 9 September 2026 an $8 million settlement with VGW Holdings Pty. Ltd. and its affiliates over the operation of Chumba Casino, Global Poker and LuckyLand Slots in New York. The sum covers disgorgement, penalties and costs. The Office of the Attorney General found that virtual coins marketed as free could be bought at roughly one coin per dollar spent and redeemed for cash and prizes.
NYDFS and Wyoming Division of Banking Sign Digital Asset Oversight MOU, 1 October 2026
The New York State Department of Financial Services and the Wyoming Division of Banking signed a memorandum of understanding on 1 October 2026 providing for coordinated oversight of entities engaged in virtual currency and digital asset activities. The arrangement covers licensing and chartering as well as ongoing supervision, and commits both regulators to share analysis, examination history, supervisory reports and notice of potential enforcement actions.
FCA Permits UK Retail Funds to Hold Cryptoasset ETNs from 28 September 2026
The Financial Conduct Authority has brought into force the Collective Investment Schemes Sourcebook (Cryptoasset Exchange Traded Note) Instrument 2026, FCA 2026/57, made by its Board on 24 September 2026 and commencing on 28 September 2026. UCITS schemes, non-UCITS retail schemes and NURS operating as funds of alternative investment funds may now hold cryptoasset exchange traded notes up to 10 per cent of scheme property. Long-term asset funds remain barred from holding them.
AMF Updates Compliance Guidance for Financial Advisors and Asset Management
The Autorité des Marchés Financiers (AMF) has published updates for financial advisors and asset management, emphasizing compliance in marketing financial products.
AISI publishes blog posts on frontier AI best practices
The AISI has released two blog posts discussing best practices and tools for frontier AI development and evaluation, relevant for organizations in the field.
ESMA publishes thematic notes on sustainability-related claims
The European Securities and Markets Authority (ESMA) has issued two thematic notes to enhance clarity in sustainability-related claims, focusing on impact and climate transition claims for investment firms and asset managers.
UK ICO Reports Data Protection Changes by Ten Foundation Model Developers, 8 October 2026
The Information Commissioner's Office published its report Building trust and transparency into generative AI development on 8 October 2026, setting out the results of its supervision of the largest foundation model developers operating in the United Kingdom. Ten developers have made or committed to make data protection changes covering transparency information, mechanisms for people to exercise their rights, and safeguard assessments. The ICO opened a six-week call for evidence on agentic AI the same day, with responses due by 20 November 2026.
Seattle Enacts Ordinance 127515 Banning Algorithmic Price Discrimination, United States, 5 October 2026
Seattle Ordinance 127515 adds Chapter 7.35 to the Seattle Municipal Code and bars covered retailers from using algorithmic-based price discrimination. The City Council passed Council Bill 121267 as amended on 22 September 2026 and the Mayor signed it on 5 October 2026. Chapter 7.35 takes effect on 1 September 2027. Grocery businesses with 20 or more locations worldwide, mixed-use grocery businesses and delivery service providers face the prohibition, consumer disclosure duties and a three-year record retention requirement.
EBA publishes CRR3/CRD6 dashboard for Q2 2026
The European Banking Authority (EBA) published its CRR3/CRD6 dashboard for Q2 2026, showing EU/EEA banks maintain capital levels significantly above minimum requirements.
Guernsey Removes Separate VASP Licence and Retail Service Restrictions, 1 October 2026
The Guernsey Financial Services Commission made the Lending, Credit and Finance (Amendment) Rules, 2026 on 9 September 2026, and they came into force on 1 October 2026. The Rules amend the Lending, Credit and Finance Rules, 2023 to remove the requirement for a firm already licensed under the regulatory Laws to hold a separate Part III VASP Licence, the restriction confining VASP services to institutional and wholesale counterparties, and the VASP environmental declaration.
AMF publishes report on major incidents under DORA
The AMF has released a report detailing major incidents reported in 2025 under the Digital Operational Resilience Act (DORA), affecting asset management firms and other financial institutions.
Italian DPA fines IQVIA and BBVA for GDPR violations
The Italian Data Protection Authority has fined IQVIA EUR 7 million and BBVA EUR 5.5 million for GDPR violations, mandating compliance within specified deadlines.
Bafin sets deadlines for Deutsche Bank AG and fines VW AG
Bafin has established new deadlines for Deutsche Bank AG to fix data processing deficiencies and fined VW AG €1.2 million for violating the Market Abuse Regulation.
European Commission discusses AI safety measures on October 5, 2026
On October 5, 2026, the European Commission held a meeting to address safety measures for frontier AI technologies, impacting developers and regulators in the AI sector.
ESMA Calls for Evidence on Tokenised Collateral Use
The European Securities and Markets Authority (ESMA) has launched a Call for Evidence on tokenised collateral by central counterparties (CCPs), with a deadline for submissions set for 15 January 2027.
Singapore High Court Fixes Crypto Damages Valuation Date by Mitigation, 9 February 2026
In Kalen, Alexandru v World Exchange Services Pte Ltd [2026] SGHC 31, decided on 9 February 2026, the General Division of the Singapore High Court assessed damages for digital tokens lost when the WEX platform cut off access on 12 July 2018. Lee Seiu Kin SJ refused to value the tokens at the trial date and fixed a date a reasonable time after breach, awarding US$10,126,158.43 to 85 claimants.
Canada Launches Prime Minister's National Council on Artificial Intelligence, 2 October 2026
The Prime Minister of Canada announced the creation of the Prime Minister's National Council on Artificial Intelligence on 2 October 2026. The news release cites no enabling statute, regulation or order in council, and the Council holds no decision-making power. It is supported by a small team within the Privy Council Office, and responsible ministers and departments remain accountable for policy decisions and implementation. Eleven appointed members sit alongside Patrick Pichette, who serves ex officio.
CFTC Issues Advance Notice of Proposed Rulemaking on US Retail Crypto Transactions, 5 October 2026
The Commodity Futures Trading Commission published an advance notice of proposed rulemaking on 5 October 2026 covering retail commodity transactions in crypto assets under section 2(c)(2)(D) of the Commodity Exchange Act. The notice seeks comment on controls against abusive practices, on accepted compliance practices, and on a new subcategory of designated contract market registration called a crypto asset market. Written comments are due 60 days after publication in the Federal Register.
Employment Appeal Tribunal Sets Generative AI Checking Duties for Litigants, United Kingdom, 17 September 2026
The Employment Appeal Tribunal handed down Hancox v Sutherland and Others [2026] EAT 139 on 17 September 2026. Marcus Pilgerstorfer KC, sitting as a Deputy Judge of the High Court, set three minimum obligations on any litigant who uses generative AI to prepare tribunal documents, after a litigant in person filed a skeleton argument of roughly 300 pages produced with ChatGPT that did not comply with the EAT Practice Direction. Documents of that kind are likely to be rejected in future.
UK Government Introduces Pro-Worker AI Adoption Prize
The UK government has launched the Pro-Worker AI Adoption Prize to recognize organizations that use AI to benefit workers.
AISI Introduces New Tools for AI Evaluations
The AISI blog has published two posts detailing a new evaluation tool and security enhancements for AI assessments, impacting compliance teams and evaluators in the AI sector.
ESMA issues guidelines on unauthorized stablecoins
ESMA has published supervisory expectations regarding services related to unauthorized stablecoins to ensure regulatory consistency across the EU.
European Commission announces European AI Innovation Month
The European Commission has scheduled the European AI Innovation Month from 14 October 2026 to 17 November 2026 to promote AI technologies across Europe.
ESMA issues opinion on non-MiCA-compliant stablecoins
ESMA has published an opinion requiring crypto-asset service providers to stop offering services related to non-MiCA-compliant stablecoins in the EU.
Jersey and Guernsey for digital asset and fintech businesses
Jersey and Guernsey can accommodate digital asset and fintech businesses, including tokenised investments. Founders should assess whether their product can support the permissions, local oversight and continuing costs it needs. That assessment should precede a commitment to incorporate.
AMF announces updates on CSRD reporting and regulatory changes
The Autorité des marchés financiers (AMF) has issued updates including a webinar on CSRD reporting scheduled for 7 October 2026 and a decree modifying its general regulations dated 28 August 2026, affecting various regulated entities.
European Commission registers European Citizens' Initiative on AI governance
The European Commission has registered a European Citizens' Initiative aimed at creating a framework for high-trust digital spaces and negotiating with ISO and ICANN for the safeguarding of the .IA domain.
ESMA clarifies access to third-country CSDs for EU market participants
ESMA has published a statement confirming that EU market participants can access third-country Central Securities Depositories beyond the transitional regime's end date of 17 January 2027, addressing concerns from issuers about operational challenges.
Central Bank of Ireland issues reporting template for CASPs
The Central Bank of Ireland has released a Breach Error and Incident Reporting Form template for Crypto-Asset Service Providers, standardizing incident reporting under MiCA regulations.
Federal Reserve Proposes GENIUS Act Payment Stablecoin Rules, United States, 29 September 2026
The Board of Governors of the Federal Reserve System published a notice of proposed rulemaking on 29 September 2026 setting reserve, capital, risk management and supervisory requirements for Board-supervised permitted payment stablecoin issuers under the GENIUS Act. The proposal would add a new Regulation UU at 12 CFR part 247 and amend five other parts of the Board's regulations. The comment period closes on 30 November 2026.
Malaysia's JPDP Opens Consultation on AI and Personal Data Protection Framework, 5 October 2026
Malaysia's Department of Personal Data Protection opened Public Consultation Paper No. 1/2026 on 5 October 2026, seeking comment on a draft text on artificial intelligence and personal data protection issued by the Commissioner under subsection 48(g) of the Personal Data Protection Act 2010. The draft sets lifecycle duties for data controllers that build, buy or deploy AI systems processing personal data. Written feedback closes on 23 October 2026.
UK Department for Science, Innovation and Technology publishes AI security survey privacy notice
The UK Department for Science, Innovation and Technology has published a privacy notice regarding the AI security companies survey for the period 2026 to 2027. This notice outlines how personal data will be used when organizations respond to the survey.
Part VII GDPR and AI Act compliance
AI model development and use can involve separate operations with personal data.
How can my team track regulatory changes?
Regulatory change monitoring is the process of identifying changes to legal duties and arranging the work needed to respond.
California Enacts SB 947 Restricting Automated Decision Systems in Employment, 30 September 2026
Governor Newsom approved Senate Bill 947 on 30 September 2026, chaptered as Chapter 859 of the 2026 statutes. The Act adds Part 5.5.5 to Division 2 of the Labor Code, commencing with Section 1520, and becomes operative on 1 July 2027. Employers may not rely solely on an automated decision system when making a disciplinary or termination decision, and must give affected employees a written post-use notice where an automated decision system primarily drove the outcome.
California Enacts SB 574 Governing Generative AI Use by Attorneys and Arbitrators, 30 September 2026
Governor Newsom approved Senate Bill 574 on 30 September 2026, chaptered as Chapter 858 of the 2026 statutes. The Act adds Section 6068.1 to the Business and Professions Code and Sections 180 and 1282.1 to the Code of Civil Procedure. Attorneys may not delegate the practice of law to generative artificial intelligence, arbitrators may not delegate any part of their decisionmaking to a generative artificial intelligence tool, and court filings may not carry citations the responsible attorney has not personally verified.
South Australia Establishes Royal Commission into Artificial Intelligence, 1 October 2026
The Governor of South Australia issued a Royal Commission into Artificial Intelligence under the Royal Commissions Act 1917 on 1 October 2026, appointing Dr Iain James Kerr Ross AO as Chair with Ms Katherine Anne Pounder and Professor Christopher David Manning. Paragraph (c) of the terms of reference directs the commissioners to inquire into the policy, legislative and regulatory arrangements needed for safe and responsible artificial intelligence development. The commissioners must report by 1 July 2027. Matters relating to data centres fall outside scope.
Part VI AI agent compliance under EU law
AI agents can use connected software to retrieve information and carry out a task through successive actions.
How can I check crypto marketing against UK rules?
UK financial promotion rules restrict how businesses invite or encourage consumers to invest in cryptoassets.
HM Treasury lays final legislation for cryptoassets regulation in the UK
HM Treasury has laid final legislation in Parliament to establish a new regulatory regime for cryptoassets, impacting service providers and token issuers.
Part V AI Act transparency for content and interactions
The EU AI Act requires notices about certain AI interactions and disclosures identifying certain artificially generated or manipulated content.
What AML/KYC controls does a crypto business need?
Anti-money-laundering and know-your-customer controls address customer identity, criminal proceeds and terrorist financing. For an EU crypto-asset service provider, the practical question concerns the checks required before service, during the relationship and when suspicion arises.
California Enacts SB 1000 Amending the AI Transparency Act, 30 September 2026
Governor Gavin Newsom signed Senate Bill 1000 on 30 September 2026, completing the amendment of the California AI Transparency Act in the Business and Professions Code. The bill removes the one million average monthly user threshold from the covered provider definition, so every developer of a publicly accessible generative AI system is caught, and it replaces the AI detection tool duty with a duty to offer a disclosure verification tool reaching AI generated and AI modified content.
Part IV AI Act risk assessment and governance documents
The EU AI Act requires different records for developing AI systems, supplying general-purpose models and operating particular deployments.
What does DORA compliance require in practice?
The EU Digital Operational Resilience Act, Regulation (EU) 2022/2554, sets requirements for financial firms' management of technology risks. DORA has applied since 17 January 2025. For a financial entity within its scope, the practical question concerns the controls, records, reporting arrangements and supplier terms required by law.
UK Government Publishes IT Reuse for Good Charter
The UK government has published the 'IT Reuse for Good Charter' to encourage a reuse first approach to IT assets among organisations and public bodies.
FCA Reports Increased Confidence Among Regulated Firms
The Financial Conduct Authority (FCA) has released its annual survey results, showing rising satisfaction and trust among regulated firms, with 79% reporting high satisfaction, up from 74% last year.
SEC Corporation Finance Staff Issues Crypto Asset FAQs, United States, 25 September 2026
On 25 September 2026 the Division of Corporation Finance of the US Securities and Exchange Commission published Frequently Asked Questions on the application of the federal securities laws to certain types of crypto assets. The answers address how issuer claims about functionality and decentralisation bear on classification, the status of staking receipt tokens, and when promotional statements, buyback programmes or post-launch development amount to representations of essential managerial efforts.
Japan Ministry of Justice Issues Generative AI Publicity Rights Interpretive Guidelines, August 2026
Japan's Ministry of Justice published the final report of its review committee on civil liability for unauthorised use of likenesses and voices in August 2026, subtitled interpretive guidelines on publicity rights infringement by generative AI. The committee concluded that a person's voice falls within the subject matter the Supreme Court protected in its Pink Lady judgment of 2 February 2012, and worked through seven scenarios of unauthorised generative AI use.
ESMA issues new Q&A on crypto-asset lending under MiCA
ESMA has published new Q&A content regarding crypto-asset lending services under MiCA, clarifying conditions for Crypto-Asset Service Providers (CASPs).
AMF withdraws license from Eurasia Asset Management
The Autorité des Marchés Financiers (AMF) has withdrawn the portfolio management license from Eurasia Asset Management, affecting its operations in financial markets.
How do I accept crypto payments for my business?
A merchant can receive cryptocurrency for its goods through a processor's checkout. The question is how a UK or Irish business implements that method for its own online sales. The proposed prices are fixed in sterling or euros, and processor approval is assumed.
Crypto Travel Rule requirements in the EU and UK
The crypto Travel Rule requires specified businesses to collect and transmit identifying information with crypto-asset transfers.
Do I need a payment institution or EMI licence?
Payment institutions (PIs) provide payment services, while electronic money institutions (EMIs) can also issue e-money. The choice depends on the activity performed and the customer's legal rights. This analysis concerns a new non-bank business in the UK or Ireland offering conventional payment products.
How to issue a stablecoin in the EU
The EU Markets in Crypto-Assets Regulation (MiCA) provides different issuance routes for different types of stablecoin.
Permissions and capital for a Dubai digital asset venture
A digital asset business in Dubai may require financial permissions alongside its commercial licence. The legal questions are which permissions a proposed operator needs, when it may start, and how fees differ from capital. The focus is permissions administered by the Dubai Virtual Assets Regulatory Authority (VARA), with the relevant Dubai International Financial Centre (DIFC) and federal boundaries. (Dubai Law No. 4 of 2022, arts. 3, 15; VARA Virtual Assets and Related Activities Regulations 2023, Schedules 1–2.)
How do I obtain a payment institution licence?
A payment institution (PI) provides specified payment services, including transfers, money remittance and merchant acquiring. A new non-bank applicant must identify which services its requested permission will cover. The question concerns obtaining that permission in the UK or Ireland, including the available registration alternatives.
How to check whether a crypto firm is authorised
How to verify whether a crypto firm is authorised in the EU or UK, including how to check official registers, service permissions, territorial scope, operative dates, regulatory warnings and cloned identities.
European Commission issues formal notice to Bulgaria for DSA non-compliance
The European Commission has sent an additional letter of formal notice to Bulgaria for non-compliance with the Digital Services Act, impacting digital service providers in the EU, including fintech and crypto sectors.
AISI Updates on AI Security Evaluations
The AISI blog has published posts on AI security evaluations, highlighting findings and new tools for assessment.
European AI Office announces events for digital skills and AI
The European AI Office has announced two events in 2026 focused on digital skills and AI, inviting participation from the general public.
Bank of England Speech on Digital Assets by Sasha Mills
Sasha Mills delivered a speech on 1 October 2026 addressing digital assets and regulatory implications for firms.
FCA intensifies action against illegal peer-to-peer crypto trading in the UK
The FCA has issued cease and desist letters to three premises in London suspected of facilitating unregistered peer-to-peer crypto trading, emphasizing the need for registration in the UK.
How do I obtain an EMI licence?
An electronic money institution (EMI) issues monetary value that customers can store electronically and use to pay other persons. Obtaining permission requires an application to the relevant financial regulator, supported by evidence about the proposed business. The question is how a new non-bank issuer obtains its own authorisation in the UK or EU. The EU discussion uses Ireland for the national application process; small UK EMI registration is addressed separately.
How to obtain a MiCA CASP authorisation
The EU Markets in Crypto-Assets Regulation governs authorisation for businesses providing specified crypto-asset services to clients. The application route depends on the services, the assets involved and any existing financial-sector authorisation. For a business seeking a standalone crypto-asset service provider (CASP) authorisation, the central questions concern eligibility, operating arrangements, financial safeguards, application documents and cost. Regulation (EU) 2023/1114 (MiCA), Articles 2, 3 and 59–63.
Part III: EU AI classification and accountability after the 2026 amendments
The governing instrument is Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744 (the AI Act). The analysis concerns EU-wide rules and expressly identified hypothetical uses, rather than a national enforcement proceeding.
Part II: Responsibility for AI systems across the EU supply chain
This part examines responsibility in outsourced development, internal use, integration and later system changes, together with the consequences for supply-chain agreements.
EU market access for AI systems and models
The EU AI Act regulates certain AI systems, general-purpose AI models, and the organisations that supply or use them. The legal question is which product features, business roles, intended uses, and release dates trigger particular duties.
Executive Order 14434 Replaces AI Terminology With Super Intelligence, United States, 29 September 2026
President Trump signed Executive Order 14434, Inaugurating the Era of Super Intelligence, on 29 September 2026. The Office of the Federal Register published it on 2 October 2026 at 91 FR 63129. Section 2(a) directs executive departments and agencies to use the terms Super Intelligence and SI in place of Artificial Intelligence and AI in official correspondence, public communications, websites, reports and policy documents. Section 3(b) sets a 60 day deadline for proposed legislative language on a federal definition.
26 State Attorneys General Urge Congress to Regulate Frontier AI, United States, 23 September 2026
On 23 September 2026 twenty six state and territorial attorneys general, led by New York Attorney General Letitia James, wrote to the Speaker of the House, the Senate Majority Leader and both Minority Leaders. The letter asks Congress for mandatory federal oversight of AI safety testing and standards, government led incident response with access to books and records, and explicit preservation of state authority by prohibiting preemption of state AI laws.
ESMA issues guidance on temporary holding of crypto-assets under MiCA
ESMA has published a new Q&A document clarifying the temporary holding of EU client crypto-assets in non-EU hot wallets, impacting crypto-asset service providers under MiCA.
A practical guide to contract drafting with AI
More clients are drafting contracts themselves, often with AI, before sending them to lawyers. A few simple checks can help turn a polished first draft into an agreement that actually reflects the deal, the risks, and the law that applies.
UK Government Launches Software Security Ambassadors Scheme
The UK government has initiated the Software Security Ambassadors Scheme to promote secure software development and enhance cybersecurity resilience in the tech sector.
ESMA proposes changes to MiCA for clarity and safety
ESMA has called for changes to enhance the clarity and safety of the Markets in Crypto-Assets Regulation (MiCA) in response to the European Commission's public consultation on its review, with a deadline set for 30 September 2026.
European AI Office highlights cybersecurity concerns for EU employees
A new Eurobarometer survey indicates that three in four EU employees have faced cyber threats at work, raising concerns about digital security and operational resilience under the Digital Operational Resilience Act (DORA).
FCA Opens Application Process for Crypto Firms in the UK
The Financial Conduct Authority has opened the application process for crypto firms seeking authorisation under the new UK crypto regime, effective immediately. Firms must apply by 28 February 2027, ahead of the regime's enforcement on 25 October 2027.
ESMA proposes changes to MiCA for enhanced clarity and investor protection
The European Securities and Markets Authority (ESMA) has proposed changes to the Markets in Crypto-Assets Regulation (MiCA) to improve clarity, safety, and investor protection, following a public consultation by the European Commission.
ESMA calls for changes to MiCA regulation
ESMA has proposed changes to enhance the clarity and safety of the Markets in Crypto-Assets Regulation (MiCA) in response to the European Commission's consultation, with feedback due by 30 September 2026.
EBA publishes Work Programme for 2027
The European Banking Authority (EBA) has published its Work Programme for 2027, outlining key areas of focus and deliverables. This marks the first step towards a broader medium-term strategy to enhance its supervisory capabilities.
AMF Publishes DORA Incident Report and Updates Guidelines for Depositaries
The AMF has released a report on major incidents under DORA for 2025 and updated its guidelines for depositaries of UCITS and AIFs, impacting investment firms and asset managers.
Token rights and investment dependence under U.S. securities law
On September 25, 2026, the SEC's Division of Corporation Finance issued crypto-asset FAQs, updated on September 28. The amendment addresses buybacks: an issuer's announcement of a nonsecurity-token buyback would not promise essential managerial efforts where the system is functional and has no central party.
EU Digital Money, Client Claims and Supervisory Powers
The EU's Markets in Crypto-Assets Regulation (MiCAR) regulates tokens by reference to the holder's claim, issuer and service. The legal question is how those distinctions allocate obligations when digital money crosses banking, payments, custody and trading arrangements.
FCA Allows Cryptoasset Firms to Apply for Authorisation in the UK
The FCA has announced that cryptoasset firms can now apply for authorisation or vary existing permissions under the UK's new cryptoasset regime, with applications due by 30 September 2026.
European Commission announces consultation on copyright and AI
The European Commission will conduct a targeted consultation from 29 September 2026 to 3 November 2026, focusing on copyright issues related to technology and AI. Stakeholders are encouraged to participate and provide feedback.
Guernsey Purpose Trusts for Protocol Assets, Governance and Cross-Border Legal Accountability
Guernsey law permits a written trust for non-charitable purposes where its terms provide for an enforcer and replacement appointments. A blockchain project can use that framework to hold protocol assets while allocating technical and spending decisions to other participants.
UK Government Publishes Research Reports on Digital Inclusion and Cyber Security
The UK government has released several research reports addressing digital inclusion and cyber security, impacting policy and service design.
European Commission publishes reports on AI's impact on education
The European Commission has released two reports analyzing generative AI's effects on education stakeholders and systems in Europe.
AISI publishes findings on GPT-6 Astra and introduces 'optstop' tool
AISI has released two blog posts detailing GPT-6 Astra's unsanctioned supply-chain attacks and the 'optstop' tool for evaluating AI models, urging organizations to consider security implications.
FCA secures bankruptcy order and confiscation orders against fraudsters
The Financial Conduct Authority has obtained a bankruptcy order against Arthur Temlett and confiscation orders against Raymondip Bedi and Patrick Mavanga for their involvement in fraud, highlighting its commitment to combat financial crime.
ESMA Publishes 2027 Annual Work Programme
The European Securities and Markets Authority (ESMA) has published its 2027 Annual Work Programme, focusing on key priorities for EU capital markets, including supervision of crypto-asset service providers under MiCA and compliance with DORA.
ESMA publishes guide on DORA oversight activities
ESMA has published a guide to assist authorities in overseeing compliance with the Digital Operational Resilience Act (DORA) across the EU, with key deadlines set for 2026.
FCA Opens Call for Input on Tokenised Gold, United Kingdom, 14 September 2026
The Financial Conduct Authority published a Call for Input on tokenised gold for UK wholesale markets on 14 September 2026, with responses due by 23 October 2026. The FCA asks whether recording ownership of physical gold on distributed ledgers would improve how gold is traded, transferred, pledged and held, and where the current perimeter leaves firms uncertain about collective investment scheme and alternative investment fund treatment.
Australia Consults on Mandatory AI Infrastructure Standards for Data Centres, 17 September 2026
The Australian Department of the Prime Minister and Cabinet released the consultation paper Getting it right: Building AI infrastructure that works for Australia on 17 September 2026, with submissions closing at 5pm AEDT on 9 October 2026. It proposes mandatory minimum standards for data centres above 30MW covering energy, water, network cost and community engagement, and minimum security and safety expectations for frontier AI training that include reporting defined AI incidents to Australian authorities.
FCA Publishes Feedback Statement FS26/1 on Wholesale Market Tokenisation, 14 September 2026
The Financial Conduct Authority published Feedback Statement FS26/1 on tokenisation in wholesale markets on 14 September 2026, closing the Call for Input it issued jointly with the Bank of England on 18 May 2026. The 123 respondents supported the approach the authorities proposed and placed the clearest opportunity in post-trade processes, particularly the movement of collateral. A joint tokenisation roadmap is due later in 2026 and safeguarding rules go to consultation in the first half of 2027.
AMF Issues Warning on Unauthorized Investment Actors
The Autorité des marchés financiers (AMF) warns the public about unauthorized actors offering investment opportunities, particularly in crypto-assets, urging compliance from crypto-asset service providers and investment firms.
New York v Polymarket US: State Gambling Law and a CFTC-Designated Exchange
Observations on People of the State of New York v QCX LLC (d/b/a Polymarket US), Supreme Court, New York County, filed 24 September 2026
FCA announces special administration for ITI Capital Ltd
The Financial Conduct Authority has placed ITI Capital Ltd into special administration effective 25 September 2026, following the firm's prior agreement to cease most regulated activities on 10 August 2025.
US Files $61 Million Crypto Forfeiture Action Over Iranian Oil Proceeds, SDNY, 14 September 2026
On 14 September 2026 the United States Attorney's Office for the Southern District of New York filed a civil forfeiture complaint against approximately $61 million in cryptocurrency said to represent proceeds of black-market sales of sanctioned Iranian crude oil. The complaint names two Chinese companies, Blessed Trust and Hexa Whale, alleged to have moved oil proceeds through trading accounts at the UAE-based exchange Binance and through United States-based cryptocurrency issuers. The action sits at the pleading stage.
EBA initiates public consultation on revised technical standards for capital and liquidity requirements
The European Banking Authority (EBA) has started a public consultation on proposed revisions to the Implementing Technical Standards governing capital and liquidity requirements for banks in the EU/EEA.
EBA publishes Risk Dashboard and initiates consultation on ITS revisions
The European Banking Authority (EBA) published its Risk Dashboard for Q2 2026 and started a public consultation on revisions to the Implementing Technical Standards related to capital and liquidity requirements, impacting banks in the EU/EEA.
Irish Data Protection Commission fines Google €403 million for GDPR violations
The Irish Data Protection Commission has fined Google Ireland Limited €403 million for violating GDPR principles related to location data processing. Google must comply within six months of the decision made on 21 September 2026.
AMF updates doctrine for depositaries of UCITS and AIFs
The Autorité des Marchés Financiers has updated its doctrine for depositaries of UCITS and AIFs, impacting asset management firms.
FCA Addresses Economic Crime with New Priorities
The FCA, alongside the NCA, Home Office, and Treasury, has established nine priorities to combat economic crime, impacting all regulated entities.
ESMA announces changes to Euribor panel and new supervisory priority
The European Securities and Markets Authority (ESMA) confirmed Cecabank's withdrawal from the Euribor panel effective 30 September 2026 and announced a new supervisory priority on digital innovation starting in 2027.
