Global Trustee and Fiduciary Services Bite-Sized Issue 9 2024

10 QUICK LINKS AI DORA FUND LIQUIDITY MIFID II/MIFIR SUSTAINABLE FINANCE/ ESG TOKENISATION AUSTRALIA ASIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 9 | 2024 Treasury Unveils NewCFIUS Enforcement Website to Provide Further Clarity and Transparency Regarding CFIUS Penalties and Other Enforcement Actions On 14 August 2024, the Treasury Department updated the Committee on Foreign Investment in the United States (CFIUS) website to share more details and guidance with the public and the investing community about how CFIUS approaches compliance and enforcement, as well as a list of its penalty actions. The updates revealed that in 2023 and to date in 2024, CFIUS has issued three times more penalties than it had in the previous nearly 50-years since its establishment. CFIUS is an interagency committee authorized to review certain transactions involving foreign investment in the United States in order to determine the effect of such transactions on the national security of the United States. The Treasury Department chairs CFIUS. The website update shares detailed information about all the civil monetary penalties imposed by CFIUS over the last few years, including the largest penalty CFIUS has ever issued. For each penalty action, CFIUS is providing added transparency by describing the nature of the conduct that gave rise to the penalty and mitigating and aggravating factors, among other details, where applicable and consistent with the CFIUS’s confidentiality obligations. In 2023 and 2024 to date, CFIUS has issued three times more penalties than CFIUS had previously issued in its nearly 50-year history. Link to Press Release here SEC Proposes Joint Data Standards Under the Financial Data Transparency Act of 2022 On 2 August 2024, the SEC proposed joint data standards under the Financial Data Transparency Act of 2022 (FDTA) that would establish technical standards for data submitted to certain financial regulatory agencies. The proposed joint standards would include: • Eight common identifiers related to entities, geographic locations, dates, and certain products and currencies; • A principles-based joint standard with respect to transmitting and structuring data; and • A definition of “collections of information” in accordance with the Paperwork Reduction Act of 1995. Eight additional agencies have proposed or are expected to propose the joint standards: the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Consumer Financial Protection Bureau, the Department of the Treasury, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the National Credit Union Administration, and the Office of the Comptroller of the Currency. The proposed joint standards would promote interoperability of financial regulatory data across the agencies by establishing common identifiers for entities, geographic locations, dates, and certain products and currencies. In addition, the proposal would establish a principles-based joint standard with respect to data transmission and schema and taxonomy formats, which would enable financial institutions to submit high-quality, machine-readable data to the agencies. The public comment period for the proposed joint standards will remain open for 60 days following publication in the Federal Register. Link to Press Release here Link to Proposal here