Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

3 QUICK LINKS FINTECH MIFID II/MIFIR OPEN FINANCE SUSTAINABLE FINANCE/ESG T+1 ASIA AUSTRALIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2025 Intermediaries are reminded to notify the SFC (and the HKMA, where applicable) before making changes to their virtual asset-related activities, including the following: a. The type(s) of clientele served; b. Allowing clients to deposit or withdraw virtual assets from the intermediaries’ accounts for the first time; c. Providing staking services to their clients for the first time; d. Allowing their clients to subscribe for or redeem products using virtual assets for the first time; or e. Other material changes made to the arrangements for such activities as first communicated in the advance notification. Link to Circular here AI Live Testing On 9 September 2025, the Financial Conduct Authority (FCA) published feedback statement FS25/5 summarising feedback on its artificial intelligence (AI) Live Testing as a result of its Engagement Paper published during April 2025. AI Live Testing is part of the FCA’s AI Lab. The FCA says its goal is to give firms the confidence to deploy AI systems in a way that drives growth and delivers positive outcomes for UK consumers and markets. The FCA says it also wants to work with industry to better understand potential AI risks and explore effective mitigation strategies, to support the FCA’s regulatory and supervisory approach to safe and responsible AI adoption in UK financial markets. AI Live Testing supports the UK Government’s AI Opportunities Action Plan, published in January 2025. The AI Opportunities Action Plan aims to help drive UK economic growth and efficiency with fifty recommendations for how the UK can shape the future of AI. The FCA asked for feedback on the potential benefits, opportunities and challenges raised by its proposals on AI Live Testing, which will enable firms to engage directly with its regulatory and technical teams, getting tailored support to develop, assess and deploy AI systems live in UK financial markets. This will include exploring output-driven validation and other methods to evaluate the impact of AI system use in UK financial markets. The FCA says it will start workingwith firms accepted in the first cohort of AI Live Testing fromOctober. Applications for a second cohort will open before the end of 2025. Link to FS25/5 here In addition to FS25/5, on 9 September 2025, the FCA published a webpage on its approach to AI. The FCA says it has frameworks in place that are relevant for using AI safely, with examples covering the Consumer Duty and the Senior Managers and Certification Regime. Link to AI and the FCA: Our Approach here Managing Explanations: How Regulators can Address AI Explainability On 8 September 2025, the Financial Stability Institute (FSI) published an Occasional Paper which aims to describe current regulatory guidance on AI model risk management (MRM); discuss existing challenges in applying it to AI models, especially in the context of limited explainability; and put forward considerations for addressing some of these challenges. For that purpose, the Occasional Paper reviews existing guidance on MRM, identifies elements related to model explainability, analyses the extent to which that guidance could be met by AI models and discusses possible elements of improvement in the current policy setup.