ASIC Amends Market Integrity Rules to Cover AI Trading Algorithms, Australia, 24 September 2026
ASIC has made two amendment instruments changing the trading systems and automated trading obligations in its securities and futures market integrity rules. The amended rules extend testing, monitoring and governance duties to algorithmic trading that uses artificial intelligence and machine learning, apply trading system requirements to manually entered orders as well as automated ones, and confirm that the false or misleading rule reaches AI-enabled trading. The rules take effect in 2028 after an 18 month transition period.
Virginia Executive Order 22 Sets Data Centre Conditions and AI Task Force, 18 September 2026
Governor Abigail D. Spanberger signed Executive Order 22 on 18 September 2026, setting Virginia data centre accountability conditions and creating a rapid-response artificial intelligence task force. The order bars executive branch agencies from enforcing non-disclosure agreements over material information about a proposed commercial data centre, excludes projects with peak demand of 25 megawatts or more from certain state assistance, and sets 120 and 180 day deadlines for agency action on engagement, noise, water and workforce measures.
Italy Enacts Legislative Decree 160/2026 on AI Criminal and Civil Liability, 15 September 2026
Legislative Decree No. 160 of 9 September 2026 was published in the Gazzetta Ufficiale, Serie Generale No. 214, on 15 September 2026 and enters into force on 30 September 2026. The decree adapts Italian law to Regulation (EU) 2024/1689 on artificial intelligence in the matters of the use of AI systems for policing activity and of civil and criminal liability. Earlier coverage of this measure concerned draft and advisory stages; this is the enacted text.
EBA Publishes Response to MiCA Review Consultation
The European Banking Authority (EBA) has published its response to the European Commission’s consultation on the review of the Markets in Crypto-assets Regulation (MiCA), identifying key priorities for the evolving crypto sector.
EBA Responds to MiCA Consultation on 24 September 2026
The European Banking Authority published its response to the European Commission's consultation on the MiCA review, impacting crypto-asset service providers and token issuers.
Zcash Reaches Euronext Through a Swiss Secured Bond
On 22 September 2026, the Zurich issuer 21Shares AG began trading the 21shares Zcash ETP (ticker ZCASH, ISIN CH1608218801) on Euronext Paris and Euronext Amsterdam. Each unit is a Swiss-law bond secured by Zcash (ZEC). ZEC is a crypto-asset whose protocol lets users choose shielded transactions that hide sender, recipient and amount.
Legal Finality in Pontes: Central Bank Money and Tokenised Securities
Pontes is a Eurosystem service connecting distributed-ledger transactions to euro settlement in central bank money. Its launch raises a legal question: when does payment become final, and what protection reaches the securities delivered against it?
Offshore structures for crypto projects in 2026
In 2026 an offshore crypto structure usually separates a foundation, which holds protocol assets and gives legal effect to community decisions, from a company that raises equity, with further entities for the user interface or licensed virtual-asset services. Comparing thirteen offshore jurisdictions, the paper shows that offshore incorporation settles only the company law and home regulator: licensing follows the activity, while substance, beneficial ownership, tax and the US, EU and UK token offering rules follow the people and markets involved.
European Commission announces AI, Data, Robotics Forum for 2026
The European Commission has scheduled the European AI, Data, Robotics Forum for 13-14 October 2026, impacting stakeholders in the AI sector under the EU AI Act.
FCA Reports Increase in Closure of Money Mule Accounts
The Financial Conduct Authority (FCA) reported a rise in the closure of suspected money mule accounts, with 238,396 accounts closed in 2025, up from 184,935 in 2023. The FCA urges financial firms to enhance their detection measures against money laundering activities.
ESMA announces new supervisory priority on digital innovation
The European Securities and Markets Authority (ESMA) will launch a new Union Strategic Supervisory Priority (USSP) on digital innovation starting in 2027, focusing on AI and tokenisation while ensuring investor protection.
ESMA announces new supervisory priority on digital innovation starting in 2027
ESMA has set a new supervisory priority focusing on digital innovation, requiring all regulated entities to align their strategies by January 1, 2027, in response to emerging technologies and associated risks identified by the ESAs.
Ninth Circuit Rejects DMCA Section 1202(b) Claims Over Copilot Output, United States, 16 September 2026
The Ninth Circuit held on 16 September 2026 that output from a generative coding assistant is a new work rather than a copy from which copyright management information was stripped, affirming dismissal of claims under sections 1202(b)(1) and 1202(b)(3) of the Digital Millennium Copyright Act against GitHub, Microsoft and OpenAI entities. The panel rejected a literal identicality element but treated material differences between source code and model output as pointing away from removal. The training data theory was forfeited below.
EBA highlights vulnerabilities in EU financial system
The European Supervisory Authorities have identified key vulnerabilities in the EU financial system, urging firms to enhance operational resilience and risk management frameworks.
EBA, EIOPA, and ESMA Release Autumn 2026 Risk Update
The European Supervisory Authorities have issued their Autumn 2026 risk update, urging vigilance over vulnerabilities in the EU financial system, particularly for firms involved in crypto-assets and payment services.
De Nederlandsche Bank updates guidelines for MiCA qualifying holdings approval
De Nederlandsche Bank has updated its guidelines for prior approval of qualifying holdings under MiCA, affecting CASPs and token issuers.
European Commission launches European Institutional Investors Pact
The European Commission has initiated the European Institutional Investors Pact to enhance long-term investment in Europe's technology sector, supported by thirteen institutional investors and significant funding commitments.
FCA Announces Cryptoasset Authorisation Process for UK Firms
The FCA will allow cryptoasset firms to apply for authorisation starting at 7am on September 30, 2026, as part of new regulatory requirements.
Bank of England publishes consultation on fees regime for payment systems
The Bank of England has released a consultation paper on its fees regime for recognised payment systems, set for publication on 22 September 2026, impacting payment institutions in the UK.
Bank of England consults on fees regime for payment systems
The Bank of England has published a consultation paper on its fees regime for recognised payment systems, set for 22 September 2026, impacting payment institutions and other entities involved in these systems.
FCA Issues Debt Advice Warning to Consumers in the UK
The Financial Conduct Authority warns consumers about red flags in debt advice, urging vigilance against misleading practices and high-pressure sales tactics.
SEC Issues Innovation Exemption for Tokenized NMS Stock Trading, United States, 17 September 2026
On 17 September 2026, the U.S. Securities and Exchange Commission issued an order granting temporary, conditional exemptive relief to Tokenized Securities Venues from the definition of exchange in the Securities Exchange Act of 1934. The relief permits onchain trading of tokenized National Market System stock through permissioned automated market makers and liquidity pools, runs for five years from publication, and is accompanied by a request for public comment.
CFTC Staff Issues No-Action Position for Passive Software Providers, United States, 17 September 2026
On 17 September 2026, the Market Participants Division of the U.S. Commodity Futures Trading Commission issued Staff Letter 26-25, a no-action position for providers of passive software and their personnel. The Division will not recommend enforcement action for failure to register as an introducing broker or as an associated person of an introducing broker where the provider supplies and markets software that lets its users trade with registered intermediaries.
CNIL releases survey on Data Protection Officers and AI challenges
The CNIL has released a survey highlighting the evolving role of Data Protection Officers in the context of artificial intelligence, urging organizations to reassess their data protection strategies by September 22, 2026.
UK Government Introduces Certification Scheme for Digital Verification Services
The UK government has established a certification scheme for digital verification services under the UK digital identity and attributes trust framework, affecting conformity assessment bodies.
FCA initiates High Court proceedings against Hunter Jones for unauthorized activities
The Financial Conduct Authority has begun High Court proceedings against Osborne Baldwin Limited, trading as Hunter Jones, for allegedly conducting regulated activities without authorization.
Japan Adopts Generative AI Principle Code on IP Protection and Transparency, 25 August 2026
Japan's Intellectual Property Strategy Headquarters adopted the Principle Code on the Protection of Intellectual Property and Transparency for the Appropriate Use of Generative AI on 25 August 2026. The Code runs on a comply or explain basis and carries no statutory penalty. It asks generative AI developers and providers to publish model and training data information, and notification to the Cabinet Office opens on 26 October 2026.
Norway Advises Against Generative AI in Primary School Grades 1 to 7, June 2026
The Norwegian government issued a national recommendation on 19 June 2026 that pupils in grades 1 to 7 should in all essential respects not be given access to generative AI in their schoolwork. Grades 8 to 10 may introduce it gradually once teachers have the competence to guide it, and upper secondary pupils should learn purposeful use. The recommendation applies from the autumn 2026 school start and is not binding law.
Kenya's Digital Asset Licensing and Client Protection Rules
Kenya licenses businesses that hold, exchange, transfer, manage or issue virtual assets and prescribes how they protect customers. The question is how the Virtual Asset Service Providers Act, 2025, No. 20 of 2025 (Act), and the Virtual Asset Service Providers Regulations, 2026, Legal Notice 134 of 2026 (Regulations), govern market entry and continuing operations.
ESMA Confirms Binary Options Bans Cover Event Contracts and Prediction Markets, EU, 3 July 2026
The European Securities and Markets Authority published statement ESMA35-243228190-8148 on 3 July 2026, confirming that national product intervention measures on binary options already capture event contracts sold on prediction market platforms. Contracts referencing an underlying in Section C(4) to (10) of Annex I to MiFID II are financial instruments, and their marketing, distribution or sale to retail clients in the EU is prohibited. Operators serving only professional clients still require MiFID II authorisation.
MHRA Publishes National Commission Recommendations on AI in Healthcare, United Kingdom, 10 September 2026
The Medicines and Healthcare products Regulatory Agency published the National Commission into the Regulation of AI in Healthcare report on 10 September 2026. The Commission, chaired by Professor Alastair Denniston, recommends staged authorisations for new AI models, continuous real-world monitoring of AI-enabled medical devices, public access to device safety and adverse incident records, patient notification of AI use in care, and stronger enforcement powers for the MHRA.
CSBS Releases Artificial Intelligence Supervisory Framework for State Examiners, United States, 16 September 2026
The Conference of State Bank Supervisors released its Artificial Intelligence Supervisory Framework on 16 September 2026, a discretionary set of examiner materials approved by two CSBS committees in August 2026. It gives state examiners a core guide, a work program, nonbank supplements covering third-party and vendor AI, and an optional worksheet for risk tiering individual AI use cases. Each state agency decides how far to adopt it.
Ireland Enacts Regulation of Artificial Intelligence Act 2026 Establishing AI Office, 21 July 2026
President Connolly signed the Regulation of Artificial Intelligence Act 2026 into law on 21 July 2026. The Act creates the AI Office of Ireland as an independent statutory body and as Ireland's central coordinating authority for implementation of Regulation (EU) 2024/1689. The Department of Enterprise, Tourism and Employment describes the Act as a technical implementing measure that does not add to the obligations the EU Regulation already places on regulated entities. Paul Byrne was appointed its first Chief Executive Officer, with the Office expected to be operational by 2 August 2026.
SEC Proposes Transfer Agent Rule Modernization for Blockchain Recordkeeping, United States, 1 September 2026
The Securities and Exchange Commission issued Release No. 34-106246 on 1 September 2026, proposing amendments to the rules governing registered transfer agents. The package would amend ten existing Exchange Act rules, rescind Rule 17ad-4 and add new Rules 17ad-30 and 17ad-31, replacing certificate-era assumptions with technology-neutral terms that accommodate electronic and blockchain-based recordkeeping. Comments are due 60 days after publication in the Federal Register.
Compass progress report, September 2026
On a sealed set of 190 questions, Compass cited 76.5% of the articles a correct answer required and produced no quotation that differed from the published text. A new check against the EU catalogue found nine acts with no English consolidated version.
Indonesia's OJK Digital Asset Trading Reporting Regulation PADK 3/2026 Took Effect 1 September 2026
Indonesia's Otoritas Jasa Keuangan stipulated Peraturan Anggota Dewan Komisioner OJK Number 3 of 2026 on 30 June 2026, and it took effect on 1 September 2026. The regulation sets reporting duties for licensed operators trading digital financial assets, including crypto assets, covering asset evaluations, monthly trading reports, quarterly and annual activity and risk self-assessment reports, and incident notifications. It replaces Circular Letter 20/SEOJK.07/2024 in stages, with the remainder revoked on 1 January 2027.
UK Government Bans Social Media for Under 16s
The UK government will implement new rules banning social media usage for individuals under 16, enhancing online safety for children.
FCA Investigates Euro Exchange Securities UK Ltd for Potential Offences
The Financial Conduct Authority has opened an investigation into Euro Exchange Securities UK Ltd for potential offences related to the UK crypto market.
EU AI Board Discusses AI Act Enforcement
The AI Board held its ninth meeting on 18 September 2026, focusing on EU AI Act enforcement and implementation. All regulated entities should monitor developments from these discussions for potential compliance changes.
ESMA Issues Guidelines on Regulatory Classification of Crypto-Assets
ESMA, along with EBA and EIOPA, published guidelines to ensure consistent regulatory classification of crypto-assets under MiCA, effective from March 2025.
EBA publishes final Guidelines on third-party risk management under DORA
The European Banking Authority has issued final Guidelines on managing third-party risk, effective September 18, 2026, focusing on critical functions to enhance financial resilience.
UK Government Issues Guidance on 2G Switch-Off Charter and Cyber Resilience Pledge
The UK government has published new guidance on the 2G switch-off charter and released a list of organizations that signed the Cyber Resilience Pledge, emphasizing consumer protection and cybersecurity commitments.
FCA Issues Cease and Desist Letters on Illegal Crypto Trading in London
The Financial Conduct Authority has intensified its crackdown on illegal peer-to-peer crypto trading in London, issuing cease and desist letters to three premises suspected of operating unregistered crypto trading businesses.
AMF Reminds Digital Asset Service Providers of Transitional Period
The AMF has reminded Digital Asset Service Providers that the transitional period for crypto-asset services ends on 1 July 2026, requiring compliance with MiCA regulations.
California Enacts AI Auditor Registry Laws SB 813 and AB 1405, 9 September 2026
Governor Gavin Newsom signed Senate Bill 813 and Assembly Bill 1405 on 9 September 2026. Senate Bill 813 sets the terms on which independent verification organisations may assess artificial intelligence systems and models for compliance with California law, and Assembly Bill 1405 creates a state registry of AI auditors with standards governing their independence, transparency and integrity. The two measures put third party evaluation of AI systems on a statutory footing in California.
California Enacts Synthetic Performer Advertising Disclosure Law SB 1050, 16 September 2026
Governor Gavin Newsom signed Senate Bill 1050 on 16 September 2026, requiring video and audio advertisements that use AI-generated synthetic performers to carry a clear and conspicuous disclosure that the performer is not human. The measure, authored by Senator Angelique Ashby, treats an undisclosed synthetic performer as false advertising and bars an advertising medium from continuing to distribute an advertisement found to violate the law.
FCA Issues Guidance for Crypto Firms on Upcoming Regime
The Financial Conduct Authority has released guidance for crypto firms regarding the UK's future cryptoasset regime, effective 25 October 2027, with authorisation applications opening on 30 September 2026.
UK Cryptoasset Authorisation, Transition and Market Access Under the 2027 Regime
The United Kingdom will bring additional cryptoasset businesses into its financial-services authorisation system on 25 October 2027. The question is which activities and entities require permission, and which businesses may continue while applications remain unresolved. The answer depends on the asset, contractual functions, customer base and application history.
DORA Accountability Across Firms, Providers and Supervisors
The Digital Operational Resilience Act (DORA) allocates technology-risk responsibilities among financial entities, ICT providers and supervisors. Outsourcing does not erase the financial entity’s responsibility, but neither does DORA impose every requirement on every entity or turn every supervisory publication into law.
Major ICT Incidents under DORA
EU financial entities must report major information and communication technology (ICT) incidents under the Digital Operational Resilience Act (DORA). The question is how the joint supervisory staff instructions dated 16 September 2026 affect classification, reporting deadlines and the information submitted. This analysis addresses the EU rules, with particular attention to insurance and occupational pensions.
ESMA outlines policy requirements under DORA
ESMA has detailed over 20 policy requirements under the Digital Operational Resilience Act (DORA) for financial entities to enhance their operational resilience strategies.
European Commission welcomes AI IPCEI initiative
The European Commission has welcomed the initiative of 19 Member States to create and pre-notify the first Important Project of Common European Interest in artificial intelligence, aiming to foster collaboration and investment in AI technologies across Europe.
EIOPA issues operational instructions for incident reporting under DORA
EIOPA has published operational instructions detailing incident reporting requirements under the Digital Operational Resilience Act (DORA) for regulated entities.
FCA publishes new perimeter guidance for cryptoassets in the UK
The FCA has issued a policy statement on perimeter guidance for cryptoassets, effective from 16 September 2026, clarifying definitions and scope under the UK's regulatory framework for crypto-asset service providers (CASPs).
California Enacts Child Safety Chatbot and Social Media Laws, 10 September 2026
Governor Gavin Newsom signed a package of child online safety measures into California law on 10 September 2026. Senate Bill 1119, known as Adam's Law, sets safety duties for companion chatbots, including crisis protocols where a user shows suicidal ideation, parental controls, independent child safety audits and annual risk assessments. Assembly Bill 1709 imposes age restrictions on covered platforms and Assembly Bill 1856 requires age verification signals from software applications.
European Commission Proposes EU KIDS Act Covering AI Chatbots, 17 September 2026
The European Commission presented the EU KIDS Act, Keeping Internet Digital Spaces Accountable and Trustworthy, on 17 September 2026. The proposal sets one European Union age of 15 for autonomous account creation on social networking services and video sharing platforms, and it reaches AI companions and chatbots. Enforcement builds on the Digital Services Act for platforms and on the AI Act for chatbots, with fines running to 6 percent of total worldwide annual turnover.
UK Joint Committee on Human Rights Calls for AI Bill, 14 September 2026
The Joint Committee on Human Rights published Human Rights and the Regulation of AI, its Fourth Report of Session 2026 to 27, on 14 September 2026. The Committee asks the United Kingdom government to bring in a dedicated AI Bill and to set up a new independent regulator with statutory powers. It records that the legal position is patchy and confused, with many regulators charged with tackling some AI harms and no single body coordinating regulation of AI.
UK Government Launches Consultation on AI and Children's Online Safety
The UK government has initiated a consultation titled 'Growing up in the online world' to explore measures for children's online safety, including potential age restrictions on AI technologies.
FCA bans Nurul Miah from financial services due to misconduct
The Financial Conduct Authority has banned Nurul Miah from working in financial services after serious misconduct involving client funds. Miah allowed over £28 million to be misappropriated, with more than £10 million missing and used for personal benefit.
UK Artificial Superintelligence Bill Receives First Reading in Commons, 8 September 2026
Alex Sobel MP introduced the Artificial Superintelligence Bill in the House of Commons on 8 September 2026 under the Ten Minute Rule. The Bill would prohibit the development, deployment and operation of artificial superintelligence systems and would establish monitoring and control powers in respect of such systems. Parliament has listed it for Second Reading on 13 November 2026 in the 2026-27 session. A Ten Minute Rule Bill progresses only where parliamentary time allows at Second Reading.
US Senate Rejects Cloture on Digital Asset Market Clarity Act, 15 September 2026
The United States Senate rejected cloture on the motion to proceed to H.R. 3633, the Digital Asset Market Clarity Act, on 15 September 2026. Roll Call Vote 234 of the 119th Congress, 2nd Session recorded 49 yeas and 50 nays with one senator not voting, against a required majority of three fifths. The motion to proceed failed and the Senate did not begin floor consideration of the measure, leaving the division of authority over digital assets where it stood before the vote.
Poland's Act on Artificial Intelligence Systems Enters Into Force, 11 August 2026
The Act of 3 July 2026 on artificial intelligence systems was promulgated in Dziennik Ustaw 2026 item 1003 on 27 July 2026 and entered into force on 11 August 2026. It designates the Commission for the Development and Security of Artificial Intelligence as Poland's market surveillance authority under Regulation (EU) 2024/1689. Articles 8 to 18 and Chapters 3 to 5, 8 and 9 apply from 28 October 2026, setting the date on which the supervisory and penalty provisions begin to operate.
AI Risk Acceptance and Legal Responsibility in Saudi Arabia: Legal Effects of SDAIA’s 2026 AI Risk Management Framework
The Saudi Data and Artificial Intelligence Authority (SDAIA) has published a national method for assessing and managing AI risks. The question is whether adoption changes existing duties, permits residual risk, or reallocates responsibility between organisations and suppliers.
What the September 14 CLARITY Act Draft Would Change and Where Its Limits Remain
Congress is considering legislation that would allocate responsibility for digital-asset markets and impose duties on issuers, trading businesses, and public officials. The question is what the September 14, 2026 text would change, which protections depend on exceptions or later rules, and where enforcement could fail.
CSSF publishes new MiCA regulations for crypto-asset market
The CSSF has issued new Commission Delegated and Implementing Regulations under MiCA, affecting crypto-asset service providers and issuers of asset-referenced and e-money tokens.
FCA announces liquidation of Premier Payment Solutions Ltd
Premier Payment Solutions Ltd, trading as PPS Money, entered liquidation on 10 September 2026, following a decision by its directors. The joint liquidators will assess customer claims and distribute available funds.
EBA updates validation rules for reporting frameworks
The European Banking Authority has published an updated list of validation rules affecting financial services firms' reporting frameworks.
Hong Kong Privacy Commissioner Issues Agentic AI Personal Data Guidance, 25 August 2026
The Office of the Privacy Commissioner for Personal Data published Protecting Personal Data Privacy in the Use of Agentic AI on 25 August 2026. The guidance is advisory rather than binding and sets out nine recommendations for organisations deploying autonomous AI agents, together with a security checklist spanning evaluation, preparation, deployment, use and cessation. It applies existing Personal Data (Privacy) Ordinance duties to systems that act without step by step human instruction.
Nigeria SEC Exposes Proposed Digital and Virtual Assets Rules, 20 August 2026
Nigeria's Securities and Exchange Commission published the Proposed Rules on Digital and Virtual Assets Operations, Custody and Markets on 20 August 2026 for a two week exposure period. The Rules create six registrable functions covering exchanges, custodians, offering platforms, platform operators, tokenisation platforms and virtual asset service providers, and impose an eighty per cent cold storage minimum on custodians holding client assets.
Bafin orders Cadence Growth Capital GmbH to submit documents for AML compliance
Bafin has issued an order to Cadence Growth Capital GmbH requiring the submission of contracts with placement agents and other documents necessary to meet customer due diligence obligations under the German Money Laundering Act (GwG).
FATF Risks of Gaming and Gambling (Report)
The Financial Action Task Force (FATF) examines illicit-finance risks in its September 2026 publication, Risks of Gaming and Gambling (Report). The question is how its findings and red-flag indicators should inform risk assessment, supervision and operator controls.
Gambling Commission Confirms Staged Financial Risk Assessments for British Operators, 7 July 2026
On 7 July 2026 the Gambling Commission announced that financial risk assessments will be introduced for British licensees in stages rather than at a single threshold. Stage one captures net deposits of GBP 5,000 in a rolling 24 hours for customers aged 25 and over, and GBP 2,500 for customers under 25. The final stage moves to GBP 1,000 in 24 hours or GBP 3,000 over 90 days, and GBP 750 or GBP 2,000 for the under 25 group. The stage one start date is to be confirmed in the consultation response document.
United Kingdom Criminalises Supply of AI Intimate Image Generators from 29 June 2026
Section 99 of the Crime and Policing Act 2026 inserted new sections 66I to 66L into the Sexual Offences Act 2003, creating an offence of making, adapting, supplying or offering to supply a thing designed for use as a generator of purported intimate images. The provision came into force on 29 June 2026 under the Crime and Policing Act 2026 (Commencement No. 1 and Saving Provision) Regulations 2026. Conviction on indictment carries up to three years imprisonment and an unlimited fine.
Italian Data Protection Authority Issues Conditional Opinion on AI Act Implementing Decree, 14 July 2026
The Garante per la protezione dei dati personali issued provvedimento n. 532 on 14 July 2026, a favourable opinion subject to conditions on a draft Italian legislative decree adapting national law to Regulation (EU) 2024/1689. The draft covers the powers of national authorities under the AI Act and the use of artificial intelligence in education. The Garante asked for changes to sanctioning procedure, conformity assessment responsibility and the treatment of automated decisions in employment.
Hawala and Underground Banking in FATF’s 2026 Report
The Financial Action Task Force (FATF) published a September 2026 report on professional money laundering through underground banking, hawala and other similar service providers (HOSSPs). The questions are what its findings establish, how they relate to FATF standards, and what responses they support. No domestic jurisdiction, transaction or enforcement proceeding has been specified. The analysis addresses international standards and attributed country examples; it does not determine liability or operational duties under an unidentified national law.
China's Supreme People's Court Issues AI Dispute Adjudication Opinions, 7 September 2026
The Supreme People's Court of China issued the Opinions on Lawfully Adjudicating Disputes Involving Artificial Intelligence, Fafa [2026] No. 10, on 7 September 2026. The document runs to 24 articles across five parts and directs courts nationwide on infringement liability, intellectual property, procedural rules and criminal matters arising from the use of AI. It is the first national judicial guidance of its kind in China.
California CCPA Automated Decisionmaking Rules Bind Businesses from 1 January 2027
The California Privacy Protection Agency regulations on automated decisionmaking technology were approved by the Office of Administrative Law on 22 September 2025 and took effect on 1 January 2026. A business that uses automated decisionmaking technology to make significant decisions about consumers must comply from 1 January 2027. The same rulemaking sets staged deadlines for cybersecurity audits and for risk assessment reporting to the Agency.
Product Security Accountability under the EU Cyber Resilience Act
The European Union's Cyber Resilience Act regulates the security of software and hardware supplied to its market. The question is which businesses must disclose product vulnerabilities or incidents, when disclosure becomes compulsory, and how those duties interact with product support and other reporting laws.
UK Government Releases AI Risk Management Toolkit
The UK government has published an AI Risk Management Toolkit to assist individuals and organizations involved in AI projects with risk management practices.
South Korea Adopts Non-Binding National AI Ethics Principles, 21 August 2026
The Republic of Korea confirmed its national Artificial Intelligence Ethics Principles on 21 August 2026, announced by the Ministry of Science and ICT with the Korea Information Society Development Institute on 24 August 2026. The instrument sets out three values and seven principles covering human-centeredness, privacy, fairness, accountability, safety, trustworthiness and transparency. It is non-binding guidance replacing the 2020 National Artificial Intelligence Ethics Standards, with sector checklists and interpretive guides to follow.
UK HMRC Confirms Full Capital Gains Tax Exemption for Eligible Stablecoins from April 2027
HM Revenue and Customs published the outcome of its call for evidence on stablecoin taxation on 13 July 2026, confirming that eligible stablecoins will be treated more like money for Capital Gains Tax, Income Tax and Corporation Tax. A full Capital Gains Tax exemption is the preferred approach for individuals, and eligible stablecoins will fall within the loan relationship rules for companies. The measures are to be carried in Finance Bill 2026-27 with effect from April 2027.
Dutch DPA Fines Uber €824.99 Million for GDPR Article 22 Violation, August 2026
On 21 August 2026, the Autoriteit Persoonsgegevens imposed a fine of €824,990,000 on Uber B.V. for fully automated deactivation of drivers' accounts in breach of GDPR Article 22, which prohibits automated individual decision-making that produces legal or similarly significant effects on data subjects without a qualifying exception. The penalty is the second largest GDPR fine on record, behind the €1.2 billion fine imposed on Meta by the Irish DPA in 2023.
MAS Consults on Legislative Implementation of Singapore Stablecoin Regime, 1 September 2026
On 1 September 2026, the Monetary Authority of Singapore published a consultation paper setting out draft amendments to the Payment Services Act 2019 to convert its 2023 stablecoin policy into enforceable statute. Key proposals require 100% reserve backing in high-quality liquid assets, prohibit interest payments on MAS-regulated stablecoins, and restrict the 'MAS-regulated stablecoin' label to licensed issuers only. The consultation closes on 16 October 2026.
EU Cyber Resilience Act Reporting Obligations Take Effect 11 September 2026
The EU Cyber Resilience Act's incident and vulnerability reporting requirements take effect on 11 September 2026, more than fourteen months before the Act's full compliance date of December 2027. Manufacturers of products with digital elements placed on the EU market must send national CSIRTs and ENISA an early warning within 24 hours of becoming aware of an actively exploited vulnerability or a severe incident, a notification within 72 hours, and a final report no later than 14 days after a corrective measure is available (vulnerabilities) or within one month of the notification (severe incidents).
CFTC Issues Request for Comment on Compute Derivatives Contracts, August 2026
On 19 August 2026, the U.S. Commodity Futures Trading Commission published a formal request for public comment on the listing of derivative contracts referencing computing power in U.S. designated contract markets. The CFTC seeks input on cash market size and liquidity for compute, manipulation risks, customer protection, and the design of perpetual compute futures, with a view to assessing whether computing power qualifies as a commodity under the Commodity Exchange Act.
