Global Trustee and Fiduciary Services Bite-Sized Issue 10 2024

12 QUICK LINKS CBDC CRYPTOASSETS FINTECH LIBOR TRANSITION OPERATIONAL RESILIENCE PRIIPS SUSTAINABLEFINANCE/ESG T+1 ASIA/PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2024 ASIC also released minor updates to Regulatory Guide 274 Product design and distribution obligations (RG 274) to provide greater clarity around ASIC’s guidance on the appropriateness requirement for target market determinations (TMDs). The changes to RG274 will not require product issuers to update their TMDs. Link to Report 795 here Link to Regulatory Guide 274 here EUROPE ESMA Publishes its 2025 Annual Work Programme On 1 October 2024, the European Securities and Markets Authority (ESMA) published its 2025 Annual Work Programme (AWP). ESMA says a significant portion of its work in 2025 will comprise policy work to facilitate the implementation of the large number of mandates received in the previous legislative cycle, and the preparation of newmandates, such as the European Green Bonds and the ESG Rating Providers Regulations. Following the adoption of EMIR 3, ESMA will take on new responsibilities and develop a substantial number of technical standards, including for the new Active Account Requirement. 2025 will also see the selection and authorisation of the first Consolidated Tape Provider, and the effective implementation of MiCA. The AWP underlines ESMA’s work on providing adequate opportunities for, and safeguarding the interests of, retail investors wishing to participate in EU capital markets. In addition to preparations for potential new responsibilities under the Retail Investment Strategy and for the possible shortening of the settlement cycle (T+1), key outputs include technical standards and guidelines under MiFIR/MiFID II and AIFMD/UCITS. ESMA says it will work to further strengthen supervision focusing on effective coordinated supervision across the EU financial markets. ESMA will continue to use all the tools in its convergence toolkit to further harmonise supervisory approaches and practices across its remit, including common supervisory actions, and practical exchanges on specific supervisory cases and challenges. ESMA says it will work closely with the national competent authorities to enhance cross-border cooperation and data-sharing. Through the continued implementation of its Data Strategy and the development of common SupTech and data projects, ESMA says it will be contributing to the EU strategy on supervisory data in financial services. In 2025, ESMA says it expects to finalise preparations to launch the first phase of the European Single Access Point (ESAP) in 2026, aiming to create a centralised platform for easy access to public data and information on securities markets. Link to the 2025Work Programme here ESAs Warn of Risks from Economic and Geopolitical Events On 10 September 2024, the European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) issued their Autumn 2024 Joint Committee Report on risks and vulnerabilities in the EU financial system. The Report underlines ongoing high economic and geopolitical uncertainties. The ESAs warn national supervisors of the financial stability risks stemming from these uncertainties and call for continued vigilance from all financial market participants. For the first time, the Report also includes a cross-sectoral deep dive into credit risks in the financial sector. The Joint Committee of the ESAs advises national competent authorities, financial institutions and market participants to take the following policy actions: • Financial institutions and supervisors should remain prepared to face the impacts of continued high interest rates on the real economy;