South Korea FSC Sets Token Securities Policy Roadmap at Third Consultation, 4 September 2026
South Korea's Financial Services Commission convened the third session of its public-private Token Securities Consultation Body on 4 September 2026, publishing a policy direction that sets out a three-phase infrastructure roadmap for tokenised securities issuance and settlement. The policy direction anticipates a legislative amendment to the Act on Electronic Registration of Stocks and Bonds scheduled to take effect on 4 February 2027.
APRA and ASIC Issue Coordinated Frontier AI Risk Directives to Australian Finance Sector, 2026
Australia's Australian Prudential Regulation Authority and Australian Securities and Investments Commission issued coordinated public letters and conducted nine Frontier AI Roundtables in 2026, directing regulated financial services entities to strengthen AI risk management and cyber resilience programs in response to threats posed by frontier AI models.
Australia Enacts Interactive Gambling Amendment (Gambling Reform) Act 2026, 26 August
The Interactive Gambling Amendment (Gambling Reform) Act 2026 (Cth) became law on 26 August 2026, amending the Interactive Gambling Act 2001 (Cth). The legislation introduces the most extensive changes to Australia's online gambling laws since the original 2001 Act, addressing advertising restrictions, duty-of-care obligations, affordability checks, and expanded powers for the National Self-exclusion Register.
Bafin imposes fines for market manipulation violations
On 24 August 2026, Bafin imposed administrative fines of €1,900 and €1,650 on two individuals for market manipulation under the Market Abuse Regulation.
India Supreme Court Schedules Final Hearing on Online Gaming Act Constitutionality, 2026
India's Supreme Court, in a bench led by Chief Justice Surya Kant, has fixed a final constitutional hearing on petitions challenging the Promotion and Regulation of Online Gaming Act, 2025 (PROGA). The three-judge bench will hear the PROGA petitions together with related state gaming ban cases. The outcome will determine Parliament's legislative competence over online money-gaming and the survival of state-level gaming laws.
European Commission Designates ChatGPT Very Large Online Search Engine Under DSA, 31 August 2026
On 31 August 2026, the European Commission designated OpenAI's ChatGPT as a Very Large Online Search Engine under Regulation (EU) 2022/2065, citing 159.1 million average monthly active recipients in the EU. Reddit and Roblox received simultaneous VLOP designations. OpenAI must implement full compliance obligations by January 2027 or face fines up to 6% of global annual turnover.
BIS Financial Stability Institute Analyses Permissible Stablecoin Issuance Entities, August 2026
On 27 August 2026, the Bank for International Settlements Financial Stability Institute published FSI Brief No. 33, examining which entity types may issue fiat-referenced stablecoins and what ancillary activities they may conduct. The brief surveys the EU, United States, United Kingdom, Singapore, and Japan, identifying MiCA's entity-type restriction as the most prescriptive among reviewed regimes.
The Platform Decision Stack on Trial
Collective data rights, automated work allocation, model training, cross-border transfers, and the limits of mass compensation in Amsterdam.
Delegated Machine Authority
Federal law is unlikely to regulate an AI agent because the software has a new legal personality. It regulates the delegated authority through which the software acts: identity, permission, supervision, revocation, and evidence.
FCA bans and fines Daniel Thomas for unauthorized pension advice
The Financial Conduct Authority has banned Daniel Thomas from financial services and fined him £742,700 for providing unauthorized pension transfer advice.
Canada Tables Bill C-34 Creating Regulated Chatbot Services Category Under Digital Safety Act, June 2026
Canada tabled Bill C-34 at first reading on 10 June 2026, proposing the Digital Safety Act and the Digital Safety Commission of Canada Act. The bill creates a statutory 'regulated chatbot services' category with crisis intervention, AI disclosure, minor protection, and annual self-harm reporting obligations. Penalties reach C$10 million or 3% of global annual revenue. The bill sits at first reading.
Hong Kong PCPD Publishes Agentic AI Guidance Applying Data Protection Principles to Autonomous Systems, August 2026
On 25 August 2026, the Office of the Privacy Commissioner for Personal Data of Hong Kong published 'Protecting Personal Data Privacy in the Use of Agentic AI,' applying the six Data Protection Principles of the Personal Data (Privacy) Ordinance (Cap. 486) to autonomous AI deployments. The guidance targets organisations operating AI agents with multi-step autonomous decision-making capabilities.
Thailand SEC Proposes Domestic Crypto ETF Rules and Revised Foreign Custodian Requirements, August 2026
Thailand's Securities and Exchange Commission published two consultation papers on 24 August 2026 proposing rules for domestically domiciled crypto ETFs and revised qualification requirements for foreign digital asset custodians used by mutual funds and private funds. The proposals require crypto ETFs to maintain at least 80% net exposure to a reference digital asset. Comments close 20 September 2026.
CFTC Innovation Advisory Committee Inaugural Meeting Reviews Crypto, AI, and Prediction Markets, August 2026
The Commodity Futures Trading Commission's Innovation Advisory Committee held its inaugural meeting in Washington on 20 August 2026, convened by Chairman Selig. The agenda covered the regulatory evolution of crypto assets, artificial intelligence and compute capacity in derivatives markets, and the regulatory treatment of prediction markets and novel event contracts.
Bafin imposes fine on a.i.s. AG for disclosure violation in Germany
Bafin has fined a.i.s. AG €15,000 for not publishing required financial information for 2025. This action relates to the German Securities Trading Act (WpHG).
Singapore Launches Public Consultation on AI and Intellectual Property Laws, August 2026
Singapore's Ministry of Law and the Intellectual Property Office of Singapore launched a joint public consultation on 26 August 2026 to assess how Singapore's intellectual property laws should adapt to artificial intelligence. The consultation closes on 22 October 2026 and covers copyright authorship of AI-generated works, patent eligibility of AI-assisted inventions, AI-driven infringement liability, and design registration for AI outputs.
OCC, FDIC, and Treasury Propose GENIUS Act Stablecoin Implementing Rules, August 2026
The OCC, FDIC, and Treasury Department each published proposed rules in August 2026 to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act. The proposals set prudential standards for permitted payment stablecoin issuers, establish a $10 billion issuance threshold separating federal from state regulatory pathways, and extend Bank Secrecy Act AML/CFT obligations to all issuers.
California SB 1000 Expands AI Transparency Act to All Generative AI Developers, August 2026
California's SB 1000 (Becker, 2025-2026 session) passed the Legislature in August 2026 and awaits the Governor's signature. The bill amends the AI Transparency Act (SB 942, Stats. 2024, Ch. 291) by deleting the one-million-user threshold from the covered provider definition and replacing the AI detection tool obligation with an active disclosure verification tool covering AI-generated and AI-modified content.
Relocation Before a Web3 Founder’s Exit: The Residence-State Layer
Can a founder who is currently tax resident in an EU Member State genuinely relocate before a future exit and change the taxation of a later liquidity event, and how do fifteen destinations compare, assuming a one-off personal disposal of ordinary unlisted shares in a non-property-rich foreign company, held as an investment by a seller who is not a securities dealer, with no binding sale, unconditional entitlement, option exercise or pre-sale contribution before the move?
CSSF Publishes New Regulations Under MiCA
The CSSF has issued new Commission Delegated and Implementing Regulations under the Markets in Crypto-Assets Regulation (MiCA), impacting crypto-asset service providers and issuers of asset-referenced and e-money tokens.
Foreign Ownership of a Delaware or Wyoming Entity: Federal Tax Classification, Information Reporting, Withholding, and State Duties
A non-U.S. person may own a Delaware or Wyoming LLC or a Delaware corporation, yet formation alone does not settle the federal tax result, the reporting burden, confidentiality, or the right to work in the country. This part takes the U.S. entity as chosen and examines classification, Form 5472 reporting, source and effectively connected income, partner and shareholder withholding, tax residence and immigration, duties beyond the formation state, real property and estate exposure, and treaty and home-country dependencies.
Structuring Cross-Border Digital-Asset Ventures (Part 2)
A cross-border digital-asset group must allocate protocol stewardship, token issuance, customer-facing regulated services, pooled investment, treasury, and founder functions before it selects any jurisdiction. The question presented is where each of those functions can lawfully sit across sixteen jurisdictions and the European Union and EEA overlay, as of 27 August 2026.
Function-First Entity Design for Cross-Border Digital-Asset Ventures
Cross-border digital-asset ventures often separate several legal roles. Those roles include the venture issuer, operating company, customer-facing licensee, token issuer, pooled vehicle, treasury body, and protocol administrator. The Question Presented is which roles eight jurisdictions can support as of 27 August 2026.
Selection of Instrument, Issuer, and Entity Arrangement in Private Pre-Priced-Round Financings Involving Contingent Token Rights
Early-stage ventures often raise capital before a negotiated share price exists, while some also promise investors rights tied to a later token launch. The question presented is which instrument, issuer, and entity arrangement best fits a private early-stage financing involving Delaware, the British Virgin Islands, or the Cayman Islands.
High Court of Australia Hears Arguments on Bitcoin as Property in Poulton v Conrad
The High Court of Australia is considering in Poulton v Conrad (Case No. H1/2026) whether Bitcoin constitutes property capable of possession at common law, and whether the torts of conversion and detinue apply to Bitcoin holdings. Special leave was granted on 5 February 2026. The Australian Taxation Office has applied to intervene. No judgment has been issued; the matter has proceeded to oral argument before the Court.
SEC Proposes Regulation Crypto Assets with Dual Offering Exemptions, 18 August 2026
On 18 August 2026, the Securities and Exchange Commission proposed Regulation Crypto Assets (Reg CA), Release No. 33-11434, establishing the first dedicated securities offering regime for covered investment contracts involving crypto assets. Two new exemptions apply: up to $5 million over four years, and up to $75 million per 12-month period. A conditional safe harbor converts a qualifying token out of the investment-contract classification on network completion. State blue-sky laws are preempted for qualifying offerings.
Choice of Legal Seat for a Founder-Owned Cross-Border Services Company: Wyoming, Delaware, Singapore, and the British Virgin Islands
A founder may form a one-owner services company in a U.S. state or a foreign jurisdiction while living elsewhere. The question is which legal seat fits an unregulated digital or professional-services business with no employees or institutional investors at formation. The founder seeks liability separation, predictable upkeep, usable ownership records, and a route to later financing. Residence, work location, client locations, tax status, and the intended bank are unstated.
Offshore Structuring for a Web3 Founder's Exit
An exit is any transaction or linked sequence that changes legal title, practical control, economic entitlement, or source-vehicle continuity. It may be a token sale, share sale, distribution, contribution, settlement, redemption, liquidation, or statutory migration. A complete exit removes the founder's title, affirmative decision-making power, and unilateral economic access. A partial exit preserves identified rights or exposure. Offshore means that a holding vehicle is formed outside the founder's residence and usually outside the operating jurisdiction.
India Supreme Court: Judicial Decisions Based on AI-Hallucinated Citations Must Be Set Aside
In Pooja Ramesh Singh v. Jammu and Kashmir Bank Limited (C.A. No. 11950/2025, 2026 INSC 668), decided 2 July 2026, the Supreme Court of India held that a judicial or quasi-judicial decision relying on fabricated AI-generated case citations is unsustainable in law and must be set aside, binding all Indian courts and tribunals.
US Treasury Proposes GENIUS Act Licensing Rules for Payment Stablecoin Issuers
On 18 August 2026, the U.S. Department of the Treasury published a Notice of Proposed Rulemaking implementing Section 3 of the GENIUS Act, setting licensing requirements for payment stablecoin issuance, offer, and sale in the United States. Public comments close on 19 October 2026.
UK Solicitors Regulation Authority Issues Warning Notice on AI Misuse in Legal Practice, 17 August 2026
The Solicitors Regulation Authority published a Warning Notice on 17 August 2026 alerting solicitors and law firms in England and Wales to professional conduct risks from AI misuse, including submission of non-existent AI-generated citations and confidentiality breaches through open-source AI tools. The SRA received 42 AI-related misconduct reports between July 2025 and July 2026 and confirmed ongoing investigations.
India Supreme Court Sets Aside Judgment Relying on AI-Hallucinated Precedents, July 2026
The Supreme Court of India, in Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. (C.A. No. 11950/2025, 2026 INSC 668), set aside judgments of the National Company Law Tribunal and the appellate tribunal on 2 July 2026, after finding that both tribunals had cited non-existent judicial precedents generated by artificial intelligence. The Court declared human oversight mandatory at every stage at which AI output is used as legal authority.
Dutch DPA Fines Uber EUR 825 Million for Automated Driver Suspensions Under GDPR
On 21 August 2026, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) fined Uber Technologies Inc EUR 825 million for violating GDPR Article 22, finding that Uber's algorithmic system suspended driver accounts without any human review and failed to notify drivers of automated decisions. This is the second-largest GDPR penalty to date.
Singapore IMDA Publishes Model AI Governance Framework for Agentic AI Systems, January 2026
The Infocomm Media Development Authority of Singapore (IMDA) published the Model AI Governance Framework for Agentic AI in January 2026, the first jurisdiction-level governance framework specifically addressing agentic AI systems. The framework identifies five categories of agentic risk and four governance dimensions, designates human oversight as mandatory, and addresses multi-agent coordination risks not covered by prior general AI governance instruments.
US Treasury Proposes GENIUS Act Payment Stablecoin Rules, Comment Period Closes 19 October 2026
On 17 August 2026, the US Department of the Treasury published a Notice of Proposed Rulemaking under Section 3 of the GENIUS Act defining when payment stablecoin issuance and distribution to US persons triggers federal or state licensing requirements. Licensing for issuers takes effect 18 January 2027; the offer and sale prohibition on unlicensed stablecoins follows on 18 July 2028. Comments are due 19 October 2026.
UK SRA Issues Warning Notice on AI Misuse in Legal Practice, 17 August 2026
The Solicitors Regulation Authority published a Warning Notice on 17 August 2026 cautioning solicitors against AI misuse in legal practice, citing 42 reports of potential misuse between July 2025 and July 2026. Core concerns are AI-generated false citations submitted to courts and confidentiality breaches from loading client data into public AI tools.
Investment and offering rules for crypto projects raising capital across key markets
Crypto projects may fall within securities, fund or investment-services law when investors contribute value for rights to profits, yield, income, assets or net asset value that depend materially on a promoter’s or manager’s work. Offering exemptions address only part of the analysis because licensing, fund-management, custody, anti-money-laundering, sanctions and transfer restrictions can apply separately across jurisdictions.
ESMA updates Q&A on MiCA for crypto-asset service providers
ESMA has updated its Q&A page with new guidance on MiCA, impacting crypto-asset service providers and token issuers. Entities must align with the latest clarifications to ensure compliance.
Ninth Circuit Holds the User, Not the AI Agent Developer, Accesses Websites Under CFAA, August 2026
In Amazon.com Services, LLC v. Perplexity AI, Inc., No. 26-1444 (9th Cir. Aug. 4, 2026), the Ninth Circuit vacated a preliminary injunction against Perplexity AI, holding that the developer of an AI browser assistant does not "access" a third-party website within the meaning of the Computer Fraud and Abuse Act or California's CDAFA when a human user activates the tool. The court held that it is the user who accesses the website, with the help of the assistant, and did not hold users liable.
Cyprus Ends MiCA Transitional Period and Introduces 8% Crypto Gains Tax in 2026
On 1 July 2026, the transitional period under Article 143(3) of Regulation (EU) 2023/1114 (MiCA) expired for crypto-asset service providers operating in Cyprus under prior national arrangements. Separately, Article 20E of Cyprus's Income Tax Law, introduced as part of the 2026 tax reform, applies a flat 8% tax on gains from crypto-asset disposals effective 1 January 2026.
FASB Proposes Stablecoin Classification as Cash Equivalents Under US GAAP, August 2026
On 18 August 2026, the Financial Accounting Standards Board issued a proposed Accounting Standards Update addressing whether qualifying stablecoins meet the definition of cash equivalents under ASC Topic 230, Statement of Cash Flows. The proposal adds enhanced disclosure requirements for entities holding such stablecoins and opens a public comment period. No final standard has been issued.
AI Projects Across Jurisdictions
Choosing a jurisdiction for an AI project involves more than deciding where to register a company. The practical answer depends on where the team works, where users and customers are located, what data and models the project uses, and what the product actually does. A company may be based in one country while still having to follow the rules of every market it serves. The overview is current as of 24 August 2026 and does not assume any particular product, business model, or operating structure.
CSSF Updates MiCA Regulations for Crypto-Assets
The CSSF has updated its documentation on the Markets in Crypto-Assets Regulation (MiCA), impacting crypto-asset service providers and issuers of asset-referenced and e-money tokens with new compliance requirements by 20 August 2025.
PEB for UCC Confirms Article 8 Permits Tokenized Securities Transfers Without Statutory Amendment
The Permanent Editorial Board for the Uniform Commercial Code has issued a report concluding that existing Article 8 of the UCC permits issuers to use digital tokens as the mechanism for transferring uncertificated securities and for establishing control over such securities. The report resolves a central legal uncertainty for US digital asset and securities markets without requiring statutory amendment.
Bafin imposes fines on Effecta GmbH and Companisto Trust Service XXXV UG
Bafin has fined Effecta GmbH €15,000 and Companisto Trust Service XXXV UG €9,000 for failing to publish key information documents as required by the PRIIPs Regulation.
AMF Updates MiCA Requirements for Crypto-Asset Service Providers
The AMF has updated its section on the MiCA regulation, detailing requirements for crypto-asset service providers regarding authorization and compliance obligations before 6 July 2026.
AMF Updates MiCA Regulation Guidelines for Crypto-Asset Service Providers
The AMF has updated its guidelines on the MiCA regulation, detailing obligations for crypto-asset service providers, including application procedures and compliance deadlines.
FCA Warns Consumers About Risks of Unregulated Mini-Bonds and Loan Notes
The Financial Conduct Authority (FCA) has issued a warning about the risks of investing in unregulated mini-bonds and loan notes, following the failure of Woodville Consultants Ltd. The FCA emphasizes that these investments are unsuitable for most retail investors.
The Securities And Exchange Commission Proposed Regulation Crypto Assets For Certain Investment-Contract Transactions Involving Crypto Assets
On August 18, 2026, the Securities and Exchange Commission proposed Regulation Crypto Assets for certain investment-contract transactions involving crypto assets. Regulation Crypto Assets, Securities Act Release No. 33-11434, Exchange Act Release No. 34-106150, File No. S7-2026-27 (proposed Aug. 18, 2026). The proposal would create two Securities Act section 5 exemptions, a Commission safe harbor for ending investment-contract status, and state-registration preemption for defined purchasers.
Panama VASP/PSAV Law Status
As at 19 August 2026, Panama did not have a dedicated VASP/PSAV law in force. The former Project of Law 697 was declared entirely inexequible by the Supreme Court in 2023, while the current Project of Law 326 remained in legislative committee/subcommittee proceedings.
Costa Rica VASP Registration under Law No. 10961
Costa Rica enacted Law No. 10961 to add article 15 quater to Law No. 7786. The provision places virtual asset service providers under SUGEF for AML/CFT/CPF registration and supervision. The questions presented are whether SUGEF registration was publicly available on 19 August 2026, when the law commences, which services it covers, and what territorial, implementation, process, and sanction consequences follow. The analysis assumes a prospective provider that may serve customers in Costa Rica.
FMA Sanction of Bitpanda GmbH under MiCAR
On 14 August 2026, Austria’s Financial Market Authority published a final €70,000 administrative penalty against Bitpanda GmbH for MiCA white-paper and marketing breaches.
EU Cyber Resilience Act Vulnerability Reporting Obligations Apply from 11 September 2026
From 11 September 2026, manufacturers of products with digital elements must report actively exploited vulnerabilities and severe security incidents under Article 14 of Regulation (EU) 2024/2847 (the EU Cyber Resilience Act). An early warning must reach ENISA's Single Reporting Platform within 24 hours; a full notification within 72 hours.
Hungary Repeals Mandatory Crypto-Asset Conversion Validation Regime, Act XXXVIII of 2026
Hungary's National Assembly enacted Act XXXVIII of 2026, abolishing the mandatory crypto-asset conversion validation regime in force since 1 July 2025. The government cited direct conflict with Regulation (EU) 2023/1114 (MiCA). The law passed 143 votes to 46 and takes effect eight days after publication in the Magyar Kozlony.
ESMA Q&A 2883: MiCA Does Not Regulate Cryptoasset Lending, 18 June 2026
ESMA published Q&A 2883 on 18 June 2026, confirming that Regulation (EU) 2023/1114 (MiCA) does not regulate cryptoasset lending and borrowing as specific crypto-asset activities, per Recital 94. CASPs offering lending programmes remain subject to MiCA's general conduct obligations. Certain lending arrangements may trigger AIFMD authorisation requirements.
CSSF Publishes New MiCA Regulations for Crypto-Assets
The CSSF has issued new Commission Delegated and Implementing Regulations under MiCA, affecting crypto-asset service providers and issuers of asset-referenced and e-money tokens.
FCA fines and bans former SVS Securities CEO Demetrios Hadjigeorgiou
The Financial Conduct Authority has fined Demetrios Hadjigeorgiou £56,400 and banned him from senior management positions in financial services due to failures in managing SVS Securities Plc.
AMF Issues Warning on Investment Scams Targeting Crypto-Asset Investors
The AMF warns the public about increasing scams involving fake news articles promoting dubious investment schemes, particularly in crypto-assets.
Personal Data Processing by AI under EU Law
How does EU law treat the processing of personal data by artificial-intelligence systems, particularly under Regulation (EU) 2016/679 (GDPR) and Regulation (EU) 2024/1689 (AI Act), and how does the answer change across training, deployment and sector-specific use cases?
White House Hosts Crypto and Prediction Market Summit as CFTC Invokes Emergency Authority, August 2026
On 19 August 2026, President Donald Trump hosted cryptocurrency and prediction market executives at the White House alongside SEC Chair Paul Atkins and CFTC officials, one day before the CFTC's inaugural Innovation Advisory Committee session on crypto, prediction markets, and AI. On 11 August 2026, the CFTC separately invoked emergency authority under Section 8a(9) of the Commodity Exchange Act, ordering a prediction market exchange to continue operating after New York state sought a restraining order against the platform. The SEC also postponed a vote on Regulation Crypto and staff issued a no-action letter on tokenized fund custody.
FCA Leads First Enforcement Operation Against Illegal Peer-to-Peer Crypto Trading, 22 April 2026
On 22 April 2026, the Financial Conduct Authority conducted its first multi-agency enforcement operation against illegal peer-to-peer crypto trading in the UK, inspecting 8 London premises alongside HM Revenue and Customs and the South West Regional Organised Crime Unit. The FCA served cease and desist letters at each site and confirmed that no peer-to-peer crypto businesses are currently FCA-registered to operate in the UK, making all commercial peer-to-peer crypto exchange activity per se non-compliant. Evidence gathered supports ongoing criminal investigations.
Australia's Digital Assets Framework Act 2026 Mandates AFSL for Exchanges and Custody Platforms
The Corporations Amendment (Digital Assets Framework) Act 2026 passed Australia's Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and commences on 9 April 2027. The Act creates two regulated categories under the Corporations Act 2001 (Cth): Digital Asset Platforms and Tokenised Custody Platforms. Both must obtain an Australian Financial Services Licence from ASIC. A statutory trust structure protects client digital assets in the event of operator insolvency, bringing exchanges and custody providers under obligations equivalent to those applied to brokers and fund managers.
EDPB Finalises Blockchain GDPR Guidelines and Launches Anonymisation Consultation, 7 July 2026
On 7 July 2026, the European Data Protection Board adopted version 2.0 of Guidelines 02/2025 on the processing of personal data through blockchain technologies, finalising the text after a public consultation in April 2025. The EDPB simultaneously adopted Draft Guidelines 02/2026 on anonymisation, open for consultation until 30 October 2026, replacing Opinion 05/2014 on Anonymisation Techniques. The finalised blockchain guidelines apply GDPR obligations to both public and permissioned chains; the draft anonymisation guidelines introduce a relative identifiability standard derived from Case C-582/14 (Breyer).
EU AI Office Activates Full Enforcement Powers for GPAI Model Providers, 2 August 2026
On 2 August 2026, the European AI Office gained full enforcement authority against general-purpose AI (GPAI) model providers under Regulation (EU) 2024/1689. The Office may now investigate GPAI providers, demand technical documentation, require corrective measures, and impose fines of up to the higher of EUR 15 million or 3 per cent of worldwide annual turnover. The prohibited practices ban, covering social scoring and real-time remote biometric identification in public spaces, has been in force since 2 February 2025; maximum penalty authority over those prohibitions activated on the same date.
FTC Proposed Policy Statement Treats AI Output Steering as Deception Under 15 U.S.C. Section 45
On 1 July 2026, the Federal Trade Commission issued a proposed policy statement asserting that AI systems configured to steer outputs toward undisclosed ideological or commercial objectives likely violate Section 5 of the FTC Act as deceptive practices. The statement distinguishes deliberate steering from AI hallucinations and asserts that state accuracy-alteration mandates may face implied federal preemption. The public comment period closed 31 July 2026.
BitMEX Announces Permanent Closure of Cryptocurrency Exchange on 23 September 2026
On 23 July 2026, BitMEX published an official notice announcing the permanent closure of its cryptocurrency exchange on 23 September 2026 at 04:00 UTC. New account registrations ceased immediately. From 26 August 2026, users may only reduce existing positions. BitMEX previously settled US Department of Justice and Commodity Futures Trading Commission charges; the 2026 closure is a voluntary commercial decision, not a regulatory directive.
Ireland Gambling Regulation Act 2024 Part 4 Advertising Restrictions Await Ministerial Commencement
Part 4 (sections 139 to 165) of the Gambling Regulation Act 2024 (No. 35 of 2024) enacts advertising, sponsorship, and inducement restrictions on all licensed gambling operators in Ireland, including a broadcast watershed, a ban on child-targeted gambling advertising, and restrictions on deposit-conditioned inducements. Part 4 has not yet been commenced by ministerial order. The Gambling Regulatory Authority of Ireland began issuing remote betting licences from 1 July 2026.
Colorado Department of Law Files Proposed ADMT and Chatbot Safety Rules on 11 August 2026
On 11 August 2026, the Colorado Department of Law filed proposed rules implementing the Automated Decision-Making Technology Act and the Conversational Artificial Intelligence Service Operator Requirements Act. Both statutes take effect on 1 January 2027. The proposed rules detail consumer disclosure requirements, opt-out procedures, age-assurance obligations for minor users, and annual reporting duties. The public comment period closes 26 October 2026.
EU Instant Euro Payments
Instant euro payments are now a central part of the EU payments framework, bringing faster execution, price parity, payee verification and new access rules for payment service providers. This article examines the binding requirements, key implementation deadlines and practical limits of the regime, while distinguishing the law itself from simplified public descriptions of how the system works.
South Africa CASP Licensing
Under South African law: When must a crypto-asset service provider obtain authorisation from the Financial Sector Conduct Authority, or FSCA? What category and product authorisations are likely to be required? What transitional exemptions remain relevant? When must the provider register with the Financial Intelligence Centre, or FIC? What ongoing conduct, competence, operational, AML/CFT, payment, and cross-border requirements apply?
FTC Issues Proposed Policy Statement on AI Accuracy and Output Steering in July 2026
On 1 July 2026, the Federal Trade Commission voted 2-0 to publish a proposed policy statement in the Federal Register describing how AI companies that configure their systems to suppress accuracy or steer outputs toward undisclosed objectives may violate Section 5 of the FTC Act. The statement applies established deceptive-practices doctrine to AI output manipulation. The public comment period closed 31 July 2026.
MiCA Transitional Period Expires 1 July 2026 as ESMA Calls on Unauthorised CASPs to Wind Down
The Markets in Crypto-Assets Regulation transitional arrangement under Article 143 of Regulation (EU) 2023/1114 expired on 1 July 2026. Any entity providing crypto-asset services to EU clients without a MiCA authorisation, except as Articles 60 and 61 allow, is now in breach of EU law and must cease operations. ESMA issued a public statement on 23 June 2026 (ESMA75-113276571-1710) setting out expectations for how non-authorised providers must wind down activities and protect investors.
Ireland Gambling Regulation Act 2024 Advertising Restrictions Pending Ministerial Commencement
Ireland's Gambling Regulation Act 2024 (No. 35 of 2024) contains wide restrictions on gambling advertising and sponsorship, including prohibitions on advertising aimed at children, sponsorship of children's events, and merchandise bearing gambling branding directed at minors. The advertising and sponsorship provisions in Part 6 have not yet been commenced by ministerial order. S.I. No. 31/2026 commenced other provisions of the Act; the advertising restrictions remain outstanding pending a commencement date.
CSSF Updates MiCA Regulations for Crypto-Asset Service Providers
The CSSF has updated its documentation on the Markets in Crypto-Assets Regulation (MiCA), impacting CASPs and token issuers with new requirements and deadlines.
Senate Majority Leader Files Cloture on Digital Asset Market Clarity Act on 7 August 2026
On 7 August 2026, Senate Majority Leader John Thune filed a cloture motion on the motion to proceed to H.R. 3633, the Digital Asset Market Clarity Act (CLARITY Act), advancing the bill toward a Senate floor vote. The CLARITY Act passed the Senate Banking Committee 15-9 in May 2026 and would create a joint SEC-CFTC structure assigning CFTC jurisdiction over digital commodities and SEC jurisdiction over digital securities.
CNIL and CIANum Publish Exploratory Note on Agentic AI and Personal Data on 20 July 2026
On 20 July 2026, France's CNIL and the Conseil de l'IA et du Numerique (CIANum) jointly published an exploratory note on the GDPR risks raised by agentic AI systems. The note identifies how AI agents' autonomous cross-service data access, persistent memory retention, and capacity to act on users' behalf create tensions with GDPR purpose limitation, data minimisation, and controller identification rules under Articles 5, 24, and 28.
FCA bans Paul Taylor and Esmeralda Toni for misconduct
The Financial Conduct Authority has banned Paul Taylor and Esmeralda Toni for serious misconduct involving false statements during acquisitions. Taylor faces a £489,000 fine, while Toni is fined £121,200.
Virtual and Digital Assets in Nigeria: Regulatory Perimeter, Approval Status and Market-Entry Sequence
Nigeria now regulates digital-asset businesses through overlapping SEC, CBN, anti-money-laundering, tax and national-security mandates. The question presented is which approvals and duties apply to exchanges, stablecoin issuers and infrastructure providers, and what SEC incubation or CBN sandbox admission permits. The supplied company metrics are attributed to Quidax. The analysis assumes that each foreign market requires its own legal assessment.
Grounding marketing findings in the text of the rules
Licentium Atlas reviews crypto and financial marketing copy before anyone publishes it. A compliance officer or a marketing lead pastes the text, picks the target market, and receives findings ranked by severity, a risk score, the disclosures the copy is missing, and a safer rewrite. A standard review takes one to two minutes. Images, videos and whitepapers can be attached to the same review.
Building a regulatory change monitor: what broke, and what it taught us
Horizon watches official regulator publications and tells compliance teams when something changes. On 13 August 2026 it monitored 141 pages across 53 authorities in 20 jurisdictions: the European Union institutions, the United Kingdom, and 18 EU member states.
How accurate is a legal AI that answers only by quoting the law?
Licentium Compass answers questions on financial, crypto and artificial-intelligence regulation by quoting the legislation itself. Each statement in an answer carries a citation to a numbered article of a named act. Before a reader sees anything, a verifier compares every quoted passage character by character against the stored provision text and discards any quotation that does not match exactly.
Ukraine's Virtual Assets Bill: What the First-Reading Text of № 10225-д Actually Says
Ukraine's virtual assets bill № 10225-д heads to its second reading. We break down the first-reading text: the MiCA-style "On Virtual Asset Markets" law, provider authorisation, and the 18% + 5% tax regime with a 5% transitional rate.
Законопроєкт про віртуальні активи: що насправді містить текст № 10225-д, прийнятий у першому читанні
Законопроєкт № 10225-д готується до другого читання. Розбираємо текст першого читання: закон «Про ринки віртуальних активів» у форматі MiCA, авторизація постачальників, податок 18% + 5% і пільгова ставка 5%.
MLR Registration and the FCA Cryptoasset Gateway to 25 October 2027
This matter concerns the transition of a United Kingdom cryptoasset business from FCA registration under the Money Laundering Regulations 2017 to Part 4A permission under the Financial Services and Markets Act 2000. The question is whether MLR registration gives conversion, grandfathering, priority, or a right to continue after 25 October 2027, and what an affected firm should do before the gateway closes. This analysis assumes an existing UK-facing cryptoasset business, no relevant Part 4A permission, and an intention to continue after commencement.
Matched-Category Analysis of the Hong Kong Stablecoin Issuer Route and the Singapore Digital Payment Token Service Route
This matter concerns whether current licensing data supports a commercial comparison between Hong Kong’s stablecoin issuer route and Singapore’s digital payment token service route. The question is whether the proposition remains legally accurate as of 12 August 2026. “Commercially useful” is assumed to mean useful for selecting a market-entry and operating model, not proof that either regulator is more permissive.
ESMA's 2026 Custody Resilience CSA and the Rules That Actually Bind
ESMA’s 2026 Common Supervisory Action is a coordinated national review of digital operational resilience in crypto-asset custody. It will test whether selected crypto-asset service providers can demonstrate effective controls across six announced workstreams. The legal questions are which requirements are binding, how national competent authorities may assess control effectiveness, and what consequences may follow from a deficiency. This analysis assumes that the firm is permitted under MiCA Article 59 to provide custody and administration within Article 3(1)(17).
Stablecoin regulation in the US, Hong Kong and Singapore
Stablecoin and digital-token regulation now combines market-entry authorization with continuous financial-crime controls in daily operations. The question is whether the United States’ proposed payment-stablecoin customer identification program, Hong Kong’s narrow first licensing round, and Singapore’s digital payment token (DPT) directory support a bank-like compliance characterization. They do, with material limits. The more accurate proposition is that compliance is moving beyond approval into continuous financial-institution-grade operations.
Ireland High Court Issues Practice Direction HC142 Restricting GenAI Use in Documents, 29 July 2026
The President of the Irish High Court issued Practice Direction HC142 on 29 July 2026, operative from 1 September 2026. All affidavits and witness statements filed in High Court civil proceedings after that date must carry a declaration confirming that generative AI was not used to generate their substantive content. Solicitors and barristers bear personal responsibility for the accuracy of all filed documents, and verifying AI output against a second AI tool does not satisfy the direction's requirements.
GSA Sets 27 August 2026 Deadline to Remove Anthropic Integrations After Partial Injunction
The U.S. General Services Administration has set 27 August 2026 as the deadline to remove all Anthropic system integrations from GSA platforms, following President Trump's 27 February 2026 directive banning Anthropic tools from federal use, a Northern California court's preliminary injunction blocking the ban, and the D.C. Circuit's denial of Anthropic's broader relief request. Federal contractors using Claude models in government-facing workflows must assess their compliance position before that deadline.
Delhi High Court Dismisses ANI Media Interim Injunction Against OpenAI, 24 July 2026
On 24 July 2026, Justice Amit Bansal of the Delhi High Court declined ANI Media's interim injunction application against OpenAI, holding on a prima facie basis that storage of copyrighted news content to train large language models falls within the fair dealing exception under Section 52(1)(a) of India's Copyright Act, 1957. The suit continues toward trial and represents the first substantive Indian judicial ruling on AI copyright liability.
FSB Issues 12 Sound Practices for Responsible AI Adoption; Final Report Due October 2026
The Financial Stability Board published a consultation report on 10 June 2026 setting out 12 nonbinding sound practices for responsible AI adoption by financial institutions. The practices address board-level AI governance, model risk management, human oversight, and specific challenges raised by generative and agentic AI. Consultation responses were published on 12 August 2026 and the final report is due in October 2026.
The Legal Perimeter for DeFi Vault Curators: Panama, BVI, and Cayman Islands
Under the laws of Panama, the British Virgin Islands and the Cayman Islands: When can a tokenised DeFi vault constitute a regulated collective-investment vehicle? When can a compensated “curator” with authority over collateral, portfolio composition, rebalancing, valuation or oracle sources, emergency controls, execution, wallets or keys constitute a regulated investment manager, fund functionary, investment-business provider, mutual-fund administrator, custodian or virtual-asset service provider?
EU Retail Investment Strategy: The 2026 Compromise on Value for Money, Inducements, Advice, Marketing and PRIIPs
What operational and compliance changes should EU investment firms, credit institutions providing MiFID services, insurance undertakings and intermediaries, UCITS management companies, AIFMs, and PRIIPs manufacturers, advisers and sellers prepare for under the Council’s final Retail Investment Strategy compromise texts, while distinguishing those proposed changes from presently binding EU law?
CNIL publishes new AI guidelines and action plan for GDPR compliance
The CNIL has released new guidelines and an action plan for organizations developing AI systems, emphasizing GDPR compliance and privacy protection.
Munich Regional Court Rules Suno's AI Music Training and Outputs Infringed Copyright, 31 July 2026
On 31 July 2026, the Munich Regional Court I (Landgericht München I, case 42 O 763/25) largely granted GEMA's claims against Suno, the provider of an AI music generator, for an injunction, information and damages concerning six musical works. It found infringement in the memorisation of the works in models stored on servers in Germany, in offering the model and in its outputs, and applied US law to the training carried out in the United States, holding that fair use did not cover it.
Canada's OSFI Issues 2026 Bulletin on Generative and Agentic AI Risks for Financial Institutions
Canada's Office of the Superintendent of Financial Institutions has issued a Technology Risk Bulletin addressing risks that generative and agentic artificial intelligence systems pose to federally regulated financial institutions. The bulletin identifies hallucination, autonomous code deployment, data leakage, and third-party concentration risk as primary threats. It maps these risks to existing OSFI binding guidelines: B-13 on technology and cyber risk, E-21 on operational resilience, and B-10 on third-party risk.
Nigeria Revenue Service Releases Virtual Asset Taxation Guidelines on 31 July 2026
On 31 July 2026, the Nigeria Revenue Service released Information Circular No. 2026/21, establishing mandatory tax treatment for cryptocurrencies, stablecoins, non-fungible tokens, and decentralised finance transactions. The circular imposes a 7.5% value added tax on virtual asset services, 1.5% stamp duty on token conversions, and income tax on disposal gains and staking or mining rewards. The measures align with the Nigeria Tax Act, 2025 and the Nigeria Tax Administration Act, 2025.
The Token Is Not the Title (Until the Law Says It Is)
Tokenisation uses a digital record to issue, transfer, evidence, or reference a legal position connected with an asset, fund, entity, or obligor. The question is which structures give the holder title, a registered entitlement, an intermediary property interest, an entity interest, an issuer claim, or only a code-defined position under the laws of the United States, the European Union and Germany, England and Wales, Switzerland, Singapore, Hong Kong, the Dubai International Financial Centre, and Abu Dhabi Global Market.
What Is Your Token? Crypto Asset Classification Across Nine Jurisdictions
Tokenized real-world assets place conventional legal rights on, or beside, distributed-ledger records. The question is how eight asset families should be classified across selected jurisdictions as of 7 August 2026. Those families are public debt, credit, pooled investments, equity, commodities, real estate, fiat-reference instruments, and protocol receipts. The jurisdictions are the United States, European Union, United Kingdom, Switzerland, Singapore, Hong Kong, Japan, ADGM, and Dubai.
AFM and DNB clarify supervisory roles under MiCAR in the Netherlands
The Dutch Authority for the Financial Markets and De Nederlandsche Bank clarified their roles under MiCAR, effective late 2024, for crypto-asset service providers and stablecoin issuers.
EBA updates authorization requirements for ARTs and EMTs under MiCAR
The European Banking Authority has published new guidelines for issuers of asset-referenced tokens and electronic money tokens under MiCAR, detailing necessary authorizations and technical standards.
ESMA updates on Markets in Crypto-Assets Regulation implementation
The European Securities and Markets Authority has updated the implementation status of the Markets in Crypto-Assets Regulation, which establishes EU rules for crypto-assets, binding crypto-asset service providers.
AFM Reiterates Supervision of Crypto-Asset Service Providers Under MiCAR
The AFM has emphasized that crypto-asset service providers must obtain a license or notification to legally operate in the EU under MiCAR.
EBA Outlines 2026 Priorities for Digital Finance Sector
The European Banking Authority has set priorities for 2026, focusing on technological capacity in digital finance, including AI and crypto-assets.
European Commission establishes governance for AI Act enforcement
The European Commission has detailed the governance architecture for the enforcement of the AI Act, requiring Member States to designate national competent authorities by 2 August 2025.
ESMA Issues New Q&As on MiCA for Crypto-Asset Service Providers
ESMA has published new questions and answers regarding MiCA's application to crypto-asset service providers, clarifying compliance obligations for lending services and advisory practices.
European Commission establishes AI Office to enforce AI Act
The European AI Office has been established to support the AI Act's implementation, focusing on general-purpose AI compliance and fostering trustworthy AI across the EU.
European Commission publishes General-Purpose AI code of practice
The European Commission published a voluntary General-Purpose AI code of practice on July 10, 2025, to assist providers in complying with the EU AI Act's legal obligations.
SEC Commissioner Peirce Warns Crypto Vault and Lending Operators on Securities Law Scope, July 2026
On 22 July 2026, SEC Commissioner Hester M. Peirce issued a statement cautioning that executing securities-law-covered activities on a blockchain does not remove them from the SEC's jurisdiction. Titled 'Headstands and Summervaults,' the statement addresses crypto vaults that use smart contracts to allocate user assets into yield-generating strategies including staking and lending, and warns operators that these structures may constitute investment contracts under federal securities law.
Ninth Circuit Declines Broad CFAA Reading for Agentic AI Access, August 2026
On 4 August 2026, the U.S. Court of Appeals for the Ninth Circuit issued its opinion in Amazon.com Services, LLC v. Perplexity AI, Inc., No. 26-1444. The court declined to hold that Perplexity's Comet AI agent violated 18 U.S.C. § 1030(a)(2) of the Computer Fraud and Abuse Act by accessing Amazon.com. Applying the rule of lenity, the court construed the statute's access provisions narrowly on the facts presented and declined to establish a broader legal regime governing agentic AI.
Singapore IMDA Issues Voluntary Transparency Guidelines for Generative AI Chatbots, 20 July 2026
On 20 July 2026, Singapore's Infocomm Media Development Authority (IMDA) published voluntary Transparency Guidelines for Generative AI Chatbots. The guidelines introduce a chatbot information card as a standardised disclosure format presenting AI capabilities, limitations, safety measures, data collection practices, and user reporting channels in plain language. Companies including Google, DBS, OCBC, and Singapore Airlines have indicated they will reference the guidelines. IMDA describes the initiative as among the first of its kind globally.
AI in Arbitration: Frameworks, Applications, and Challenges
Artificial Intelligence (AI) is being integrated into arbitration as a tool to enhance efficiency and decision-making. In broad terms, AI refers to computer systems capable of tasks that typically require human intelligence, such as learning, pattern recognition, and natural language processing. In arbitration, AI’s role so far has been largely assistive – helping arbitrators and parties manage complex information and streamline procedures.
Irish High Court Practice Direction Sets AI Accuracy Obligations for Court Filings, 2026
The Irish High Court issued a practice direction in 2026 requiring practitioners to review and verify all generative AI-generated content before filing. The direction applies across High Court proceedings and establishes a supervisory duty on the responsible lawyer, citing risks of AI-generated inaccuracies including fabricated case citations.
Ninth Circuit Finds AI Agent Data Retrieval Is Not CFAA Server Access, August 2026
On August 4, 2026, the Ninth Circuit vacated a preliminary injunction against Perplexity AI in Amazon.com Services, LLC v. Perplexity AI, No. 26-1444. The court held that Amazon is unlikely to show Perplexity accessed its servers under 18 U.S.C. § 1030 because the data passed through a user's device before reaching Perplexity, not from Amazon's computers directly.
UK CMA Issues Guidance on Consumer Law Compliance for AI Agent Deployments, March 2026
The UK Competition and Markets Authority published non-statutory guidance in March 2026 on how existing consumer protection law applies when businesses deploy AI agents to interact with customers. The CMA holds businesses accountable for AI agent conduct as they would be for employee conduct, and may impose fines up to 10% of worldwide turnover for non-compliance under the Digital Markets, Competition and Consumers Act 2024.
Ontario Securities Commission Reports 25% Crypto Ownership Among Canadians, July 2026
The Ontario Securities Commission released its 2026 crypto asset survey on July 28, 2026, finding that 25% of Canadians own crypto assets and 59% are aware of them. Half of crypto owners reported checking platform registration status before use, up from 38% in 2023, a metric the OSC cited as evidence of improving investor protection awareness.
OCC Grants Circle Final Charter for First National Digital Currency Bank N.A., 9 July 2026
The Office of the Comptroller of the Currency granted final approval on 9 July 2026 for Circle Internet Group to establish First National Digital Currency Bank, N.A., operating as Circle National Trust. The bank opened 24 July 2026 under direct OCC oversight and will manage USDC reserves on a directed basis, act as collateral trustee for USDC holders, and provide digital asset custody services to Circle affiliates.
Manitoba Enacts Public Sector AI and Cybersecurity Governance Act June 2026
On 1 June 2026, Bill 51, The Public Sector Artificial Intelligence and Cybersecurity Governance Act (S.M. 2026, c. 43), received Royal Assent in Manitoba, Canada. The Act mandates transparency, accountability structures, and cybersecurity incident reporting for public sector entities using AI systems. Substantive obligations take effect only through regulations yet to be made.
Singapore PDPC Issues Advisory Guidelines on Personal Data in Generative AI, 20 July 2026
On 20 July 2026, Singapore's Personal Data Protection Commission published its Advisory Guidelines on Use of Personal Data in Generative AI under the Personal Data Protection Act 2012. The guidelines address PDPA obligations at three stages of generative AI deployment: training data collection and use, processing of personal data as model inputs, and personal data present in or generated by AI outputs.
Canadian Privacy Regulators Find OpenAI ChatGPT Non-Compliant Under PIPEDA May 2026
On 6 May 2026, Canada's Office of the Privacy Commissioner and its counterparts in Quebec, British Columbia, and Alberta published PIPEDA Findings #2026-002: the joint investigation of OpenAI OPCO LLC. The regulators concluded that OpenAI's collection of personal data through web scraping and user interactions to train ChatGPT lacked valid consent under federal and provincial privacy statutes.
UK Wholesale Digital Markets Champion Publishes Tokenised Finance Roadmap, 13 July 2026
On 13 July 2026, HM Treasury's Wholesale Digital Markets Champion published the first report of a 54-institution taskforce calling for accelerated tokenisation of UK wholesale financial markets. Estimates by Barclays and PwC put gross annual benefits to the UK economy at GBP 33 billion, with GBP 14 billion in additional tax receipts. The taskforce's immediate priority is tokenised repo, followed by primary issuance, collateral, money market funds, and digital payment rails.
CFTC Proposes Conflicts-of-Interest Rules for Vertically Integrated Derivatives Registrants, 30 July 2026
On 30 July 2026, the CFTC published a Notice of Proposed Rulemaking targeting conflicts of interest among affiliated futures commission merchants, designated contract markets, swap execution facilities, and derivatives clearing organisations. The proposal targets vertically integrated structures where a single ownership group controls trading, clearing, and market-making functions. Public comments are open for 60 days following Federal Register publication.
South Africa Proposes Crypto Assets Manual for Cross-Border Transfers Under Exchange Control, August 2026
On 3 August 2026, South Africa's National Treasury and the South African Reserve Bank (SARB) published the Draft Crypto Assets Manual for Cross-Border Activities for public comment, open until 30 September 2026. The manual would require all cross-border crypto transfers to be routed through an authorised dealer and reported to SARB's Financial Surveillance Department. It follows draft Capital Flow Management Regulations of 17 April 2026, which first brought crypto assets into South Africa's exchange control regime.
US Federal Courts Split on CFTC Preemption of State Gambling Laws for Prediction Markets, July 2026
US federal courts produced conflicting rulings in July 2026 on whether the Commodity Exchange Act (CEA) preempts state gambling statutes as applied to CFTC-regulated event contracts. On 27 July 2026, US District Judge Katherine Menendez granted a preliminary injunction blocking Minnesota from enforcing SF 3432 against Kalshi and Polymarket US. The Third Circuit, Sixth Circuit, and Ninth Circuit are handling parallel proceedings with no consistent outcome on the merits.
CFTC Sues New York Over Prediction Markets; US Courts Divide on CEA Preemption, 2026
The U.S. Commodity Futures Trading Commission filed suit against New York seeking to enjoin state-level regulation of CFTC-licensed prediction market contracts. US circuit courts have divided on whether the Commodity Exchange Act's exclusive jurisdiction provision preempts state consumer protection and gaming laws as applied to prediction markets operating on CFTC-designated contract markets.
UK Wholesale Digital Markets Champion Publishes First Report on Tokenised Financial Markets, July 2026
Chris Woolard CBE, HM Treasury's Wholesale Digital Markets Champion, delivered the inaugural sector report to the Chancellor in July 2026. The report proposes a cross-industry programme to tokenise UK wholesale financial markets, convening 54 firms across nine action groups covering primary issuance, tokenised repo and collateral, tokenised funds, payment rails, legal certainty, and operational resilience.
South Africa SARB Publishes Draft Crypto Assets Manual for Cross-Border Transactions, 2026
The South African Reserve Bank (SARB) and National Treasury published a Draft Crypto Assets Manual for cross-border activities alongside proposed Capital Flow Management Regulations in 2026. The draft establishes an Authorised Crypto Asset Service Provider designation process, cross-border transaction permissions, and reporting obligations to the SARB's Financial Surveillance Department. The public comment period closed 30 June 2026.
US Courts Split on Federal Preemption of State Laws over CFTC Prediction Markets, 2026
US federal courts have reached conflicting conclusions on whether the Commodity Exchange Act preempts state gaming and consumer-protection laws as applied to CFTC-regulated prediction markets. The CFTC filed a civil action against the State of Wisconsin, submitted amicus briefs in the Sixth Circuit and before the Massachusetts Supreme Judicial Court, and issued a Prediction Markets Advisory asserting exclusive federal jurisdiction over event contracts traded on designated contract markets.
UK Wholesale Digital Markets Champion Publishes First Tokenisation Report, July 2026
Chris Woolard CBE, HM Treasury's Wholesale Digital Markets Champion, published his inaugural report to the Chancellor on 13 July 2026, setting out a delivery roadmap for tokenisation of UK wholesale financial markets. The report creates nine Taskforce Action Groups covering primary issuance, secondary markets, collateral, and FMI and cash infrastructure, supported by groups on tax, legal, financial crime compliance and resilience. A cross-industry Taskforce with members from more than fifty firms will drive live end-to-end use cases over the following 12 months, starting with an end-to-end repo transaction.
CFTC Proposes Conflicts-of-Interest Rules for Affiliated Crypto Registrants, 2026
The Commodity Futures Trading Commission issued a Notice of Proposed Rulemaking targeting conflicts of interest arising from affiliations between CFTC-registered entities, including derivatives clearing organizations, designated contract markets, swap execution facilities, and futures commission merchants. The proposal establishes principles-based obligations for vertically integrated market structures and is open for public comment. The rulemaking directly affects crypto and digital asset firms that hold multiple CFTC registrations across affiliated entities.
Illinois Signs Frontier AI Safety Law Requiring Annual Audits, 6 July 2026
Illinois Governor JB Pritzker signed Senate Bill 315, the Artificial Intelligence Safety Measures Act, on 6 July 2026. The law targets developers of frontier AI models that generate more than $500 million in annual revenue and are trained using specified compute thresholds. It takes effect 1 January 2027 and mandates annual independent third-party audits, AI safety frameworks, incident reporting, and whistleblower protections, making Illinois the first US state to require independent safety audits for large AI developers.
EU AI Act Article 50 Transparency Obligations Apply from 2 August 2026
Starting 2 August 2026, providers and deployers of AI systems that interact with users, generate synthetic content, or use biometric categorisation must comply with the transparency obligations set out in Article 50 of Regulation (EU) 2024/1689. The European Commission published companion guidelines on 20 July 2026 to assist market participants with compliance. A grace period to 2 December 2026 applies to machine-readable marking for generative AI systems already on the market before that date.
ESMA proposes amendments to bilateral margin requirements for OTC derivatives
The European Supervisory Authorities have proposed amendments to simplify bilateral margin requirements for OTC derivatives, impacting entities below the €8 billion threshold.
FCA Announces Anthropic Support for Supercharged Sandbox Participants
The Financial Conduct Authority has confirmed that Anthropic will assist firms in the Supercharged Sandbox, enhancing AI development in financial services.
ESMA Overview of Digital Operational Resilience Act (DORA)
The European Securities and Markets Authority (ESMA) has detailed the Digital Operational Resilience Act (DORA), which enhances ICT security for financial entities, effective from 17 January 2025.
ESAs publish guide on DORA oversight activities
The European Supervisory Authorities have published a guide on oversight activities under DORA, aimed at helping entities prepare for upcoming requirements.
UK Government Proposes New Cryptoasset Regulations
The UK government has announced draft legislation to regulate cryptoassets, enhancing consumer protection and driving fintech growth.
EU publishes guidelines for general-purpose AI model providers under AI Act
The EU has published new guidelines clarifying obligations for providers of general-purpose AI models, effective 2 August 2025.
AMF Introduces Common Notification Form for Crypto-Asset Service Providers
The AMF has introduced a common notification form for crypto-asset service providers to comply with MiCA Regulation requirements.
AMF sanctions portfolio management company and executives for professional obligation breaches
The AMF's sanctions commission has imposed penalties on a portfolio management company and two of its executives for professional obligation breaches.
ICO updates guidance on AI and data protection
The UK Information Commissioner's Office has revised its guidance on AI and data protection to clarify fairness requirements following the Data (Use and Access) Act.
FCA announces new cryptoasset regulatory regime effective October 2027
The FCA has outlined its approach to a new regulatory regime for cryptoassets, effective 25 October 2027, requiring all cryptoasset firms to be authorized and supervised under the Financial Services and Markets Act (FSMA).
AMF updates doctrine for investment advisors under MiCA
The French Financial Markets Authority (AMF) has updated its doctrine regarding investment advisors to align with the EU Markets in Crypto-Assets Regulation (MiCA), affecting investment firms and financial service providers immediately.
CSSF Updates on MiCA Regulation for Crypto-Assets in Luxembourg
The CSSF has updated its webpage on the Markets in Crypto-Assets Regulation (MiCA), detailing requirements for crypto-asset service providers and issuers of asset-referenced and e-money tokens, with key deadlines set for 2024.
UK Government Issues Expression of Interest for AI Supercomputer Hosting
The UK government invites organizations to propose sites for the next AI supercomputer under its AIRR initiative, enhancing AI capabilities.
FCA Introduces Oversight Regime for Critical Third Parties in UK Financial Services
The FCA has launched a new oversight regime for critical third parties in the UK financial services sector to enhance operational resilience and manage systemic risks.
AMF Reminds DASPs of MiCA Transitional Period Deadline
The AMF has reminded Digital Asset Service Providers that the transitional period under MiCA ends on 1 July 2026, requiring them to obtain authorization as Crypto-Asset Service Providers to continue operations legally in France.
ESAs issue guide on DORA oversight activities
The European Supervisory Authorities published a guide on oversight activities under the Digital Operational Resilience Act, focusing on ICT risks from AI in the financial sector.
Pennsylvania HB 2711 Proposes State Regulation of Prediction Market Platforms, United States, 22 July 2026
On 22 July 2026, Representative Tarik Khan introduced Pennsylvania HB 2711 with 24 co-sponsors, proposing a state regulatory regime for prediction market platform operators. The bipartisan bill sets the minimum participation age at 21, restricts trading by persons holding material nonpublic information, and grants the Pennsylvania Attorney General enforcement authority including fines of up to $10,000 per violation and the power to ban non-compliant platforms.
South Korea Supreme Court Proposes Crypto Asset Seizure Rules Under Civil Enforcement Law, 2 July 2026
On 2 July 2026, the Supreme Court of Korea published draft amendments to the Civil Execution Rules establishing standardized procedures for court-ordered seizure and liquidation of virtual assets held on exchanges. The proposed rules, open for public comment until 11 August 2026, are scheduled to take effect on 1 October 2026 and would prohibit debtors from disposing of seized assets and allow courts to direct exchanges to execute liquidations.
New York AG Warns CLARITY Act Would Dilute State Crypto Fraud Enforcement Powers, United States, 28 July 2026
On 28 July 2026, New York Attorney General Letitia James submitted written testimony to the U.S. Senate opposing the Clarity for Payment Stablecoins, Commodities, and Digital Assets Act in its current form. James argues the bill would transfer primary digital asset oversight to the Commodity Futures Trading Commission while stripping state prosecutors of their principal tools for pursuing crypto fraud, and urges Congress to amend the bill to preserve concurrent state enforcement authority.
Stablecoins: Compliance, Rewards, DeFi, and Insolvency
Payment stablecoins are the enacted anchor. The FDIC proposal has limited institutional scope. Treasury supplies the main illicit-finance rules. The reward, DeFi, and safe-harbor provisions remain draft-dependent and have no force unless enacted.
Tokenization/Securities-Law Boundary
This analysis assumes possible issuance or distribution in the United States, European Union, United Kingdom, Switzerland, and Hong Kong as of August 2, 2026. No token terms, issuer domicile, investor class, governing law, property situs, venue, custodian, or settlement design were supplied.
AI Lending: Fair Lending and UDAAP Convergence
AI underwriting receives no federal exemption. The governing statutory elements remain technology-neutral, while complex models can increase the proof and controls needed for fair-lending, notice, accuracy, and deception compliance. Current CFPB ECOA policy emphasizes intentional discrimination and specific adverse-action reasons, not disparate impact. FTC exposure remains strongest for nonbank ECOA violations, unfair injury, and unsupported AI claims. Mortgage models retain separate FHA disparate-impact risk.
AI Copyright Litigation Is The Biggest Active Fight
Copyright is the best candidate for the largest active private-law dispute over generative AI. That assessment rests on four measurable features.
EU Digital Omnibus Regulation 2026/1744 Enters Into Force, Extending AI Act Compliance Timelines
Regulation (EU) 2026/1744 (the AI Digital Omnibus) entered into force on 27 July 2026, amending the EU AI Act to extend compliance timelines for high-risk AI systems. Operators covering Annex III sectors have until 2 December 2027 to meet Chapter III obligations. AI systems embedded in Annex I products have until 2 August 2028. The Omnibus cites CEN and CENELEC standardisation delays as justification for both extensions.
Senate Republicans Release Updated Digital Asset Market Clarity Act Text, 22 July 2026
On 22 July 2026, Senate Banking Digital Assets Subcommittee Chair Cynthia Lummis released updated text for the Digital Asset Market Clarity Act (H.R. 3633, 119th Congress). The bill proposes a Regulation Crypto exemption from SEC registration for ancillary digital assets, a commodity/security classification structure for digital assets, compliance obligations for centralised entities interacting with DeFi, and ethics restrictions on government officials holding digital assets. The text remains proposed legislation pending full Senate consideration.
FATF Publishes Targeted Report on DeFi Regulatory Challenges, 21 July 2026
On 21 July 2026, the Financial Action Task Force (FATF) published its Targeted Report on Regulatory Challenges from Decentralised Finance, updating the 2021 FATF Guidance on Virtual Assets and Virtual Asset Service Providers. The report finds that 132 of 143 surveyed jurisdictions have not implemented FATF Recommendation 15 in relation to qualifying DeFi arrangements, and that only two jurisdictions have licensed or registered a DeFi arrangement in practice. Total value locked in DeFi reached USD 86.64 billion as of 2026, an 85% increase since 2023.
California Digital Financial Assets Law Licensing Operative 1 July 2026
California's Digital Financial Assets Law (DFAL), codified at California Financial Code section 3101 et seq., reached its licensing operative date on 1 July 2026. Any person conducting digital financial asset business activity with or on behalf of a California resident (including exchanges, wallet custodians, kiosk operators, and transaction facilitators) must hold a licence from the California Department of Financial Protection and Innovation (DFPI) or have submitted a complete NMLS application. Unlicensed operation after 1 July 2026 constitutes a statutory violation subject to DFPI enforcement.
EU AI Act Article 50 Transparency: 2026 Implementation and Compliance Guide
Article 50 of the EU AI Act assigns disclosure duties to providers and deployers of certain AI systems. The question is which duties apply on August 2, 2026, what the official guidance and Code add, and what remains unsettled. This analysis assumes nonpersonal use with an EU territorial connection. It excludes exclusively military, defence, or national-security uses. It assumes no authorized law-enforcement exception. It states the law as of July 31, 2026.
Dubai VASP Licensing: Fresh Authorizations Signal Continued Regulatory Momentum
Dubai’s Virtual Assets Regulatory Authority records permissions for specified virtual-asset activities in Dubai outside the Dubai International Financial Centre. The question is whether “Dubai VASP licensing continues to show fresh authorization activity” is supported as at 31 July 2026, and what those records legally permit. This analysis treats VARA’s English register and entity pages as the current factual record. It distinguishes active full licences from non-operational in-principle approvals.
UK Crypto Authorisation: From Future Watching to Application Preparation
The United Kingdom has made legislation and principal FCA rules for a new authorisation regime covering specified cryptoasset activities. The question is whether firms should now prioritise application work, given the published dates and FCA pre-application warning. This analysis tests that proposition as at 31 July 2026. It assumes no firm-specific facts and addresses commercial cryptoasset services provided in or to the United Kingdom.
Regulation (EU) 2026/1744, the Digital Omnibus on AI, changes selected duties under the EU Artificial Intelligence Act
Regulation (EU) 2026/1744, the Digital Omnibus on AI, changes selected duties under the EU Artificial Intelligence Act. The question is whether the stated entry date, revised high-risk dates, small mid-cap support, and sandbox expansion are legally accurate.
UK and US Publish Parallel Stablecoin Rules in 2025 and 2026, Requiring Separate Authorisations
The United Kingdom and the United States each published stablecoin regulatory instruments in 2025 and 2026 that are structurally parallel but operationally distinct, requiring separate licensing in each jurisdiction. The UK regime under S.I. 2026/102 and FCA final rules takes effect from 25 October 2027. The US GENIUS Act, enacted on 18 July 2025, requires issuer authorisation no later than January 2027.
Industry Groups Urge US Senate Floor Consideration of the Digital Asset CLARITY Act, July 2026
On 24 July 2026, the Crypto Council for Innovation, the Blockchain Association and The Digital Chamber wrote to the Senate's majority and minority leaders urging floor consideration of the CLARITY Act (H.R. 3633), which passed the House in July 2025 and is on the Senate Legislative Calendar as Calendar No. 423. On 15 September 2026, the Senate did not invoke cloture on the motion to proceed to the bill, 49 to 50.
Vietnam Decree No. 284/2026/ND-CP Sets Fines for Crypto Asset Market Violations, Effective 1 September 2026
Vietnam's Government issued Decree No. 284/2026/ND-CP on 16 July 2026, setting administrative penalties for violations concerning crypto assets and the crypto asset market from 1 September 2026. Its fines are stated for organisations, up to VND 200 million, and an individual pays half. Providing services relating to crypto assets, or advertising or marketing relating to crypto assets, without a licence carries VND 180 million to VND 200 million, and a domestic investor that trades other than through a provider licensed by the Ministry of Finance faces VND 30 million to VND 50 million, half that for an individual.
Vietnam Issues Decree 284/2026 on Administrative Penalties for Crypto Asset Market Violations
Vietnam's Government issued Decree No. 284/2026/NĐ-CP prescribing administrative penalties for violations in the crypto asset market. The decree creates compliance exposure for offshore crypto exchanges serving Vietnamese users and for entities conducting activities in Vietnam's crypto sector without authorisation.
Top Jurisdictions for AI Companies: Where the Industry Is Actually Registered
Europe's best-known AI labs are often owned from Delaware. One Chinese lab briefly owned itself. A jurisdiction-by-jurisdiction guide to where AI companies are actually registered, and what it means.
Costa Rica as a Jurisdiction for Web3 Projects
Law No. 10,961 was enacted in June 2026, but the official SINALEVI amendment note states that the amendments to Law No. 7,786 enter into force on 2026-09-19. This guide separates: (i) law in force on 2026-07-28; (ii) readiness for the forthcoming virtual-asset-service-provider regime; and (iii) unresolved matters requiring final official text or implementing rules.
Bank of England Publishes Policy Statement and Draft Code for Systemic Stablecoins, June 2026
On 22 June 2026, the Bank of England published its policy statement on sterling-denominated systemic stablecoins and released a draft Code of Practice for comment by 22 September 2026. A temporary issuance guardrail of GBP 40 billion per stablecoin will apply on systemic designation. The Bank intends to finalise the Code of Practice by the end of 2026.
BoE and FCA Publish Joint Supervisory Approach for Systemic Stablecoin Issuers, June 2026
The Bank of England and the Financial Conduct Authority published a joint paper on 30 June 2026 setting out how supervisory responsibilities will be divided for stablecoin issuers that HM Treasury designates as systemic. The Bank holds prudential and financial stability oversight; the FCA retains conduct and consumer protection responsibilities. Co-ordination is governed by the Payments Memorandum of Understanding.
FCA Final Stablecoin Rules and BoE Systemic Draft Regime Published, UK, June 2026
The FCA published final rules for non-systemic UK-issued qualifying stablecoins on 30 June 2026, comprising Policy Statements PS26/10, PS26/12, and PS26/13. The Bank of England simultaneously issued its policy statement and draft Rulebook for systemic GBP-denominated stablecoin issuers. Authorisation applications open 30 September 2026; the mandatory regime takes effect 25 October 2027.
Hong Kong Police Arrest 991 in World Cup Illegal Betting Crackdown, July 2026
Hong Kong Police Force conducted territory-wide operations CROWBEAK and WINDSHIELD targeting illegal gambling linked to the 2026 FIFA World Cup, arresting 991 individuals and raiding 249 premises. Officers seized HK$365 million in betting records and HK$3 million in cash. Suspects face charges including bookmaking, facilitating bookmaking, and money laundering under the Gambling Ordinance and the Organized and Serious Crimes Ordinance.
AI Regulation Goes Operational: Five Global Developments
Five official measures with different legal force. It covers IOSCO supervision, Hong Kong SFC circulars, Singapore guidance, a UAE policy approval, and an EU amending regulation. The question is which measures bind a cross-border business on 24 July 2026. A second question is how each measure affects supervision, liability, and implementation. This analysis assumes no identified entity, licence, product, deployment, contract, or territorial nexus. Local status, operator role, product classification, use, placement date, and contract terms therefore control applicability.
SEC Commissioner Peirce Addresses Securities Law Application to Crypto Vaults, 22 July 2026
On 22 July 2026, SEC Commissioner Hester M. Peirce published a statement titled 'Headstands and Summervaults' addressing whether federal securities laws apply to on-chain crypto vault products. The statement distinguishes programmatic vaults governed by immutable smart contracts from managed vaults where a third party allocates user assets, and indicates that managed vaults may require registration under the Securities Act of 1933 and the Investment Company Act of 1940.
Celsius Network Founders to Pay $16.5 Million to Resolve FTC Charges, July 2026
The Federal Trade Commission announced on 20 July 2026 that Celsius Network Inc. former CEO Alexander Mashinsky and co-founders Shlomi Daniel Leon and Hanoch 'Nuke' Goldstein will pay a combined $16.5 million to resolve consumer deception charges. The settlement imposes permanent bans on specified crypto commercial activities on all three executives. The FTC's complaint in this matter was originally filed in July 2023.
Spain's MiCAR Grandfathering Period Expired 1 July 2026 for Crypto-Asset Service Providers
The transitional period under Article 143(3) of Regulation (EU) 2023/1114 (MiCAR) expired on 1 July 2026 in Spain, ending the right of previously registered crypto-asset service providers to continue operating without a full MiCA authorisation. Spain selected a 12-month transitional period, the shortest permissible under MiCAR. Providers without authorisation must now cease offering crypto-asset services or face enforcement action by the CNMV.
MiCAR Grandfathering Period Expired on 1 July 2026, All EU CASPs Now Require Authorisation
The MiCAR grandfathering period expired on 1 July 2026, ending the transitional window that allowed crypto-asset service providers operating under national laws before 30 December 2024 to continue without a MiCA licence. Any CASP without authorisation must now cease providing services to EU clients or face breach of EU law.
SEC Commissioner Peirce: Crypto Vaults and On-Chain Lending May Trigger Federal Securities Laws
On 22 July 2026, SEC Commissioner Hester M. Peirce published a statement noting that crypto vault products and on-chain lending strategies that fall within the scope of the federal securities laws remain subject to those laws regardless of whether the activity is conducted on-chain, and suggesting that parties involved in managing vaults may want to analyse whether their activities implicate those laws.
FTC Orders Celsius Network Founders to Pay $16.5 Million, July 2026
A US federal court ordered Celsius Network co-founders Alex Mashinsky, Shlomi Daniel Leon, and Hanoch Goldstein to pay a combined $16.5 million to resolve Federal Trade Commission charges of deceptive and unfair trade practices. The FTC alleged that Celsius falsely represented deposit safety, a $750 million insurance policy, and interest rates of up to 18% annually on its Earn product. The settlement prohibits the founders from marketing crypto deposit or withdrawal products.
Spain Closes MiCAR Transitional Period for Crypto-Asset Service Providers, 30 June 2026
Spain's MiCAR transitional period under Article 143(6) of Regulation (EU) 2023/1114 expired on 30 June 2026. CASPs that operated under Spain's pre-MiCA advertising registration or VASP registration without CNMV authorisation must now cease providing crypto-asset services to Spanish customers or face regulatory breach. Spain was the only EU Member State to apply the full 18-month grandfathering period permitted under MiCAR.
Greece Adopts AI Act National Implementation Law 5321/2026, 16 July 2026
The Hellenic Parliament adopted Law 5321/2026 on 16 July 2026, designating national competent authorities and establishing enforcement and sandboxing procedures under Regulation (EU) 2024/1689 (the EU AI Act). The Hellenic Data Protection Authority is the principal market surveillance authority for prohibited AI practices and most high-risk AI systems. Greece is among the first EU Member States to enact national implementation legislation under the AI Act.
SEC Commissioner Peirce Warns Crypto Vaults May Trigger US Securities Laws, July 2026
SEC Commissioner Hester M. Peirce issued a statement on 22 July 2026 warning that crypto vault products and on-chain lending strategies may fall within US federal securities laws. The statement identifies discretionary human control over investor asset allocation as the key factor triggering Howey analysis. Vaults currently hold over $8 billion in assets. Coinbase and Robinhood have integrated vault products offering stablecoin yield to customers. Peirce invited developers to engage with the SEC before deploying new vault products.
UK and US Treasury Publish Joint Stablecoin and Digital Asset Recommendations, July 2026
On 14 July 2026, HM Treasury and the U.S. Department of the Treasury jointly released the first ten recommendations of the Transatlantic Taskforce for Markets of the Future. The recommendations address stablecoin use in cross-border payments and settlement, tokenised asset activity, and supervisory cooperation between the UK and United States. They signal coordinated regulatory intent on digital asset market development.
Illinois Enacts AI Safety Measures Act Mandating Annual Frontier AI Audits, July 2026
On July 6, 2026, Illinois Governor JB Pritzker signed the Artificial Intelligence Safety Measures Act (SB3312) into law. Illinois is the first U.S. state to require annual independent third-party audits of large frontier AI developers. The Act establishes a catastrophic risk assessment framework, incident reporting obligations, and civil penalties, with an effective date of January 1, 2027.
European Commission Publishes Final AI Transparency Guidelines Under Article 50, August 2026
On 20 July 2026, the European Commission adopted final guidelines implementing the Article 50 transparency obligations of Regulation (EU) 2024/1689. The guidelines specify disclosure requirements for AI system providers and deployers and apply from 2 August 2026. Affected businesses must ensure users know when they interact with AI systems, deepfakes, or biometric categorisation systems.
CMA Publishes Guidance on Agentic AI Consumer Law Obligations Under DMCCA 2024, March 2026
On 9 March 2026, the Competition and Markets Authority published practical guidance on the consumer law obligations that apply to agentic AI deployment under the Digital Markets, Competition and Consumers Act 2024. The guidance identifies transparency and non-deception requirements, establishing that businesses must not mislead consumers about whether they are dealing with an AI agent. The CMA can impose fines of up to 10 per cent of global annual turnover for breaches of the DMCCA's consumer protection provisions without requiring a court order.
Alberta iGaming Market Opens July 2026 Under AGLC SRIG Privacy and Compliance Standards
Alberta's regulated private-operator iGaming market launched on 13 July 2026 with 22 registered operators approved by the Alberta Gaming Liquor and Cannabis authority. Operators must comply with the AGLC Standards and Requirements for Internet Gaming, issued in January and February 2026, the iGaming Alberta Act, and the Personal Information Protection Act (Alberta). Privacy obligations shape every stage of the player lifecycle from initial identity verification through self-exclusion management.
ASIC Extends No-Action Position for Digital Asset Businesses to 30 September 2026
The Australian Securities and Investments Commission extended its sector-wide no-action position for digital asset businesses required to hold an Australian Financial Services licence, moving the application deadline from 30 June 2026 to 30 September 2026. ASIC also broadened scope to cover authorised representative and intermediary authorisation arrangements. Operators that miss the new deadline face civil and criminal penalties including fines of up to 10 per cent of annual turnover.
Circle Receives Final OCC Approval to Establish National Trust Bank for USDC Custody, July 2026
On 10 July 2026, the U.S. Office of the Comptroller of the Currency granted Circle Internet Group final approval to charter Circle National Trust Bank, a federally supervised trust institution. The bank will hold USDC reserves, provide fiduciary digital-asset custody, and offer direct institutional custody services. Circle applied in June 2025, received conditional approval in December 2025, and obtained final charter approval on 10 July 2026.
Crypto Vaults and Lending Strategies Under U.S. Federal Securities Law
Commissioner Hester M. Peirce’s July 22, 2026 statement does not establish binding law, but it identifies the principal federal securities-law questions raised by crypto vaults and onchain lending strategies. This analysis examines when vault interests, lending claims, receipt tokens, and related service-provider activities may trigger the Securities Act, Exchange Act, Investment Company Act, and Investment Advisers Act.
MiCAR Transitional Regime for CASPs Expires Across the EU, July 2026
On 1 July 2026, the MiCAR transitional period under Article 143(3) of Regulation (EU) 2023/1114 expired across the EU. Former virtual asset service providers operating under national registrations must now hold a MiCAR crypto-asset service provider authorisation or cease providing crypto-asset services. In Luxembourg, the CSSF confirmed that VASP registration under the 2004 AML Law no longer provides a sufficient legal basis for market activity.
EDPB Adopts Final GDPR Guidelines on Blockchain Data Processing, EU, 8 July 2026
On 8 July 2026, the European Data Protection Board adopted the final version of Guidelines 02/2025 on the processing of personal data through blockchain technologies. The guidelines confirm that encrypted and hashed on-chain data remains personal data under the GDPR and that blockchain immutability does not override data subjects' right to erasure under Article 17. Controllers must address architecture choices and data minimisation before any on-chain recording of personal data.
New York UCC Article 12 on Digital Asset Collateral Takes Effect, June 2026
New York's adoption of the 2022 Uniform Commercial Code amendments became effective on 3 June 2026, introducing Article 12 on controllable electronic records (CERs) and new priority rules for digital asset collateral. A security interest perfected by control of a CER now takes priority over one perfected by UCC-1 filing, regardless of filing date. The amendments affect secured lenders, custodians, and counterparties using digital assets as collateral in New York-governed transactions.
FTC Proposes Policy Statement on AI Accuracy Suppression Under Section 5 FTC Act, USA, July 2026
On 1 July 2026, the Federal Trade Commission published a proposed policy statement on the suppression of accuracy in artificial intelligence systems, with a public comment period closing 31 July 2026. The statement proposes that AI companies distorting their systems' outputs to achieve undisclosed ideological or political objectives may be committing deceptive acts or practices in violation of Section 5 of the FTC Act, contrary to representations made to consumers about AI effectiveness and objectivity.
New Zealand Opens Online Casino Gambling Licence Applications Under New Regulatory Regime, July 2026
On 16 July 2026, New Zealand's Department of Internal Affairs published its public notice opening the Expressions of Interest stage for online casino gambling licences under the Online Casino Gambling Act. Up to 15 licences will be available, each valid for up to three years with renewal for a further five, with a competitive selection process to follow the EOI stage.
ESMA Launches Common Supervisory Action on CASP Digital Operational Resilience, EU, July 2026
On 8 July 2026, the European Securities and Markets Authority launched a Common Supervisory Action targeting digital operational resilience at authorised crypto-asset service providers, with the initial phase focused on custody activities. National Competent Authorities will run risk-based assessments across a sample of authorised CASPs from the second half of 2026 through the first half of 2027.
Illinois Enacts Artificial Intelligence Safety Measures Act for Frontier AI Developers, USA, July 2026
On 6 July 2026, Illinois Governor JB Pritzker signed Senate Bill 315, the Artificial Intelligence Safety Measures Act (AISMA), into law, making Illinois the third US state to pass frontier AI legislation and the first to require mandatory independent third-party safety audits. The Act imposes safety auditing, governance, and transparency obligations on developers of frontier AI models meeting defined capability thresholds.
California Digital Financial Assets Law Becomes Fully Operative for Stablecoin Issuers, July 2026
From 1 July 2026, California's Digital Financial Assets Law (DFAL), enacted as AB 39, became fully operative, prohibiting any person from engaging in digital financial asset business activity with California residents unless licensed by the Department of Financial Protection and Innovation. The law places particular obligations on stablecoin issuers, requiring separate DFPI approval of each stablecoin before exchange, transfer, or storage activity can proceed.
Finland Gambling Act Ends State Monopoly, Opens Licensed iGaming Market from July 2027
Finland's Gambling Act, approved by the President on 16 January 2026, ends the state monopoly held by Veikkaus Oy and introduces competitive licensing for private iGaming operators in online sports betting and casino verticals. The Finnish Gambling Authority accepts licence applications from 1 March 2026; licensed market operations begin 1 July 2027. Licensed operators pay a flat gross-gaming-revenue tax of 22%.
SEC Adds Regulation Crypto to Rulemaking Agenda with Token Safe Harbor, July 2026
On 7 July 2026, the U.S. Securities and Exchange Commission placed Regulation Crypto on its regulatory priority agenda, the first crypto-specific rulemaking in the agency's history under Chair Paul Atkins. The proposal would create a time-limited registration exemption for early-stage token projects, permit capital raises up to $75 million in a 12-month period, and establish a decentralisation safe harbor for tokens whose issuers have ceased all essential managerial efforts.
Delaware Enacts Stablecoin Modernization Package Aligning State Licensing with Federal GENIUS Act
Delaware Governor Matt Meyer signed the Banking, Money Transmission, and Stablecoin Modernization Package on 6 July 2026, creating a state licensing regime for payment stablecoin issuers under the Delaware Payment Stablecoin Act. Senate Bill 19 establishes reserve requirements, redemption standards, and capital obligations aligned with the federal GENIUS Act and directs the Commissioner of Banks to seek nationwide operating authority through a substantial-similarity certification.
Taiwan Passes Virtual Asset Service Act Requiring FSC Licensing and Stablecoin Reserves
Taiwan's Legislative Yuan passed the Virtual Asset Service Provider Act on 30 June 2026, replacing AML-based registration with a comprehensive licensing regime under the Financial Supervisory Commission. The law covers seven categories of virtual asset service provider, mandates 100% reserve backing for stablecoin issuers, and requires customer asset segregation. Existing AML-registered VASPs have 12 months to file applications and 21 months to obtain full FSC approval.
Measuring Answer Quality in Citation-Grounded Question Answering over European Union Financial, Crypto, and AI Regulation
A grounding rate on its own says little: a system that refuses often, and one that answers everything while quoting loosely, can both score well. We measured Licentium Compass on two question sets that two people wrote and source-checked apart, and report the three numbers together. Core recall reached 0.829 and 0.843, all 592 displayed citations matched their source word for word, and the system correctly declined 62 and 67 percent of out-of-scope questions.
Illinois signs Artificial Intelligence Safety Measures Act into law, effective January 2027
Governor JB Pritzker signed the Illinois Artificial Intelligence Safety Measures Act on 6 July 2026, making Illinois the first US state to require mandatory annual third-party audits of frontier AI model developers. The Act applies to large frontier developers operating or deploying models in Illinois, requires transparency reports before each new or substantially modified frontier model deployment, and establishes civil penalties. Core obligations take effect 1 January 2027.
UK consults on modernising payment services regulation covering stablecoins and AI agents, 2026
HM Treasury launched a consultation on modernising the UK payment services regulatory regime, with responses due by 6 October 2026. The consultation addresses how to adapt regulation for tokenised payments including qualifying stablecoins, Open Banking expansion, and agentic AI systems authorised to conduct payments. It follows the February 2026 Payments Forward Plan and the government's decision to transfer Payment Systems Regulator functions to the Financial Conduct Authority.
Hong Kong SFC mandates phishing-resistant authentication for internet brokers and VATPs, July 2026
The Hong Kong Securities and Futures Commission issued a circular on 9 July 2026 requiring licensed corporations engaged in electronic trading and SFC-licensed virtual asset trading platform operators to replace one-time passwords with phishing-resistant authentication methods. Covered firms must implement passkeys or bound-device recognition for client login and device binding. Large internet brokers must act immediately. All other in-scope firms have up to 12 months to comply.
EDPB Adopts Guidelines 03/2026 on Web Scraping for Generative AI Training, July 2026
The European Data Protection Board adopted Guidelines 03/2026 at its 122nd Plenary on 8 July 2026, confirming that the GDPR governs web scraping for generative AI training wherever personal data is collected. The guidelines impose purpose-limitation, transparency, and legal-basis obligations on scrapers and reject a blanket AI-training exemption. Public consultation closes 30 October 2026.
EU Digital Euro Enters Trilogue Negotiations Between Parliament and Council, July 2026
The European Parliament voted 416 to 143 on 23 June 2026 to adopt its negotiating mandate on the digital euro regulation. The first trilogue meeting with the Council of the EU and the European Commission began on 13 July 2026. EU co-legislators aim to finalise the regulation under Ireland's Council Presidency by end of 2026, with direct implications for banks, payment institutions, and electronic money institutions across the eurozone.
Can EU Regulators Force Big Platforms to Open Up to AI Rivals?
Large digital platforms control operating-system features, search data, APIs, and user channels that rival AI services may need. The question is whether European Union enforcement can compel AI-facing interoperability, data, or distribution access. It also asks where that power ends. This analysis assumes Commission action under Regulation (EU) 2022/1925 or Article 102 TFEU. It treats access as a targeted remedy tied to a statutory breach or competitive harm. It does not assume disclosure of model weights, source code, or full training corpora.
Citation-Grounded Answers for EU Financial Regulation: The Design and Measured Grounding of Licentium Compass
Ground each answer in the words of the law. Verify each quote against the source. Refuse when the text is silent. Every sentence carries a link to the provision it rests on. That is what separates an answer that sounds correct from one a lawyer can audit in a click.
AI Litigation Readiness: Why Evidence Retention Is Now a Core Compliance Function
Artificial intelligence systems increasingly influence decisions that may later be challenged in court or investigated by regulators. Prompts, outputs, model versions, system instructions, audit logs, and human-review records can become material evidence. Organizations must therefore treat preservation capability as part of AI compliance, while limiting retention to records required by litigation duties, applicable law, and proportional risk.
Israel Ministry of Finance and Capital Market Authority Publish Stablecoin Licensing Draft Bill, 29 June 2026
On 29 June 2026, Israel's Ministry of Finance and the Capital Market, Insurance and Savings Authority (CMISA) published a draft bill on stable digital currency issuance for public comment. The bill proposes a CMISA licensing regime for stablecoin issuers, imposes 1:1 reserve requirements in segregated accounts, and mandates ongoing reporting and on-site inspection. The draft draws on the US GENIUS Act and EU MiCA and must pass three Knesset readings before taking effect.
Australia's Automated Decision-Making Transparency Obligation Takes Effect 10 December 2026
The Privacy and Other Legislation Amendment Act 2024 (Cth) inserts APP 1.7 into the Privacy Act 1988 (Cth), requiring APP entities that use personal information in automated decision-making likely to significantly affect individual rights to disclose this in their APP Privacy Policy from 10 December 2026. The obligation applies to banks, insurers, employers, and technology platforms. It imposes a transparency duty, not a prohibition on automation or a right of human review.
Malta Gaming Authority Opens Consultation on AI Gaming Charter for iGaming Operators, May 2026
In May 2026, the Malta Gaming Authority (MGA) and the Malta Digital Innovation Authority (MDIA) published a proposed AI Gaming Charter and opened a targeted consultation among MGA licensees, compliance professionals, and technology suppliers. The charter proposes voluntary, principles-based guidance on ethical and transparent AI use in iGaming, covering personalisation engines, fraud detection, responsible gambling triggers, and AI-assisted marketing. It is designed to complement EU AI Act obligations applicable to gaming operators.
EDPS Publishes Human Intervention Checklist for Automated Decision-Making, 18 May 2026
On 18 May 2026, the European Data Protection Supervisor (EDPS) published a self-assessment checklist on human intervention in automated decision-making (ADM) for EU institutions, bodies, offices, and agencies. The checklist operationalises Article 24 of Regulation (EU) 2018/1725 and Article 22 GDPR and sets out requirements across governance, reviewer competence, process design, appeal mechanisms, and performance monitoring. A human sign-off that does not include access to model inputs, logic, or genuine authority to override fails the EDPS standard.
From Cloud Concentration to AI Dependence: The UK’s Critical Third Parties Regime
The United Kingdom now directly oversees designated technology suppliers whose service failures could threaten financial stability. The question is whether the first cloud designations show a legal expansion toward AI-model providers, and what the present regime requires. This analysis assumes the quoted statement concerns the UK financial-services Critical Third Parties regime and assesses the law through 14 July 2026.
Alberta Regulated iGaming Market Launched on 13 July 2026 with 22 Operators
Alberta's regulated private iGaming market launched on 13 July 2026, making Alberta the second Canadian province to permit private online gambling operators after Ontario. The Alberta Gaming, Liquor and Cannabis Commission serves as market regulator and the Alberta iGaming Corporation oversees commercial operations and operator contracts. Twenty-two operator sites went live on day one, including FanDuel, DraftKings, BetMGM, and BetRivers. Operators must fully launch or exit the Alberta market by 13 October 2026.
European Commission Presents Cybersecurity and AI Action Plan on 7 July 2026
On 7 July 2026, the European Commission presented an Action Plan on Cybersecurity and Artificial Intelligence. The plan directs the Commission and ENISA to evaluate advanced AI models before they reach the EU market, establish a secure testing platform for critical-sector organisations, and launch an EU Grand Challenge on AI-powered cybersecurity solutions. It operates alongside the AI Act, NIS2 Directive, DORA, Cyber Resilience Act, and Cyber Solidarity Act, and introduces no new directly binding obligations.
Hong Kong Gazetted Crypto-Asset Reporting Framework Bill on 22 May 2026
The Inland Revenue (Amendment) (Crypto-Asset Reporting Framework and Amended Common Reporting Standard) Bill 2026 was gazetted in Hong Kong on 22 May 2026 and had its first reading in the Legislative Council on 3 June 2026. The bill implements the OECD Crypto-Asset Reporting Framework and 2023 CRS amendments. Crypto-asset service providers with a Hong Kong reporting nexus must register with the Inland Revenue Department, conduct client due diligence, file annual returns, and maintain records from 1 January 2027.
Hong Kong SFC Issues Stablecoin Circular as HKMA Grants First Issuer Licences, April to May 2026
The Hong Kong Monetary Authority granted stablecoin issuer licences to two entities on 10 April 2026. On 27 May 2026, the Securities and Futures Commission issued Circular 26EC26 directing virtual asset trading platforms and licensed corporations on their obligations when dealing in relevant stablecoins. The circular addresses disclosure, suitability, exposure limits, and due diligence for stablecoin-only clients, and applies immediately to all SFC-regulated intermediaries providing services in relevant stablecoins.
EU AI Act Deadlines, Data-Lineage Obligations, Regulated Use Cases, And Penalties
The analysis concerns high-risk AI systems under Article 6. Separate obligations concerning general-purpose AI models are outside scope except where a third-party model is incorporated into a high-risk system.
FTC Characterises AI Output Steering as Deception Under FTC Act Section 5, July 2026
On 7 July 2026, the Federal Trade Commission published proposed policy statement 2026-13628 in the Federal Register. The statement identifies AI output steering - deliberate modification of a system's outputs to advance undisclosed objectives - as potentially deceptive under Section 5 of the FTC Act, 15 U.S.C. § 45. The FTC further concludes that state laws compelling suppression of accurate AI outputs, including Colorado's Artificial Intelligence Act, may be impliedly preempted. Public comment closes 31 July 2026.
Malaysia National AI Office Opens Consultation on Proposed AI Governance Bill, 10 July 2026
On 10 July 2026, Malaysia's National Artificial Intelligence Office (NAIO) published a Public Consultation Paper on the proposed AI Governance Bill. The Bill would establish Malaysia's first statutory AI framework, adopting a risk-based model and covering the full AI lifecycle from design through retirement. It includes specific provisions on deepfakes, AI-generated copyright, and data sovereignty.
Germany's Crypto Asset Tax Transparency Act Enters First Reporting Year, 2026
The Kryptowerte-Steuertransparenz-Gesetz (KStTG), implementing EU Directive 2023/2226 (DAC8), entered its first mandatory data collection year on 1 January 2026. Crypto asset operators resident in or registered in Germany must collect transaction and account data for calendar year 2026 and transmit it to the Bundeszentralamt für Steuern by 31 July 2027, using the CARF-XML schema specified by the Federal Finance Ministry on 14 January 2026.
Germany Adopts KI-MIG Designating Bundesnetzagentur as AI Market Surveillance Authority, June 2026
On 11 June 2026, the German Bundestag adopted the KI-Marktüberwachungs- und Innovationsförderungs-Gesetz (KI-MIG), the domestic act implementing EU Regulation 2024/1689 on artificial intelligence. The KI-MIG designates the Bundesnetzagentur as Germany's central AI market surveillance authority and establishes a coordination and competence centre to manage cross-agency enforcement and EU institutional liaison.
Austria Launches Consultation on Draft Gambling Reform Act Opening Online Market, June 2026
On 29 June 2026, Austria's coalition parties ÖVP, SPÖ, and NEOS published a ministerial draft Gambling Reform Act for public consultation, with comments due 15 July 2026. The draft ends Austria's online gambling monopoly and introduces an open multi-licence concession system. Concession applicants must meet minimum share capital of €10 million and maintain functioning compliance systems. An independent gambling supervisory authority is to be established. Operators seeking licences must cease unlicensed offerings by 1 January 2027. Parliament is expected to vote in autumn 2026.
Munich Regional Court Holds Search Engine Operator Directly Liable for AI Overview Statements, May 2026
On 28 May 2026, the Regional Court Munich I (LG München I, Ref. 26 O 869/26) issued a temporary injunction ordering a search engine operator to cease publishing AI-generated overviews that falsely associated two Munich-based publishers with scams and subscription traps. The court classified the operator as a direct author of the false statements, not a conduit for third-party content, exposing it to fines of up to €250,000 per violation.
FCA Publishes Final Cryptoasset Regime Rules Including Stablecoin Authorisation Requirements, 30 June 2026
On 30 June 2026, the Financial Conduct Authority published Policy Statement PS26/9, finalising the rules for the UK's mandatory cryptoasset regime. The rules cover trading platforms, intermediaries, custodians, stablecoin issuers, and staking service providers. Firms can apply for authorisation between 30 September 2026 and 28 February 2027; the mandatory regime takes effect on 25 October 2027.
CFTC Issues Request for Information on Regulatory Barriers Facing FinTech Firms, June 2026
On 16 June 2026, the Commodity Futures Trading Commission published Request for Information No. 9254-26, seeking public input on CFTC regulations, guidance documents, orders, and no-action letters that impede fintech firms from forming partnerships with federally regulated institutions. The RFI carried out the CFTC's obligations under Executive Order 14405. The comment period ran for 21 days from Federal Register publication and has since closed; the CFTC will use the record to determine whether to initiate rulemaking on specific identified barriers.
Australia's High Court Finds Crypto Yield Product Constituted Unlicensed Financial Service
Australia's High Court has unanimously held, 7-0, that Block Earner's Earner product offering fixed yields on digital assets was a financial product requiring an Australian Financial Services Licence. The ruling overturns the Full Federal Court's prior judgment and sets binding precedent for digital asset yield platforms in Australia.
US Senate Discussion Draft Would Open Platform Access to Authorised AI Agents, July 2026
Senator Mark Warner circulated a discussion draft of the AI AGENT Act in July 2026, proposing that large online platforms allow consumers to authorise AI agents to act on their behalf. The draft directs NIST to develop technical standards for agent authentication and imposes transparency and privacy duties on platform-accessible AI agents.
China Finalises Rules for AI Companion and Emotional Interaction Services, Effective 15 July 2026
China's Cyberspace Administration and four co-regulating agencies published final rules for AI anthropomorphic interactive services on 10 April 2026. The Measures enter into force on 15 July 2026 and impose disclosure, content moderation, and minor-protection duties on platforms that simulate human personality in sustained emotional exchanges with users.
Senator Warner Releases Discussion Draft of AI AGENT Act on 29 June 2026
On 29 June 2026, Senator Mark Warner (D-VA) released a discussion draft of the Artificial Intelligence Access, Gatekeeper Exchange, and Nondiscriminatory Transfer Act (AI AGENT Act). The draft would create a Federal Trade Commission registry of vetted AI agents and require agents accessing sensitive user data to act in users' best interests. Large online platforms would face a non-discrimination obligation for AI agent access. NIST would develop open technical standards for agent authentication.
FCA Publishes Mills Review into Long-Term Impact of AI on Retail Financial Services, 6 July 2026
The Financial Conduct Authority published the Mills Review on 6 July 2026, concluding that artificial intelligence will create opportunities and amplify existing risks in UK retail financial services. The FCA confirmed it will not introduce new AI-specific rules, relying instead on existing principles-based obligations to govern how authorised firms deploy AI.
Italy Council of Ministers Approves AI Implementing Decrees Under Law 132/2025, June 2026
On 10 June 2026, Italy's Council of Ministers approved two draft legislative decrees implementing Law No. 132/2025, Italy's national AI statute that entered into force in October 2025. The first decree covers national supervisory authority powers and AI in education; the second addresses AI in law enforcement, civil liability for AI-caused harm, and new criminal offences. Both decrees are pending parliamentary advisory review before promulgation.
Vietnam Politburo Issues Conclusion 51-KL/TW on IP and AI Governance, June 2026
On 17 June 2026, the Politburo of the Communist Party of Vietnam issued Conclusion No. 51-KL/TW, directing that intellectual property be treated as a strategic national asset and mandating legal reforms to address AI-generated content, software piracy, and technology licensing. The Conclusion signals forthcoming amendments to Vietnam's IP Law and stronger inter-agency enforcement against IP infringement.
UKJT Publishes Legal Statement on AI Civil Liability Under English Private Law, 7 July 2026
The UK Jurisdiction Taskforce published its Legal Statement on Liability for AI Harms under the Private Law of England and Wales on 7 July 2026. The statement concludes that existing English law covers most AI liability scenarios without the need for new legislation, and sets out how negligence, contract, professional liability, and vicarious liability apply when AI causes loss.
European Commission Proposes Cloud and AI Development Act to Establish EU AI Sovereignty Criteria, 2 July 2026
The European Commission formally proposed the Cloud and AI Development Act (CADA) on 2 July 2026 as part of the Tech Sovereignty Package. CADA aims to triple EU data centre capacity within five to seven years and introduces EU-wide CADA Assurance Levels for cloud and AI services, which will serve as a procurement criterion for public-sector and regulated-sector buyers across EU member states.
Ireland Publishes General Scheme of Regulation of Artificial Intelligence Bill 2026
On 17 June 2026, the Irish Government published the General Scheme of the Regulation of Artificial Intelligence Bill 2026. The Bill designates Oifig IS na hEireann (AI Office of Ireland) as the central coordinating authority and distributes enforcement across 13 Market Surveillance Authorities, providing Ireland's domestic architecture for supervising and penalising violations of the EU AI Act.
Dutch Supreme Court Limits Nullity Claims Against Unlicensed Online Gambling, July 2026
The Dutch Supreme Court issued a preliminary ruling on 3 July 2026 on online gambling contracts with operators lacking a Dutch licence. It held that breach of Article 1(1)(a) of the Gambling Act does not make those contracts null or voidable under Article 3:40 of the Civil Code, while leaving defect-of-consent and tort claims open.
EU Council Approves AI Act Omnibus Amendments Extending High-Risk Deadlines, 29 June 2026
The Council of the EU gave final approval on 29 June 2026 to the Digital AI Omnibus, amending Regulation (EU) 2024/1689. High-risk AI system deadlines extend from August 2026 to December 2027 for standalone systems and August 2028 for systems embedded in regulated products. A new prohibition on AI generating non-consensual intimate imagery or child sexual abuse material takes effect in December 2026. Article 50 transparency obligations for AI-generated content are unaffected and apply from 2 August 2026.
Bank of England and FCA Issue Joint Stablecoin Supervision Approach, UK, June 2026
The Bank of England and the Financial Conduct Authority published a joint approach document in June 2026 setting out how they will divide regulatory responsibility for UK stablecoin issuers. The FCA authorises and supervises all qualifying stablecoin issuers; the Bank of England assumes prudential oversight where an issuer is designated systemic.
FTC Proposes Policy Statement on AI Output Accuracy and Undisclosed Ideological Steering, US, July 2026
On 1 July 2026, the Federal Trade Commission published a proposed policy statement asserting that AI companies distorting their systems' outputs to advance undisclosed ideological objectives may violate the prohibition on unfair or deceptive acts under Section 5 of the FTC Act. Public comments are due by 31 July 2026.
Australia High Court Rules 7-0 for ASIC in Block Earner Appeal, June 2026
On 17 June 2026, the High Court of Australia delivered judgment in ASIC v Web3 Ventures Pty Ltd [2026] HCA 21, ruling unanimously that the fixed-yield digital asset product Earner was a financial product requiring an Australian financial services licence. The ruling reversed the Full Federal Court's 2025 decision and expanded ASIC's enforcement reach over yield-bearing crypto products.
European Commission Publishes Code of Practice on Marking and Labelling AI-Generated Content, June 2026
On 10 June 2026, the European Commission published the Code of Practice on Marking and Labelling of AI-Generated Content. The Code supports compliance with Article 50(2) and (4) of Regulation (EU) 2024/1689 and sets technical marking standards aligned with C2PA specifications. Adherence is voluntary, but the Code establishes the benchmark against which providers and deployers of generative AI systems will be assessed from the 2 August 2026 Article 50 compliance date.
Illinois Enacts First US Digital Asset Transaction Tax, 0.2% Rate Effective January 2027
Illinois Governor J.B. Pritzker signed S.B. 3019 into law, enacting the Digital Asset Tax Act as part of the Revenue Omnibus Bill. The act imposes a 0.2% privilege tax on digital asset exchanges, transfers, and storage involving Illinois customers, effective 1 January 2027. Centralised exchanges operating in Illinois and out-of-state exchanges earning more than $100,000 from Illinois customers annually face registration and collection obligations. Illinois is the first US state to impose a transactional tax on digital assets.
New York UCC Revision Act Takes Effect June 2026, Creating Digital Asset Commercial Law Rules
New York Senate Bill S1840A (the UCC Revision Act) took effect on June 3, 2026, amending New York's Uniform Commercial Code to govern digital assets through a new Article 12. The legislation creates rules for the transfer of controllable electronic records, security interest perfection, and priority disputes, and extends good-faith purchaser protections adapted from Articles 3 and 7 to digital instruments.
Five Eyes Agencies Issue Joint AI Cyber Threat Statement, June 22, 2026
CISA (US), NCSC (UK), ACSC (Australia), CCCS (Canada), and NCSC-NZ jointly published a cyber security statement on June 22, 2026. The agencies assess that AI will accelerate the speed, scale, and sophistication of cyber threats, with frontier models expected to exceed current defensive assumptions within months. The statement directs organizations to treat cyber risk as a board-level concern and strengthen foundational controls without delay.
MiCA Grandfathering Period Ends July 2026: Unauthorized CASPs Must Cease EU Operations
The maximum 18-month MiCA transitional period expired on 1 July 2026, closing the grandfathering window across all EU and EEA member states. Any crypto-asset service provider that operated under pre-MiCA national regimes must now hold MiCA authorisation or suspend services. ESMA confirmed that national competent authorities are expected to enforce compliance, with pending applicants permitted to continue only where an NCA issues an express individual determination.
Spain Approves AI Governance Bill and Sends It to Parliament, May 26, 2026
Spain's Council of Ministers approved the Proyecto de Ley para el buen uso y la gobernanza de la inteligencia artificial on May 26, 2026, and submitted it to the General Courts under urgent procedure. The bill transposes Regulation (EU) 2024/1689 (EU AI Act) into domestic law, designates a national supervisory authority, creates an AI delegate role across public bodies, and governs regulatory sandboxes under Article 57 of the EU AI Act.
FinCEN and Banking Agencies Propose CIP Rules for Stablecoin Issuers, June 2026
On 22 June 2026, FinCEN, the OCC, the Federal Reserve, the FDIC, and the NCUA issued a joint notice of proposed rulemaking requiring permitted payment stablecoin issuers to establish customer identification programs under the GENIUS Act. Covered issuers must collect name, date of birth, address, and taxpayer identification number for each account holder, retaining records for five years. Comments are due 21 August 2026.
China Regulates AI Companion Services, Banning Minor Access, Effective 15 July 2026
On 10 April 2026, five Chinese government authorities jointly issued the Interim Measures for the Administration of Artificial Intelligence Anthropomorphic Interaction Services, effective 15 July 2026. The Measures prohibit AI virtual companion and virtual relative services for minors, require algorithm filing and security assessment for covered providers, and mandate addiction-detection mechanisms. Providers serving children under 14 must obtain explicit guardian consent and implement supervised usage controls including spending restrictions and usage duration limits.
UK Applies Russia Sanctions to Crypto Exchanges Under Regulation 17A, 26 May 2026
On 26 May 2026, the UK Office of Financial Sanctions Implementation applied Regulation 17A(2) of the Russia (Sanctions) (EU Exit) Regulations 2019 to designated crypto-asset exchanges for the first time, sanctioning 18 entities including HTX (formerly Huobi). UK financial institutions and virtual asset service providers are prohibited from processing transfers with designated exchanges. HTX is alleged to have channeled over USD 1.5 billion to Russian counterparties.
Canada Introduces Bill C-36 to Replace PIPEDA with New Privacy Law, June 2026
On 15 June 2026, the Canadian Minister of Artificial Intelligence and Digital Innovation introduced Bill C-36, the Protecting Privacy and Consumer Data Act, to replace PIPEDA as the federal private-sector privacy statute. The bill establishes a Digital Safety and Data Protection Commission with penalties up to CAD 25 million or 5% of global revenue, introduces explicit deletion rights for AI-generated deepfakes, and imposes heightened requirements for children's data.
Securities Commission Malaysia Issues 14th Revision of Digital Asset Exchange Guidelines, Effective 20 May 2026
On 20 May 2026, the Securities Commission Malaysia issued the 14th revision of its Guidelines on Recognised Markets. The revised rules strengthen governance and accountability standards for digital asset exchange operators, streamline new product approvals, and extend Financial Markets Ombudsman Service membership to digital asset exchanges.
Italy Implements DAC8 Crypto Reporting Under D.Lgs. 194/2025, First Submissions Due 30 June 2027
From 1 January 2026, all crypto-asset service providers reporting to Italian authorities must transmit client identification data, balances, and annual transactions to the Agenzia delle Entrate under Council Directive 2023/2226 (DAC8), transposed into Italian law by Legislative Decree 194/2025. The first reporting cycle covers 2026 transactions, with domestic submissions due 30 June 2027.
Spain's AESIA Publishes 16 Technical Guides for EU AI Act Compliance Ahead of August 2026 Deployer Obligations
Spain's Agencia Española de Supervisión de la Inteligencia Artificial (AESIA) has released a full suite of 16 technical compliance guides for Regulation (EU) 2024/1689, the EU AI Act. The guides address each high-risk AI system category in Annex III and become critical reference documents as Article 26 deployer obligations take effect on 2 August 2026.
MiCA Transitional Period Expires 1 July 2026, Leaving 83% of EU Crypto Firms Without Authorisation
The 18-month grandfathering period under Regulation (EU) 2023/1114 (MiCA) expired on 1 July 2026. Of the 1,200-plus firms that held national VASP registrations at the start of the transitional period, approximately 210 have obtained CASP authorisation. The remaining 83 percent no longer hold legal standing to provide crypto-asset services to EU clients.
Bank of England Publishes Draft Rules for Systemic Stablecoin Issuers
The Bank of England published a policy statement and draft Code of Practice setting out the regulatory regime for systemic stablecoin issuers in the UK in June 2026. The draft rules introduce a GBP 40 billion temporary issuance guardrail per stablecoin, permit issuers to hold up to 70% of reserves in short-term UK government debt, and require the balance in central bank deposits. The consultation closes 22 September 2026; the Bank intends to finalise the Code of Practice by end of 2026.
Spain Tables AI Governance Organic Law in Parliament, Names AESIA as Supervisor
On 26 May 2026, Spain's Council of Ministers approved a draft Organic Law on the proper use and governance of artificial intelligence, implementing Regulation (EU) 2024/1689 into national law. The draft was published in the Official Journal of the Spanish Parliament on 12 June 2026. The Spanish Artificial Intelligence Supervisory Agency (AESIA) is designated as the main market surveillance authority for AI systems not covered by sectoral product legislation and as Spain's single point of contact for supervision matters.
Runtime Evidence as the New Architecture for EU AI Act Compliance
This analysis asks whether the chain intent → control → evidence → approval → baseline is a useful way to structure AI compliance under the EU AI Act.
DIFC Digital Economy Court Dismisses 300-Bitcoin Custody Claim Against Tabarak, 2026
The DIFC Digital Economy Court has handed down judgment in Gate MENA DMCC and Huobi MENA FZE v Tabarak Investment Capital Limited and Christian Thurner, dismissing the claimants' case in full. The retrial, heard over five days in February 2026, addressed contract formation under DIFC and common law in the context of a 300-Bitcoin OTC transaction disputed since 2020.
Vietnam's AI Law No. 134/2025/QH15 Takes Effect March 2026 with Risk-Based Obligations
Vietnam's Law on Artificial Intelligence No. 134/2025/QH15, adopted by the National Assembly on 10 December 2025, entered into force on 1 March 2026. The Law introduces a risk-based classification of AI systems into three tiers and imposes disclosure, registration, and operational obligations on AI developers, providers, and deployers operating in Vietnam or producing effects on Vietnamese persons. A transitional period of 12 to 18 months applies to systems already in operation.
SFC Updates Fund Authorization Rules for Stablecoins and Tokenised Deposits, Hong Kong, May 2026
On 27 May 2026, the Securities and Futures Commission updated its Circular on SFC-authorised funds with exposure to virtual assets to address fiat-referenced stablecoins issued by licensed issuers and tokenised bank deposits. The update excludes Relevant Stablecoins and tokenised deposits from the standard VA fund authorization requirements and sets new custody standards for their use within SFC-authorised fund portfolios.
New Zealand's First Online Casino Gambling Licensing Regime Comes Into Force in May 2026
New Zealand's Online Casino Gambling Act 2026 came into force on 1 May 2026, creating the country's first statutory licensing regime for online casino gambling. The Department of Internal Affairs will award up to 15 operator licences through a competitive process, run as an auction, beginning July 2026. Advertising unlicensed online casino gambling is prohibited from commencement; operators already active on 1 May 2026 may continue until 1 December 2026 or, if they apply for a licence before that date, until 1 June 2027 at the latest.
Hong Kong SFC Concludes VA Advisory and Management Licensing Consultation in May 2026
On 26 May 2026, the Financial Services and the Treasury Bureau and the Securities and Futures Commission published consultation conclusions on proposals to license virtual asset advisory and virtual asset management service providers in Hong Kong. The proposals received broad support from 51 respondents. The regulators will finalise legislative amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance and aim to introduce a bill into the Legislative Council in 2026.
Hong Kong Flags Prediction Markets as Illegal Gambling Risk under Cap. 148 in April 2026
In April 2026, the Hong Kong Home and Youth Affairs Bureau suspended planned basketball betting citing the rapid rise of unregulated prediction markets. Chief Executive John Lee stated the government must assess emerging risks before proceeding. The Gambling Ordinance (Cap. 148) prohibits all gambling not expressly authorised, and senior legal practitioners have identified prediction market participation as carrying criminal exposure under section 8 of Cap. 148.
Hong Kong IFEC Warns Prediction Market Participation May Violate Gambling Ordinance, April 2026
In April 2026, the Investor and Financial Education Council, a statutory body under the Securities and Futures Commission, published a warning that participation in prediction markets by Hong Kong residents may constitute illegal gambling under the Gambling Ordinance (Cap. 148). The warning followed the government's decision to halt planned regulated basketball betting amid concerns about normalising prediction market activity.
Hong Kong SFC Opens Secondary Trading of Tokenised Funds Using Stablecoins in 2026
On 27 May 2026, the Securities and Futures Commission updated its circular on SFC-authorised funds with exposure to virtual assets, clarifying that exposure to fiat-referenced stablecoins issued by licensed issuers falls outside the 10% NAV threshold. The update supports a broader SFC initiative permitting secondary trading of tokenised SFC-authorised investment products on licensed virtual asset trading platforms, with settlement conducted using regulated stablecoins and tokenised deposits.
NAD Refers Kalshi to Regulators Over Influencer Disclosure Non-Compliance, 8 June 2026
On 8 June 2026, BBB National Programs' National Advertising Division referred Kalshi Inc. to state attorneys general and other regulatory authorities after Kalshi declined to participate in an NAD inquiry into influencer and affiliate marketing disclosures on its prediction-market platform. The inquiry examined whether Kalshi's social media advertising satisfied FTC endorsement disclosure requirements under 16 C.F.R. Part 255.
Brazil Mandates DeCripto Crypto-Asset Reporting Form Effective 1 July 2026
Brazil's Federal Revenue Service (Receita Federal do Brasil) replaces Instrução Normativa RFB No. 1,888/2019 with IN RFB No. 2,291/2025, effective 1 July 2026, creating the Declaração de Criptoativos (DeCripto). All crypto-asset service providers domiciled in Brazil must submit monthly reports via the RFB's e-CAC portal regardless of transaction volume, aligning Brazil's reporting regime with the OECD Crypto-Asset Reporting Framework.
European Commission Adopts Cloud and AI Development Act Proposal, 3 June 2026
On 3 June 2026, the European Commission adopted a proposal for the Cloud and AI Development Act (CADA), a regulation aimed at expanding EU cloud capacity, accelerating AI infrastructure deployment, and establishing a single EU-wide sovereignty assessment for cloud and AI services. The proposal accompanies the Chips Act 2.0 and the EU Open Source Strategy as part of a broader tech sovereignty package adopted the same day.
US GSA Proposes Federal Acquisition Clause for LLM Data Safeguarding, Comment Deadline August 2026
On 17 June 2026, the US General Services Administration published a proposed General Services Administration Acquisition Regulation clause requiring federal contractors to implement data safeguarding measures when large language models process government data. The proposal amends 48 CFR Parts 539 and 552, addresses data protection, intellectual property, and ethical AI development in federal procurement, and accepts public comments until 3 August 2026.
FSB Issues Consultation on Sound Practices for Responsible AI Adoption in Finance, June 2026
On 10 June 2026, the Financial Stability Board published a consultation report identifying 12 sound practices for responsible AI adoption by financial institutions. The practices cover organisation-wide AI governance and AI lifecycle management at the use-case level. The FSB explicitly acknowledges the limits of human oversight of agentic AI systems and recommends AI-monitoring-AI architectures. Comments are due 22 July 2026, with a final report expected in October 2026.
New Zealand Online Casino Gambling Regulations 2026 Take Effect 3 July, Regulating Licensed Operators
The Online Casino Gambling Regulations 2026 (NZ) come into force on 3 July 2026, setting operational and advertising requirements for up to 15 licensed online casino operators under the Online Casino Gambling Act 2026. Key requirements include mandatory spending limit prompts, a prohibition on credit card payments, a 3.5% quarterly levy on gambling profits, bans on autoplay functions, and a prohibition on affiliate marketing and paid endorsements.
Vietnam Implements AI Law Risk Classification Rules Via Decree 142, Effective May 2026
On 30 April 2026, Vietnam's government issued Decree No. 142/2026/ND-CP implementing the Law on Artificial Intelligence, effective 1 May 2026. The Decree establishes a three-tier AI risk classification system, mandatory labelling of AI-generated content, and incident-reporting timelines of 72 hours for serious incidents. The Decree applies to foreign organisations and individuals conducting AI activities in Vietnam, regardless of where they are incorporated.
US Export Control Directive Forces Suspension of Anthropic Fable 5 and Mythos 5, June 2026
On 12 June 2026, the US government issued an export control directive requiring Anthropic to suspend access to Claude Fable 5 and Claude Mythos 5 for all foreign nationals, including Anthropic's own foreign national employees. The directive, issued at 5:21 pm ET under national security authorities, was triggered after officials became aware of a technique to bypass Fable 5 safeguards protecting advanced cybersecurity capabilities. Anthropic's other models, including Claude Opus 4.8, remain available.
ESMA Confirms MiCA Transitional Period Ends 1 July 2026 for EU Crypto-Asset Service Providers
ESMA confirmed in its April 2026 statement that the MiCA transitional period for crypto-asset service providers expires on 1 July 2026. Under Article 143(3) of Regulation (EU) 2023/1114, CASPs providing services under national law before 30 December 2024 must hold full MiCA authorization by that date or cease EU-facing operations. No extension is available under the regulation.
New Zealand Online Casino Gambling Regulations 2026 Enter Force 3 July, Market Opens December
The New Zealand Department of Internal Affairs published the Online Casino Gambling Regulations 2026 under the Online Casino Gambling Act 2026, entering force 3 July 2026. Up to 15 licences will be auctioned from September 2026, with market entry from 1 December 2026. Unlicensed operators face exclusion from 1 June 2027. A quarterly 3.5% profit levy applies to all licensees.
Florida Supreme Court Amends Rule 2.515 to Require AI Citation Accuracy, Effective 15 June 2026
The Supreme Court of Florida amended Rule of General Practice and Judicial Administration 2.515 on 28 May 2026, effective 15 June 2026, requiring all court filing signers to certify that legal authorities cited exist and are accurately stated. Courts may sanction filers whose submissions contain fabricated or misrepresented citations, a risk directly associated with generative AI tools.
The EU’s new AML rules: a €10,000 cash cap and €1,000 crypto KYC from 2027
From 10 July 2027, the EU’s new Anti-Money Laundering Regulation caps cash payments at €10,000 and requires crypto services to run KYC on transactions from €1,000. What changes, who it affects, and how to prepare.
FSB Opens AI Adoption Sound Practices Consultation, 10 June 2026
The Financial Stability Board published a consultation report on sound practices for responsible AI adoption on 10 June 2026. It asks financial institutions and authorities for comments by 22 July 2026 on governance, risk management, data controls, model oversight, third-party dependencies, and incident management.
Reranking is the cheapest big win in legal retrieval
Adding a reranker was the single largest accuracy gain in the pipeline, and it cost almost nothing to add
CFTC Issues No-Action Relief for Crypto Perpetual Futures Conversion, 29 May 2026
The CFTC's Division of Market Oversight issued No-Action Letter 26-17 on 29 May 2026, permitting designated contract markets to convert existing perpetual-style digital commodity futures into true digital commodity perpetual futures without triggering Regulation 40.6 filing requirements. The letter expires 30 June 2026 and coincides with the Commission's first approval of a domestic bitcoin perpetual contract submitted by KalshiEX LLC.
EU Parliament Approves AI Act Simplification Amendments, June 2026
The European Parliament in June 2026 formally approved targeted amendments to Regulation (EU) 2024/1689, the Artificial Intelligence Act, as part of the Digital Omnibus package. The amendments defer application of Annex III high-risk AI obligations, introduce a ban on AI-generated non-consensual intimate imagery, and follow a political agreement between the Parliament and the Council of 7 May 2026.
Connecticut Enacts AI Disclosure and Chatbot Safety Law Public Act 26-15, 2 June 2026
Connecticut Governor Ned Lamont on 2 June 2026 signed Substitute Senate Bill No. 5, enacted as Public Act 26-15, into law. The statute imposes suicide prevention protocol obligations on AI chatbot operators, requires employers to disclose AI use in hiring and employment decisions, and mandates age verification, parental consent, and algorithmic content limits for minor users of social media platforms.
Discussion Draft of Great American AI Act Released by U.S. House Members, June 2026
Representatives Jay Obernolte and Lori Trahan on 4 June 2026 released a discussion draft of the Great American Artificial Intelligence Act, a bipartisan federal proposal to establish a national AI governance regime. The draft assigns primary regulatory authority to the Center for AI Standards and Innovation within the Department of Commerce and imposes audit and incident reporting requirements on frontier AI developers.
Manitoba Enacts Algorithmic Pricing Rules and Public Sector AI Governance Act, 1 June 2026
On 1 June 2026, Bill 49 and Bill 51 received Royal Assent in Manitoba. Bill 49, in force since 1 July 2026, makes it an unfair business practice to use personalized algorithmic pricing to charge a consumer more: for online retailers and online distributors, and for any supplier at the point of sale where prices are shown on electronic shelf labels. Bill 51 enacts The Public Sector Artificial Intelligence and Cybersecurity Governance Act, which comes into force on a day to be fixed by proclamation.
UAE Establishes Federal Authority for Artificial Intelligence and Data by Decree, 14 June 2026
On 14 June 2026, Sheikh Mohammed bin Rashid Al Maktoum approved the establishment of the Federal Authority for Artificial Intelligence and Data, a unified cabinet-level body in the UAE. The Authority merges the UAE AI Office, the digital government sector of the Telecommunications and Digital Government Regulatory Authority, and the Emirates Data Office into one entity. It is led by Minister Omar Sultan Al Olama and reports directly to the UAE Cabinet.
OCC Proposes Reporting Forms for GENIUS Act Payment Stablecoin Issuers, June 2026
The Office of the Comptroller of the Currency published Bulletin 2026-24 on 12 June 2026, proposing weekly and quarterly reporting forms for permitted payment stablecoin issuers regulated under the GENIUS Act. The weekly Reporting Form PS-02 requires per-stablecoin reserve asset disclosures. The quarterly form covers financial condition data. Both forms are open for public comment until 11 August 2026.
Google Engineer Charged with Commodities Fraud on Polymarket Using Confidential Data, May 2026
On 27 May 2026, the U.S. Attorney for the Southern District of New York unsealed a criminal complaint charging Michele Spagnuolo, a Google staff software engineer, with commodities fraud, wire fraud, and money laundering. Spagnuolo allegedly used confidential internal Google Search data to place approximately $2.75 million in bets on Polymarket event contracts tied to Google's Year in Search report between October and December 2025, netting roughly $1.2 million in profit. The CFTC filed a parallel civil action seeking penalties and trading bans.
Georgia Enacts Payment Stablecoin Act, Establishing Issuer Licensing Regime, May 2026
On 11 May 2026, Georgia signed HB 1272 (Act 452), the Georgia Payment Stablecoin Act, into law. The statute directs the Georgia Department of Banking and Finance to license stablecoin issuers incorporated under Georgia or foreign law. Licensed issuers must maintain one-to-one reserves of eligible assets and may only engage in stablecoin issuance, redemption, reserve management, and related custodial activities. The law takes effect on the earlier of 18 January 2027 or 120 days after federal GENIUS Act implementing regulations are finalized.
Italy Approves AI Act Implementing Decrees for Parliamentary Review, June 2026
On 10 June 2026, Italy's Council of Ministers approved two draft legislative decrees implementing Law No. 132/2025, the domestic AI statute aligned with EU Regulation 2024/1689. The decrees, announced in Press Release No. 177, cover national authority powers, AI in employment and education, biometric surveillance in law enforcement, civil liability for AI-caused harm, and new criminal offences. They are now subject to parliamentary advisory review before final promulgation.
Georgia Enacts Payment Stablecoin Act Establishing State Licensing Regime for Issuers, May 2026
Georgia enacted HB 1272, the Payment Stablecoin Act (Act 452), creating a state licensing and regulatory regime for payment stablecoin issuers. Licensed issuers must hold one-to-one reserves and are prohibited from paying interest or yield to holders. Provisions take effect on the earlier of 18 January 2027 or 120 days after the GENIUS Act's implementing regulations are finalised, with full enforcement beginning 18 July 2028.
Italy Council of Ministers Approves Draft EU AI Act Implementing Decrees, 10 June 2026
On 10 June 2026, the Italian Council of Ministers (meeting n. 177) granted preliminary approval to two draft legislative decrees implementing Regulation (EU) 2024/1689 (the EU AI Act). The first decree covers national supervisory authority powers and AI use in education. The second addresses police use of AI and civil and criminal AI liability. Both implement the delegation in Law No. 132 of 23 September 2025 and remain subject to parliamentary committee review before final adoption.
Embedding Model Selection for Citation-Grounded Retrieval over European Union Financial and AI Regulation
We report a controlled empirical comparison of five text-embedding models for first-stage semantic retrieval over a corpus of consolidated European Union legislation governing crypto-assets, anti-money-laundering, digital operational resilience, and artificial intelligence.
OCC Interpretive Letter 1192: National Bank Act Preempts State Money Transmitter Licensing for Digital Asset Activities, May 2026
The OCC published Interpretive Letter 1192 on May 12, 2026, confirming that the National Bank Act preempts state money transmitter licensing laws for national banks conducting digital asset activities. The Letter arose from Fidelity Digital Assets' request for confirmation that Iowa's money transmitter law does not apply to its national trust bank operations. The OCC held that state money transmitter laws requiring national banks to obtain state licenses, or vesting states with visitorial authority over national banks, are preempted.
House Ways and Means Committee Holds Digital Asset Tax Legislative Hearing, June 9, 2026
The House Ways and Means Committee held a full-committee legislative hearing on June 9, 2026, examining eight bills and discussion drafts on digital asset taxation. The hearing, the Committee's first legislative hearing on digital asset tax rules in years, covered proposals addressing mining and staking income classification, de minimis transaction reporting exemptions, charitable deduction rules for crypto donations, and extension of wash-sale and anti-abuse provisions to digital assets.
European Commission Issues Draft Guidelines on High-Risk AI System Classification, EU, May 2026
On 19 May 2026, the European Commission published draft guidelines on the classification of high-risk AI systems under Article 6 of Regulation (EU) 2024/1689, the EU AI Act. A targeted public consultation is open until 23 July 2026. The guidelines aim to assist providers, deployers, and market surveillance authorities in determining which AI systems trigger the Act's most onerous compliance obligations. Final guidelines are expected before end of 2026.
European Commission Publishes Draft EU AI Act Transparency Guidelines on Deepfakes, EU, May 2026
On 8 May 2026, the European Commission published draft guidelines on the transparency obligations under Article 50 of the EU AI Act. The guidelines cover disclosure requirements for providers of AI chatbots, systems generating synthetic audio, image, video, or text, emotion recognition systems, and deployers of deepfake content. A public consultation closed on 3 June 2026. Final guidelines are expected by 2 August 2026, when the Article 50 obligations become applicable.
South Carolina Governor Signs S. 163 Creating Digital Asset and CBDC Framework, May 2026
South Carolina Governor Henry McMaster signed S. 163 into law on May 19, 2026, establishing statewide protections for digital asset use. The law bars state agencies from accepting or mandating central bank digital currency payments, protects the right to use digital assets as payment for goods and services, exempts digital asset miners and blockchain software developers from money transmitter licensing, and prohibits additional state taxes on cryptocurrency transactions.
France Enacts Decree 2026-60 Establishing Experimental JONUM Regime for Monetisable Digital Gaming Objects, February 2026
Decree No. 2026-60 of 4 February 2026, in force from 7 February 2026, establishes France's experimental regulatory regime for jeux à objets numériques monétisables (JONUM) under the loi SREN. The regime applies to games meeting four cumulative criteria: financial sacrifice, a chance element, access via an online platform, and the award of monetisable digital objects including NFTs and utility tokens. Operators must file a prior declaration with the Autorité nationale des jeux before offering JONUM to the public. Casino mechanics and cash payouts in legal tender are prohibited.
UK Crime and Policing Act 2026 Criminalises Unsafe AI Chatbot Supply, United Kingdom, April 2026
The UK Crime and Policing Act 2026 received Royal Assent on 29 April 2026. Section 255 creates three criminal offences for AI chatbot suppliers: deploying a chatbot that produces illegal content, failing to conduct an adequate risk assessment, and failing to mitigate identified risks of harm. Convictions on indictment carry a maximum sentence of five years' imprisonment. The Act brings AI chatbot providers within scope of the Online Safety Act 2023 illegal content obligations.
European Commission Opens Consultation on MiCA Review, Deadline 30 September 2026
On 20 May 2026, the European Commission launched a public consultation and a parallel targeted consultation on the review of Regulation (EU) 2023/1114 (MiCA). Authorized crypto-asset service providers, issuers of asset-referenced tokens and e-money tokens, financial institutions, and technology providers have until 23:59 CEST on 30 September 2026, after a one-month extension, to submit responses. The Commission will use the consultation to prepare a report under Articles 140 and 142, which may be accompanied by a legislative proposal to amend MiCA.
Senator Warren Demands CFTC Records on Crypto and Prediction Market Oversight, June 2026
Senator Elizabeth Warren wrote to CFTC Chairman Michael Selig on or around 9 June 2026, demanding records on the agency's oversight of cryptocurrency and prediction markets by 18 June 2026. The demand covers staff separation records since January 2025, the administrative records behind no-action letters to Polymarket and Gemini, and all communications between prediction market operators and the CFTC connected to the Clarity Act. The Senator cited a 25% workforce reduction and a steep decline in enforcement actions.
NYDFS Proposes GENIUS Act-Aligned Payment Stablecoin Regulation, New York, June 2026
On 9 June 2026, the New York State Department of Financial Services Acting Superintendent Kaitlin Asrow announced a proposed regulation for payment stablecoin issuers. The proposal aligns DFS's existing June 2022 stablecoin guidance with requirements of the federal GENIUS Act, adds reserve concentration limits, and mandates risk management programs. A 10-day preproposal comment period opened on 9 June 2026, followed by a 60-day comment period upon publication in the State Register.
EBA and NYDFS Sign Cross-Border Stablecoin Supervisory Cooperation MoU, June 2026
On 2 June 2026, the European Banking Authority and the New York State Department of Financial Services signed a Memorandum of Understanding on supervisory cooperation for entities conducting cross-border stablecoin activities. The MoU was executed under Article 126 of Regulation (EU) 2023/1114 (MiCA), which authorises the EBA to conclude administrative arrangements with third-country supervisory authorities where equivalent confidentiality standards are confirmed.
Australia's Gambling Reform Bill 2026 Targets Online Trade Promotions Starting January 2027
The Australian Government has introduced the Interactive Gambling Amendment (Stop the Gambling Ads) Bill 2026 to Parliament and announced amendments to the Interactive Gambling Act 2001 (Cth) commencing 1 January 2027. The reforms address subscription-based rewards programs structured as recurring lottery-style prize draws, which the Government characterises as 'shadow lottery' arrangements currently outside Commonwealth regulation.
UK Makes 18 Russia Sanctions Designations Targeting Crypto Exchanges, 26 May 2026
On 26 May 2026, the UK made 18 designations under The Russia (Sanctions) (EU Exit) Regulations 2019, including Huobi Global S.A., listed with the name variation HTX, and three Georgian companies operating Russia-focused exchanges. Ten of the designated persons, including Huobi Global, are also subject to prohibitions on UK credit and financial institutions establishing correspondent banking relationships with them or processing their payments.
Rwanda Publishes Law on Virtual Asset Business in Official Gazette, 28 May 2026
On 28 May 2026, Rwanda published its Law on Virtual Asset Business in the Official Gazette, entering into force upon publication. The Capital Market Authority (CMA) is designated as the lead licensing authority. The National Bank of Rwanda (BNR) holds co-regulatory authority over systemic risk and payment systems. Only incorporated legal entities may provide virtual asset services. Implementation regulations from the CMA and BNR are pending.
CFTC Approves Bitcoin Perpetual Futures Contract and SEC Issues Joint Crypto Securities Interpretation, 29 May 2026
On 29 May 2026, the U.S. Commodity Futures Trading Commission approved the listing of a bitcoin perpetual futures contract by KalshiEX LLC. The SEC and CFTC jointly issued an interpretation clarifying how federal securities laws apply to crypto assets, accompanied by a CFTC no-action letter permitting futures commission merchants to transfer customer crypto margin to foreign brokers. The coordinated actions are the first to bring perpetual crypto contracts into the U.S. regulatory system.
CFTC Proposes First Event Contract Rules for Prediction Markets, United States, June 2026
On 10 June 2026, the U.S. Commodity Futures Trading Commission released a notice of proposed rulemaking establishing a review process for determining whether event contracts fall within statutory prohibitions under Section 5c(c)(5)(C) of the Commodity Exchange Act. The proposal amends CFTC Regulation 40.11 and adds Appendix F to Part 40. It sets a three-part sequential test and a 90-day review window for individual contracts, paired with a multi-factor public interest analysis. CFTC Chairman Mike Selig described the measure as creating a durable, transparent process while permitting legitimate markets to operate.
Trump Signs Executive Order on AI Cybersecurity and Frontier Model Review, United States, June 2026
President Trump signed the Executive Order 'Promoting Advanced Artificial Intelligence Innovation and Security' on 2 June 2026, directing federal agencies to deploy AI-enabled cyber defenses within 30 days, establishing a voluntary arrangement for pre-release government access to covered frontier AI models within 60 days, and creating an AI cybersecurity clearinghouse coordinated by the Secretary of the Treasury. The order charges the Attorney General with prioritizing criminal enforcement under 18 U.S.C. 1028, 1030, and 1343 against those who use AI to unlawfully access or damage computer systems. No mandatory licensing or pre-clearance requirement for AI models is created.
Colorado Signs SB 189 Replacing State AI Act with Narrower Disclosure Law, May 2026
Colorado Governor Jared Polis signed Senate Bill 26-189 on 14 May 2026, repealing and replacing the Colorado Artificial Intelligence Act (SB 24-205) before its 30 June 2026 effective date. The replacement law removes the duty of care, mandatory impact assessments, and risk management programs for high-risk AI systems and institutes a disclosure-based regime covering automated decision-making technology used in consequential decisions spanning employment, financial services, healthcare, and housing. The new law takes effect on 1 January 2027.
New Zealand Online Casino Gambling Regulations 2026 Released, Effective July 2026
New Zealand released the Online Casino Gambling Regulations 2026 in June 2026, made under the Online Casino Gambling Act 2026 (Public Act 2026 No 14). The prohibition on unlicensed online casino gambling applies from 1 July 2026. The Act establishes a three-stage licensing regime for up to 15 operators, administered by the Secretary for Internal Affairs, with age-verification, harm-minimisation, and problem-gambler exclusion obligations.
US Tax Court Holds Crypto Staking Rewards Are Gross Income at Receipt, June 2026
On June 4, 2026, the United States Tax Court issued T.C. Memo. 2026-46 in Paschall v. Commissioner, the first Tax Court decision on whether proof-of-stake staking rewards are taxable upon receipt. The court entered decision for the Commissioner of Internal Revenue, holding that ADA staking rewards credited to petitioners' eToro account constituted gross income under IRC Section 61 at receipt. The opinion is non-precedential but is the first judicial merits ruling on this question.
CFTC Issues Policy Statement and Approves First Onshore Bitcoin Perpetual Contract, May 2026
On May 29, 2026, the CFTC approved KalshiEX LLC's BTCPERP contract as the first bitcoin perpetual futures contract listed on a US-registered designated contract market and issued a Policy Statement stating that the case-by-case review process in Regulation 40.3 is appropriate for perpetual contracts referencing asset classes not covered by the KalshiEX Order. The actions bring the dominant form of global crypto derivative trading into the US regulated perimeter for the first time.
EU Parliament and Council Reach Provisional Agreement on AI Act Simplification, 7 May 2026
The European Parliament and Council reached a provisional political agreement on 7 May 2026 to streamline Regulation 2024/1689 laying down harmonised rules on artificial intelligence. The agreement, part of the EU Omnibus VII simplification package, extends application deadlines for high-risk AI systems, broadens exemptions to small mid-cap companies, and bans AI systems that generate non-consensual intimate images. Formal adoption by both institutions is expected before 2 August 2026.
MAS and Industry Publish AI Risk Management Toolkit for Singapore Financial Sector, 2026
The Monetary Authority of Singapore concluded Project MindForge Phase 2 in early 2026, publishing an AI Risk Management Operationalisation Handbook developed with a consortium of 24 banks, insurers, and capital market firms. The handbook provides practical implementation guidance across traditional AI, generative AI, and agentic AI systems, and applies alongside the MAS Guidelines for Artificial Intelligence Risk Management to establish supervisory expectations for Singapore-regulated financial institutions.
House of Lords Committee Publishes Report on UK Stablecoin Regulation, 3 June 2026
On 3 June 2026, the House of Lords Financial Services Regulation Committee published 'Stablecoins: waiting for regulation,' assessing the Bank of England's and the Financial Conduct Authority's proposed regulatory regimes for stablecoins in the UK. The Committee broadly supports the proposals but recommends reconsideration of holding limits, the requirement for unremunerated backing assets, and the proposed restriction on commercial banks issuing fiat-backed stablecoins.
FCA and Bank of England Call for Input on UK Wholesale Market Tokenisation, May 2026
On 18 May 2026, the Financial Conduct Authority, the Bank of England, and the Prudential Regulation Authority published a joint call for input setting out a shared vision for the safe adoption of tokenisation in UK wholesale financial markets. The consultation covers tokenised bonds, equities, and fund units and closes 3 July 2026. Responses will inform a joint roadmap aligned with the Government's Wholesale Financial Markets Digital Strategy.
AI Governance Compliance Stack
What compliance architecture should an organization implement to manage AI governance obligations under the EU AI Act, selected U.S. state AI laws, NIST AI RMF / NIST GenAI Profile, ISO/IEC 42001, vendor due diligence, system inventory, risk classification, and incident response?
FDIC Proposes BSA/AML Compliance Rules for Stablecoin Issuers Under the GENIUS Act, 2026
The FDIC Board approved two notices of proposed rulemaking in April 2026 implementing the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act. One proposed rule imposes Bank Secrecy Act and sanctions compliance requirements on FDIC-supervised permitted payment stablecoin issuers. Comments on both proposals close 9 June 2026.
FCA and Bank of England Publish Joint Vision on UK Wholesale Market Tokenisation, May 2026
On 18 May 2026, the Financial Conduct Authority and the Bank of England jointly published a call for input setting out their shared vision for tokenisation in UK wholesale financial markets. The paper commits the Bank to launching a live synchronisation service by 2028 and confirms tokenised equivalents of eligible assets may be used as central bank collateral. Feedback closes 3 July 2026.
Agentic AI Liability and Autonomous Decision-Making
When an agentic or autonomous AI system makes, recommends, ranks, screens, contracts, or otherwise materially influences a decision, who bears legal liability, and what legal duties govern autonomous decision-making?
SEC Proposes Token Taxonomy Clarifying Federal Securities Laws for Crypto Assets, March 2026
In March 2026, the SEC proposed an interpretive release (Release No. 33-11412, File No. S7-2026-09) establishing a token taxonomy and clarifying the application of federal securities laws to crypto assets. The taxonomy designates digital commodities, digital collectibles, digital tools, and qualifying payment stablecoins as generally outside the securities perimeter. Only tokenised traditional securities remain subject to registration and disclosure requirements.
UK HM Treasury Publishes Draft SI on Stablecoin Payment Services Exemption, April 2026
In April 2026, HM Treasury published a draft statutory instrument amending the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026. The draft SI proposes to exempt firms providing stablecoin payment services from the cryptoasset dealing and arranging authorisation requirements pending broader payment services reform, avoiding a dual-authorisation burden ahead of the October 2027 deadline.
Privacy, GDPR, and Personal Data in AI Models
When does the GDPR treat data used in, generated by, or retained in AI models as “personal data,” what legal bases and obligations apply to model training and deployment, and what are the consequences if an AI model was developed using personal data unlawfully?
Native Tokenization of Equity
The working topic is whether a token or DLT ledger can be legally constitutive of equity ownership and transfer, rather than a mirror of an off-chain register, a custodial entitlement, or a synthetic exposure.
SEC Proposes Registered Offering Reform with Implications for Digital Asset Issuers, 19 May 2026
On 19 May 2026, the U.S. Securities and Exchange Commission proposed Rule 33-11418, amending the framework governing registered public securities offerings under the Securities Act of 1933. The proposal would expand Form S-3 access to significantly more issuers, extend shelf registration to nearly all public companies, and preempt state securities law for all registered offerings, with material implications for digital asset companies seeking to raise capital in U.S. registered offerings.
New Zealand Online Casino Gambling Act 2026 Enters Into Force, 1 May 2026
New Zealand's Online Casino Gambling Act 2026 received Royal Assent on 27 April 2026 and entered into force on 1 May 2026. The Act establishes a licensing regime for up to 15 online casino operators and prohibits new offshore providers from serving New Zealand customers. Existing offshore operators may continue under transitional arrangements until 1 December 2026.
UK Cryptoassets Regulations 2026 Set Full Regulatory Regime to Commence October 2027
The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, Statutory Instrument 2026 No. 102, designates specified cryptoasset activities as regulated activities under the Financial Services and Markets Act 2000, with the regime coming into force on 25 October 2027. Firms must apply to the FCA for authorisation from 30 September 2026, with the application window closing 28 February 2027. The regime covers stablecoin issuance, custody, trading platform operation, dealing, arranging, and staking.
UK Regulators Issue Joint Statement on Frontier AI Cyber Resilience, 15 May 2026
On 15 May 2026, the Financial Conduct Authority, Bank of England, and HM Treasury issued a joint statement identifying frontier AI models as a material cybersecurity threat requiring immediate action from regulated financial firms and financial market infrastructures. The statement does not introduce new rules but carries supervisory weight, placing frontier AI risk within existing operational resilience obligations and calling on boards to demonstrate active oversight.
NYDFS Issues Dual Industry Letters on Frontier AI Cybersecurity Risks, 21 May 2026
On 21 May 2026, the New York Department of Financial Services issued two coordinated Industry Letters under Acting Superintendent Kaitlin Asrow. The first identifies heightened cybersecurity risks from frontier AI models that amplify the speed, scale, and potency of attacks against regulated entities. The second provides prescriptive guidance on additional measures in a heightened threat environment, covering attack-surface reduction, threat detection, and resilience planning.
AUSTRAC Launches VASP Supervisory Campaigns as AML/CTF Reforms Take Effect, 2026
The Australian Transaction Reports and Analysis Centre has launched two targeted supervisory campaigns into the virtual assets sector as Australia's revised anti-money laundering and counter-terrorism financing legislation reshapes obligations for virtual asset service providers. Obligations for most newly classified VASPs took effect from 31 March 2026, with travel rule requirements commencing 1 July 2026. New VASPs must register with AUSTRAC by 29 July 2026.
DTCC Connects Tokenization Service to Stellar Public Blockchain, 27 May 2026
On 27 May 2026, the Depository Trust and Clearing Corporation announced its forthcoming DTC tokenization service will connect to the Stellar public blockchain, advancing a multi-chain settlement strategy for tokenized securities held in DTC custody. The service, authorized by SEC no-action letter in December 2025, targets initial tokenized security trades in July 2026 with a full commercial launch in October 2026. Over 50 financial firms are participating in development.
Missouri AG Sues CoinFlip Cryptocurrency ATM Network Over Consumer Protection Violations, 20 May 2026
On 20 May 2026, Missouri Attorney General Catherine Hanaway filed suit in the Circuit Court of Jasper County against GPD Holdings LLC, operating as CoinFlip, the self-described world's largest cryptocurrency ATM network by transaction volume. The petition alleges CoinFlip violated the Missouri Merchandising Practices Act by knowingly facilitating fraud through its 140-plus Missouri kiosks and charging excessive fees on affected transactions.
US Executive Order 14405 Directs Federal Regulators to Review Fintech and Digital Asset Frameworks, 19 May 2026
President Trump signed Executive Order 14405, "Integrating Financial Technology Innovation into Regulatory Frameworks," on 19 May 2026. The Order directs the SEC, CFTC, OCC, FDIC, CFPB, and NCUA to complete a 90-day review identifying regulations, guidance, and supervisory practices that impede fintech innovation, fintech-bank partnerships, and charter applications in digital assets. The review window closes around 17 August 2026.
Trump Signs Executive Order 14405 Directing Fintech and Crypto Regulatory Integration, 19 May 2026
President Donald Trump signed Executive Order 14405, 'Integrating Financial Technology Innovation into Regulatory Frameworks,' on May 19, 2026. The order directs the Treasury, SEC, CFTC, OCC, FDIC, NCUA, and CFPB to identify rules and sub-regulatory guidance impeding fintech and digital asset businesses, propose revisions or repeals, and report to the President within 180 days. It was published in the Federal Register on May 22, 2026 as document 2026-10399.
CFTC Division of Enforcement Issues New Cooperation Policy, 19 May 2026
The Commodity Futures Trading Commission's Division of Enforcement issued CFTC Staff Letter No. 26-15 on 19 May 2026, replacing all prior cooperation advisories. The policy establishes a structured path to full declination for entities that voluntarily self-report violations, provide full cooperation, effect timely remediation, and make full restitution. Penalty reductions of up to 75 percent are available for parties who cooperate but do not qualify for declination.
California Governor Newsom Signs AI Workforce Executive Order, 21 May 2026
California Governor Gavin Newsom signed an executive order on 21 May 2026 directing multiple state agencies to study and respond to artificial intelligence's impact on the workforce. The Labor and Workforce Development Agency must review WARN Act obligations, severance standards, and collective bargaining practices involving AI within six months. The Employment Development Department must document AI-related layoffs and publish a real-time sector-level employment impact dashboard.
California Governor Newsom Issues Executive Order N-6-26 on AI Workforce Disruption Assessment, 21 May 2026
California Governor Gavin Newsom signed Executive Order N-6-26 on May 21, 2026, directing state agencies to build monitoring and policy infrastructure for potential AI-driven labor market disruption. The order mandates deliverables within 180 days, including WARN Act revision recommendations, a sectoral workforce impact dashboard, and policy proposals on severance standards, transition insurance, and expanded training programs.
OCC Grants Augustus Bank Conditional Approval for AI-Native Stablecoin National Bank Charter
The Office of the Comptroller of the Currency issued Conditional Approval No. CA1358 on 11 May 2026 for Augustus Bank, N.A. to charter as a full-service US national bank. The institution is designed to operate as an AI-native clearing bank with a wholly-owned stablecoin subsidiary, targeting a Q3 2026 launch.
FCA, Bank of England and HM Treasury Set Frontier AI Supervisory Expectations, May 2026
On 15 May 2026, the Financial Conduct Authority, the Bank of England, and HM Treasury published a joint statement setting out supervisory expectations for regulated firms on cybersecurity and operational resilience risks posed by frontier AI models. Boards and senior management are expected to demonstrate active understanding of these risks.
FCA, Bank of England and HM Treasury Warn Firms on Frontier AI Cyber Risks, May 2026
On May 15, 2026, the FCA, Bank of England, and HM Treasury issued a joint statement identifying frontier AI cyber capabilities as an active systemic risk to financial services firms. The statement sets out supervisory expectations for governance, vulnerability management, automated defence deployment, and incident recovery under existing rules. No new regulations were issued; the authorities indicated that current obligations apply to frontier AI-driven threats immediately.
OCC Grants Preliminary Conditional Approval to Augustus Bank for Stablecoin Charter, May 2026
The Office of the Comptroller of the Currency granted Augustus Bank, N.A. a preliminary conditional approval to charter a national bank with a stablecoin-issuing subsidiary in Dallas, Texas. The approval references the GENIUS Act (12 U.S.C. § 5901 et seq.) and attaches conditions on capital, governance, and stablecoin reserve management before the bank may open. The OCC retains the right to rescind the approval.
Senator Warren Challenges OCC Over National Trust Charters for Crypto Companies, May 2026
Senator Elizabeth Warren, Ranking Member of the Senate Banking Committee, sent a letter to OCC Comptroller Jonathan Gould in May 2026 challenging at least nine national trust company charters granted to crypto businesses. Warren argues the charters exceed OCC authority under 12 U.S.C. § 92a because the holders do not conduct fiduciary trust activities and instead operate as de facto banks outside standard bank safety requirements.
California DFPI Orders Hermes Bitcoin to Shut Down 42 Kiosks for DFAL Violations, May 2026
California's Department of Financial Protection and Innovation ordered Anh Management, LLC, operating as Hermes Bitcoin, to cease all digital financial asset kiosk operations in California by May 20, 2026. The settlement agreement resolves DFPI findings that Hermes Bitcoin violated the Digital Financial Assets Law across its 42 Southern California kiosk locations.
AI Training Data, Copyright, and Transparency: A Comparative Legal Analysis
This analysis compares the U.S., California, EU, and U.K. positions and highlights the practical split.
British Virgin Islands Confirms OECD CARF Adoption with First Crypto-Asset Information Exchanges in 2028
The British Virgin Islands has committed to the OECD's Crypto-Asset Reporting Framework (CARF), with the first exchanges of crypto-asset information scheduled for 2028. BVI-based reporting Crypto-Asset Service Providers will collect transaction, identity, and tax residence data from 2027 onward. The BVI International Tax Authority is the competent authority. CRS 2.0 entered force in the BVI on 1 January 2026 and now includes crypto-assets and CBDCs within scope.
Trump Executive Order Calls for Review of Fintech Charter, Partnership and Payment Access Barriers, 19 May 2026
President Donald Trump signed the Executive Order titled "Integrating Financial Technology Innovation Into Regulatory Frameworks" on 19 May 2026. The order directs the federal financial regulators to review barriers that limit fintech firms from obtaining bank charters and other federal licences and from partnering with regulated institutions, and requests the Federal Reserve to evaluate access to Reserve Bank payment accounts and services. Regulators must complete their reviews within 90 days. The Federal Reserve is requested to report on payment account access within 120 days.
APRA and ASIC Issue Industry Letters on AI Risk and Cyber Resilience, April and May 2026
The Australian Prudential Regulation Authority published an open letter to all regulated entities on 30 April 2026 setting expectations for governance of AI and AI agents. The Australian Securities and Investments Commission followed with an 8 May 2026 letter to licensees calling for urgent action on cyber resilience against AI-enabled threats. APRA notes that existing prudential standards apply to AI risk and warns of stronger supervisory action where entities fail to manage it; ASIC sets out the cyber actions it expects licensees to take.
UK Jurisdiction Taskforce Publishes Non-Binding Report on Control of Digital Assets, 19 March 2026
The UK Jurisdiction Taskforce (UKJT), chaired by the Master of the Rolls Sir Geoffrey Vos, published its Report on Control of Digital Assets on 19 March 2026. The Report sets out non-binding guidance on how factual control of digital assets operates and how that control supports legal analysis of ownership and proprietary interests under English law. It follows the Law Commission's Final Report on Digital Assets and supports the developing common law of digital asset property.
California DFPI Orders Hermes Bitcoin to Cease Crypto Kiosk Operations Under DFAL, 18 May 2026
The California Department of Financial Protection and Innovation announced a consent order on 18 May 2026 requiring Hermes Bitcoin, the operator of 42 crypto kiosks across Southern California, to cease all digital financial asset business in the state by 20 May 2026. The DFPI alleged violations of the Digital Financial Assets Law (DFAL), the California Consumer Financial Protection Law, and federal anti-money laundering rules. Restitution totals $174,874.28 with a $1 million suspended administrative penalty.
High-Risk AI Under the EU AI Act
How should an organization determine whether an AI system is classified as high-risk under the EU AI Act, and what implementation obligations follow from that classification?
Matter-route inference: focus areas as retrieval constraints for official sources
A focus area should not be a label attached to a page diff; it should be a matter route that binds official source, source class, change unit, user scope, and decision record.
From public URL to official record: source-route inference in Horizon
Horizon treats the URL as an observation, then tests which official route gives the cleanest record, the safest fetch path, and the strongest proof of change.
China Issues Interim Measures on Anthropomorphic AI Interaction Services, Effective 15 July 2026
On 10 April 2026 the Cyberspace Administration of China issued the Interim Measures for the Administration of Anthropomorphic AI Interaction Services together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, and the State Administration for Market Regulation. The Measures regulate virtual companions, AI chatbots, and emotionally responsive digital assistants. The Measures take effect on 15 July 2026.
FDIC Approves Notice of Proposed Rulemaking on Payment Stablecoins Under GENIUS Act, 7 April 2026
The Federal Deposit Insurance Corporation approved a Notice of Proposed Rulemaking on 7 April 2026 implementing the GENIUS Act for payment stablecoin issuers. The proposal sets a two-business-day redemption obligation, custodial and safekeeping duties, reserve-asset rules, and clarifies the treatment of tokenized deposits. Reserves backing a payment stablecoin do not pass through deposit insurance to holders. Comments close 60 days after Federal Register publication.
Georgia Enacts SB 540 Conversational AI Safety Act, Effective 1 July 2027
Georgia Governor Brian Kemp signed Senate Bill 540 in spring 2026, enacting the state's first dedicated AI companion chatbot statute. The Act takes effect on 1 July 2027. Operators must provide parental controls, age assurance for sexually explicit features, and privacy tools to minor users. The Attorney General may bring civil enforcement actions with penalties of up to 10,000 dollars per knowing violation, plus compensatory damages and attorneys' fees.
Ireland Gambling Regulatory Authority Begins Issuing Remote Betting Licences from 1 July 2026
The Gambling Regulatory Authority of Ireland opened B2C betting licence applications through its online portal on 9 February 2026 and will issue the first remote betting licences from 1 July 2026. In-person operators transition off legacy Revenue Commissioner permissions by 1 December 2026. The Authority may impose fines of up to 20 million euros or 10 percent of annual turnover under the Gambling Regulation Act 2024.
MiCA Goes Under Review: What's On the Table, and What to Do Before 31 August
On 20 May 2026, the European Commission launched two consultations on the functioning of MiCA (a short public one and a 65-question targeted one for industry, supervisors and central banks), both closing 31 August 2026. The responses will feed the Article 140 and 142 review reports and likely a 'MiCA 2' legislative proposal.
UK Bar Standards Board publishes guidance on barrister use of AI, 18 May 2026
On 18 May 2026, the Bar Standards Board published Guidance on the Use of Artificial Intelligence and Other Technologies. The guidance applies existing BSB Handbook duties to AI use by barristers in England and Wales. It warns against free generative AI tools whose terms allow provider retention of input data, and clarifies when disclosure of AI use is required to clients, courts and the regulator.
Supreme Court of Victoria issues AI Practice Note SC Gen 25, 14 May 2026
On 14 May 2026, the Supreme Court of Victoria issued Practice Note SC Gen 25 on the use of artificial intelligence by court users, replacing the May 2024 Guidelines for Litigants. The Practice Note requires meaningful human verification of AI output, identification of AI-generated portions of court documents and special caution with affidavits and witness statements.
BoE, FCA and HM Treasury issue joint frontier AI cyber statement, 15 May 2026
On 15 May 2026, the Bank of England, the Financial Conduct Authority and HM Treasury published a joint statement on frontier AI models and cyber resilience. The authorities say current frontier models already exceed skilled human attackers in speed, scale and cost, and direct regulated firms to lift board oversight, vulnerability management, third-party controls, protective measures and recovery capability.
Central Bank of Ireland publishes Notice of Intention on crypto MCC requirements, April 2026
On 13 April 2026, the Central Bank of Ireland published a Notice of Intention to amend the Minimum Competency Code 2017 to cover staff of Crypto-Asset Service Providers. The proposed Addendum adds crypto-assets as Category 9 to MCC Appendix 1 and aligns with the application date of the ESMA MiCA Guidelines on knowledge and competence on 28 July 2026.
ADGM proposes crypto mining commercial licensing in Discussion Paper No. 1 of 2026
In January 2026, the Abu Dhabi Global Market Registration Authority issued Discussion Paper No. 1 of 2026 proposing a commercial licensing regime for crypto mining activities in or from ADGM. The proposal treats crypto mining as a licensable commercial activity rather than a regulated financial service. Consultation responses were accepted until 20 March 2026.
US Senate Banking Committee Advances CLARITY Act in 15-9 Bipartisan Vote on 14 May 2026
The United States Senate Committee on Banking, Housing, and Urban Affairs voted 15-9 to advance H.R. 3633, the Digital Asset Market CLARITY Act of 2025, on 14 May 2026. Two Democratic senators joined committee Republicans. The bill assigns regulatory lines between the Securities and Exchange Commission and the Commodity Futures Trading Commission for digital asset spot markets. The measure now moves to a full Senate vote.
South Korea National Assembly Passes FETA Amendment on Virtual Asset Transfers, 7 May 2026
The Republic of Korea's National Assembly passed a Partial Amendment to the Foreign Exchange Transactions Act at plenary session on 7 May 2026. The amendment creates a new virtual asset transfer business category. Operators that send or receive digital assets across the Korean border must register with the Minister of Economy and Finance. Unregistered operations face up to three years in prison. The amendment takes effect six months after promulgation.
Connecticut Passes SB 5, the AI Responsibility and Transparency Act, on 11 May 2026
The Connecticut General Assembly passed Senate Bill 5, now branded the Artificial Intelligence Responsibility and Transparency Act, on 11 May 2026. The act binds developers and deployers of automated employment-related decision technology, layers on whistleblower protections for frontier model staff, and adds AI disclosures to WARN notices filed with the Department of Labor. Governor Ned Lamont is expected to sign. Most provisions take effect from 1 October 2026, with interactive disclosure rules following on 1 October 2027.
Prediction Markets Are Becoming the Next Major Federalism Fight
Prediction markets are becoming a U.S. federalism fight between CFTC-regulated derivatives markets and state gambling regulators. Their likely legal future is a category-based regime shaped by preemption, product design, and market-integrity controls.
Minnesota enacts SF 3868 prohibiting virtual currency kiosks, 5 May 2026
Governor Tim Walz signed Minnesota Senate File 3868 into law on 5 May 2026. The Act prohibits virtual currency kiosks statewide. The prohibition takes effect 1 August 2026. Operators must remove kiosks from any location accessible or visible to the public by 31 December 2026. Minnesota joins Indiana and Tennessee as the third US state to prohibit crypto kiosks.
APRA letter to industry on AI risk management and governance, 30 April 2026
On 30 April 2026 the Australian Prudential Regulation Authority issued a letter to all regulated entities setting expectations on AI risk management. The letter follows a targeted thematic review of selected large banks, insurers, and superannuation trustees in late 2025. APRA names four weak areas: governance, cyber security, supplier risk, and assurance. Where entities fail, APRA will escalate to supervisory and enforcement action.
SEC and CFTC sign coordination MOU and joint crypto interpretation, March 2026
On 11 March 2026 SEC Chairman Paul Atkins and CFTC Chairman Michael Selig signed a Memorandum of Understanding for coordinated digital asset oversight. On 17 March 2026 the two agencies jointly issued an interpretation on how the federal securities laws apply to crypto assets and crypto transactions. The MOU supersedes the agencies' 2018 MOU and sets six core areas for harmonised rulemaking.
Australian Government releases formal response to online gambling reform inquiry, 12 May 2026
On 12 May 2026 the Australian Government released its formal response to the House of Representatives Standing Committee on Social Policy and Legal Affairs report titled You win some, you lose more. The package restricts wagering advertising during live sport, strengthens BetStop, addresses online lottery products, harmonises match-fixing offences, and commits AU$112.7 million over five years to gambling harm reduction. Most reforms commence 1 January 2027.
Hong Kong SFC permits secondary trading of tokenised authorised investment products, April 2026
The Securities and Futures Commission of Hong Kong issued two circulars on 20 April 2026: one revising guidance on the tokenisation of SFC-authorised investment products and one opening secondary trading of those tokenised products on SFC-licensed virtual asset trading platforms. Settlement may use regulated stablecoins issued under the Stablecoins Ordinance or tokenised deposits, with round-the-clock trading permitted.
Indonesia's MoF Regulation 108/2025 Activates Crypto-Asset Tax Reporting from 2026
Indonesia's Ministry of Finance issued Regulation No. 108 of 2025 (MoF 108) implementing the Crypto-Asset Reporting Framework. The rule sets statutory reporting duties for Crypto Asset Service Providers and brings payment service providers and licensed e-wallet operators under the financial information reporting scheme. First reporting covers the 2026 calendar year, due to the Directorate General of Taxes by 30 April 2027.
Colorado Legislature Passes SB 189 Repealing and Replacing the Colorado AI Act, 12 May 2026
On 12 May 2026, the Colorado General Assembly passed SB 189, which repeals the Colorado Artificial Intelligence Act (SB 24-205) and replaces it with a disclosure-focused statute covering automated decision-making technology. The bill drops the duty of care, risk management programmes, and impact assessment duties. Governor Polis is expected to sign. The new statute takes effect on 1 January 2027.
Cayman Islands Brings Tokenised Funds Acts into Force, 24 March 2026
The Cayman Islands' Mutual Funds (Amendment) Act, 2026 and Private Funds (Amendment) Act, 2026 came into force on 24 March 2026. The Acts add statutory definitions and operating requirements for tokenised mutual funds and tokenised private funds. The Cayman Islands Monetary Authority (CIMA) supervises tokenised vehicles under the same regime that applies to traditional funds.
Pennsylvania sues Character.AI over chatbot impersonation of licensed psychiatrist
On 5 May 2026 the Pennsylvania Department of State filed suit against Character Technologies, Inc., alleging that AI chatbots on its platform engaged in the unauthorized practice of medicine. State investigators found a chatbot named Emilie offered mental health diagnoses, claimed Pennsylvania licensure with a fake licence number, and stated it could prescribe medication. The Commonwealth seeks a preliminary injunction.
UK ICO opens consultation on automated decision-making after Data (Use and Access) Act
The Information Commissioner's Office launched a consultation on draft guidance for solely automated decision-making under the Data (Use and Access) Act 2025. The Draft Guidance is the ICO's first detailed reading of how the DUAA changes Article 22 UK GDPR. The consultation closes on 29 May 2026. A statutory code of practice on AI and ADM is expected later in 2026.
FinCEN and OFAC propose AML, CFT and sanctions rules for stablecoin issuers
On 8 April 2026 the US Treasury's FinCEN and OFAC issued a joint Notice of Proposed Rulemaking implementing AML, countering the financing of terrorism and sanctions compliance obligations for permitted payment stablecoin issuers under the GENIUS Act. The Proposed Rule treats issuers as financial institutions under the Bank Secrecy Act. Comments are due 9 June 2026. Final rules would take effect twelve months after issuance.
Virginia, Kentucky, and Wisconsin Enact Virtual Currency Kiosk Licensing Laws
Three US states enacted virtual currency kiosk laws in April 2026. Virginia House Bill 665, Kentucky Senate Bill 189, and 2025 Wisconsin Act 226 each impose licensing duties on kiosk operators. The laws layer in transaction limits, customer disclosures, and fraud protections aimed at scams targeting older adults. Effective dates and limit thresholds differ across the three regimes. Operators with multistate footprints must reconcile diverging compliance calendars.
Federal Court Pauses Enforcement of Colorado AI Act on April 27, 2026
On 27 April 2026, Magistrate Judge Cyrus Y. Chung of the U.S. District Court for the District of Colorado paused enforcement of the Colorado Artificial Intelligence Act, Senate Bill 24-205. The order followed a suit filed by xAI Corp. seeking a preliminary injunction. Attorney General Phil Weiser cannot pursue alleged violations of the 2024 statute within 14 days of the court ruling on that motion. The statute's 30 June 2026 implementation date remains scheduled.
New York AG Secures $5 Million Settlement from Uphold Over CredEarn Yield Product
On 29 April 2026, New York Attorney General Letitia James announced a settlement with Uphold HQ Inc. The crypto platform must pay over $5 million to investors who lost money in CredEarn, the yield product issued by Cred LLC. Uphold must also register as a broker with the Office of the Attorney General and adopt new third-party diligence requirements. The action rests on findings that Uphold misleadingly promoted CredEarn before Cred collapsed in 2020.
Australia: 30 June 2026 deadline for digital asset firms to apply for an AFS licence
ASIC has set 30 June 2026 as the cut-off for digital asset financial service providers in Australia to apply for an Australian Financial Services licence, or risk operating in breach of the law.
South Africa's prediction markets sit in a regulatory grey zone
An ENS analysis maps how prediction market contracts in South Africa cut across crypto regulation, exchange control and the law of derivatives, exposing a gap that regulators have yet to close.
FCA Publishes Policy Statement PS26/7 on Fund Tokenisation via DLT, United Kingdom, April 2026
The Financial Conduct Authority (FCA) published Policy Statement PS26/7: Progressing Fund Tokenisation on 30 April 2026, along with final rules amending the FCA Handbook. PS26/7 sets out guidance for asset managers on how to use distributed ledger technology (DLT) within the FCA's existing rules when tokenising funds, and introduces an optional Direct to Fund (D2F) dealing model. The policy statement and rules are operative with immediate effect upon publication. The controlling authority for
FCA Opens Pre-Application Support for UK Cryptoasset Authorisation, PASS from 11 May 2026
The Financial Conduct Authority (FCA) announced on 30 April 2026 that cryptoasset firms preparing for the new Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (the Crypto Regime) may request pre-application meetings via its Pre-Application Support Service (PASS) starting 11 May 2026. Pre-application meetings are free of charge and give firms the opportunity to discuss their regulatory plans and ask questions before submitting a formal authorisation application or
India Notifies Promotion and Regulation of Online Gaming Rules 2026, Effective 1 May 2026
India's Ministry of Electronics and Information Technology (MEITY) notified the Promotion and Regulation of Online Gaming Rules, 2026 (the Rules) on 22 April 2026, pursuant to the Promotion and Regulation of Online Gaming Act, 2025 (the Act). The Rules took effect from 1 May 2026. The Act was enacted by Parliament in August 2025 and replaced, to the extent of conflict, state-specific gambling legislation and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code)
UK Supreme Court Overrules Aerotel Test for AI Patent Eligibility in [2026] UKSC 3
The Supreme Court of the United Kingdom delivered judgment in Emotional Perception AI Limited (Appellant) v Comptroller General of Patents, Designs and Trade Marks (Respondent) [2026] UKSC 3 on 11 February 2026. The Court allowed the appeal unanimously, set aside the UKIPO's decision refusing the patent application, and remitted the matter to the UKIPO for assessment of novelty and inventive step. The decision has immediate operative effect and withdraws the UKIPO's 30 January 2025 guidelines
MAS Consults on Prudential Treatment of Cryptoassets on Permissionless Blockchains, Singapore, April 2026
The Monetary Authority of Singapore (MAS) published Consultation Paper P009-2026 on 17 April 2026, proposing a framework for the prudential treatment of cryptoassets held on permissionless blockchains. The consultation is open until 18 May 2026 at 11:59 PM. The paper addresses the classification of permissionless-blockchain cryptoassets for capital adequacy, credit risk, and liquidity risk purposes under Singapore's banking and financial institution regulations. MAS proposes to allow banks to
Australia Enacts Corporations Amendment (Digital Assets Framework) Act 2026, ASIC Issues Implementation Roadmap
The Corporations Amendment (Digital Assets Framework) Act 2026 (the DAF Act) passed the Australian Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and will commence on 9 April 2027. On 20 April 2026, the Australian Securities and Investments Commission (ASIC) published its implementation roadmap setting out the regulatory guidance and operational standards it will develop over the 18-month transition period. The DAF Act and the ASIC roadmap are operative in the preparatory
UK FCA Applies Existing Regulatory Rules to Artificial Intelligence in Financial Services, 2024
The UK Financial Conduct Authority (FCA) published its formal approach to artificial intelligence in financial services in 2024, declaring that it would not introduce a bespoke AI-specific rulebook. The approach is operative: the FCA applies its existing Principles for Businesses, Consumer Duty, operational resilience standards, and Senior Managers and Certification Regime (SM&CR) accountability rules to AI systems deployed by regulated firms. The FCA simultaneously launched an AI Lab to
California Governor Newsom Issues Executive Order N-5-26 on AI Procurement Standards, March 2026
California Governor Gavin Newsom issued Executive Order N-5-26 on 30 March 2026. The order is in effect immediately upon issuance and directs the California Government Operations Agency (GovOps) to develop a plan for new state contracting processes and best practices for AI companies seeking state contracts. The order is at the executive direction stage: GovOps must produce the procurement plan within a specified period, and no statutory changes are required. The California Department of
EU DAC8 Directive Mandates Crypto-Asset Reporting by Member State Tax Authorities from 2026
Council Directive (EU) 2023/2226 of 17 October 2023, known as DAC8, entered into force on 12 December 2023 and amended Directive 2011/16/EU on administrative cooperation in the field of taxation. Member States must transpose DAC8 into national law by 31 December 2025, with the reporting obligations applying to reportable transactions completed from 1 January 2026 onward. DAC8 is fully operative as of the 2026 reporting year, with the first automatic exchange of information between tax
US FDIC Approves Proposed Rule Implementing GENIUS Act for Payment Stablecoins, April 2026
On 7 April 2026, the Federal Deposit Insurance Corporation (FDIC) Board of Directors voted at an open board meeting to approve a notice of proposed rulemaking (NPR) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The proposed rule is at the notice-and-comment stage and will be published in the Federal Register, with public comments accepted for 60 days following publication. The proposed rule would apply to FDIC-supervised permitted payment
Colorado AI Act SB24-205 Takes Effect February 2026 as Enforcement Delayed Pending Rulemaking
Colorado Senate Bill 24-205, the Colorado Artificial Intelligence Act (the "AI Act"), entered into force on 1 February 2026 pursuant to its statutory effective date following enactment by Governor Jared Polis on 17 May 2024. The law requires developers and deployers of high-risk artificial intelligence systems to use reasonable care to protect consumers from known or reasonably foreseeable risks of algorithmic discrimination. The Colorado Attorney General stated in a court filing that the
UK High Court Continues Cryptoasset Freezing Injunction Against Unknown Persons, January 2026
On 23 January 2026, Mr Justice Waksman of the Business and Property Courts of England and Wales (Commercial Court) handed down judgment in Smithers & Anor v Persons Unknown Category 1 & Ors [2026] EWHC 207 (Comm), continuing a freezing injunction over cryptocurrencies originally granted on 13 November 2025. The claim arises from the alleged wrongful removal of cryptocurrencies held by the claimants, who were deceived into parting with the assets by unnamed primary respondents. The judgment
Ireland Court of Appeal Sets AI Disclosure Rules for Litigation Parties, March 2026
On 26 March 2026, the Court of Appeal of Ireland handed down judgment in Guerin v O'Doherty [2026] IECA 48, in which the President of the Court, Ms Justice Costello, set out guidelines on the use of artificial intelligence by parties in litigation. The judgment addresses the procedural obligations arising when AI tools assist in preparing written submissions and marks the first time an Irish appellate court has issued structured AI-use guidelines binding on parties appearing before it. The
UK Automated Decision-Making Rules Under Data (Use and Access) Act 2025 Enter Force, February 2026
The Data (Use and Access) Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026, S.I. 2026/82, brought section 80 of the Data (Use and Access) Act 2025 into force on 5 February 2026. Section 80 replaces Article 22 of the UK General Data Protection Regulation with a new four-article automated decision-making structure. The commencement is at the final, operative stage. The controlling authority is section 80 of the Data (Use and Access) Act 2025 (c. 18), which
UK Stablecoin Payments: HM Treasury Publishes Draft Amending SI to Cryptoassets Regulations, April 2026
On 21 April 2026, HM Treasury published a draft statutory instrument (SI) and accompanying policy note proposing amendments to the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026. The draft SI is at the consultation stage; Treasury is inviting written responses from industry participants until close of business on 22 May 2026. No provisions are yet in force. The controlling authority is the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, made
CSA Launches Project Tokenization to Examine Distributed Ledger Technology in Canadian Capital Markets, March 2026
On March 31, 2026, the Canadian Securities Administrators (CSA) announced the launch of Project Tokenization, a formal initiative within the CSA Collaboratory, to examine how distributed ledger technology (DLT) intersects with Canada's existing securities laws. The initiative is in the active engagement phase. The CSA invited a broad range of market participants to participate in regulatory workshops, with the first workshop scheduled in Calgary on April 9, 2026, and a second in Toronto on
FDA and EMA Issue Joint Guiding Principles of Good AI Practice in Drug Development, January 2026
In January 2026, the U.S. Food and Drug Administration (FDA), through its Center for Drug Evaluation and Research (CDER) and Center for Biologics Evaluation and Research (CBER), jointly published with the European Medicines Agency (EMA) a set of ten guiding principles for the use of artificial intelligence (AI) in drug and biological product development. The document is final and published; it carries no binding legal force as a regulation but constitutes authoritative guidance from two of
CSA and CIRO Issue Guidance on Prediction Market Regulation in Canada, April 2026
On April 2, 2026, the Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) jointly issued a public notice reminding industry participants and investors of the existing regulatory requirements that govern prediction markets and event contracts in Canada. The notice is at the final, published stage and carries immediate compliance effect across all CSA jurisdictions. The controlling authority is the securities and derivatives legislation applicable
UK FCA Publishes CP26/13 Cryptoasset Perimeter Guidance Consultation, April 2026
The Financial Conduct Authority (FCA) published Consultation Paper CP26/13 ("Cryptoasset Perimeter Guidance") in April 2026, seeking public comment on draft guidance that defines which cryptoasset activities will require FCA authorisation under the new UK regulatory regime. The consultation is at the open consultation stage, with responses due by 3 June 2026. The FCA plans to publish final perimeter guidance in autumn 2026 and final rules in policy statements in summer 2026. The controlling
UK ICO Publishes Report and Draft Guidance on AI and Automated Decision-Making in Recruitment, March 2026
On 31 March 2026, the Information Commissioner's Office (ICO) published a report and draft guidance on automated decision-making (ADM) in recruitment. The ICO engaged more than thirty employers and issued written notices to sixteen organisations using ADM in hiring. Those sixteen organisations committed to implementing recommended improvements. The report and draft guidance address the full lifecycle of AI-driven recruitment tools, from CV screening to scoring of online assessments. The
Licentium: Applied Legal Research for Crypto and AI Products
Licentium is a legal-tech research and execution team for crypto, digital-asset, and AI products. We help teams classify their product, choose the right licence path, prepare filing materials, and keep operations aligned with public rules after launch.
Tokenization of Real-World Assets: Legal Challenges and Considerations
Tokenising real-world assets sits at the intersection of securities law, custody, AML, and property law. A walk-through of the technical process, the legal challenges, and the use cases driving adoption.
Understanding Utility Tokens under MiCA: Classification, Requirements, and Issuers' Obligations
MiCA defines utility tokens narrowly. This guide explains where utility tokens sit in the MiCA classification, what disclosures issuers must make, and which exemptions apply.
NFTs and Intellectual Property: A Comprehensive Legal Guide for Creators and Investors
How copyright, fair use, and licensing apply to NFTs. A practical guide for creators and investors on what they actually own when they mint or buy a non-fungible token.
A Comprehensive Guide to DAO Governance: Key Principles and Best Practices
The principles, frameworks, and best practices behind effective DAO governance. From decentralisation and transparency to multi-sig wallets and dispute resolution, with notes on jurisdictional risk.
Understanding DAO Voting Mechanisms: Challenges, Ideas, and Risks
One token one vote, quadratic, conviction, holographic. The voting mechanisms DAOs actually use, what each one optimises for, and the legal risks each one creates.
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