Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

13 QUICK LINKS AIFMD CBDC CRYPTOASSETS DIGITAL ASSETS FINTECH FSB MIFID/MIFIR (UK) IFR/IFD OPERATIONAL RESILIENCE OUTSOURCING SUSTAINABLE FINANCE/ESG T+1 TOKENISATION ASIA PACIFIC EUROPE NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 11 | 2025 Commenting on its discussion chapters, the FCA says that these look at how it can ensure its rulebook is fit for the future. The FCA explore what regulatory changes may be needed to promote future fund tokenisation, such as the use of digital cash settlement instruments, or money-like instruments (e.g. stablecoins) for unit deals. The FCA also discuss a future vision where firms may use DLT to support retail-scale portfolio management services, including via model portfolios. The deadline for response on the proposals that are contained in Chapters 2-4 is 21 November 2025 and for its future tokenisation models is 12 December 2025 (see Chapter 5). Link to CP25/28 here ASIA PACIFIC MAS Consults On Measures To Enhance Investors’ Ability To Seek Civil Compensation For Losses Suffered Due To Market Misconduct On 24 October 2025, the Monetary Authority of Singapore (MAS) published a consultation paper seeking feedback on proposals to enhance investors’ ability to seek civil compensation for losses suffered frommarket misconduct. Over the course of the year, MAS says that the Equities Market Review Group has announced measures to increase investor interest, improve Singapore’s ecosystem’s attractiveness to quality listings, and adopt a more pro-enterprise regulatory stance while strengthening investor confidence. MAS states that an important plank of the Review Group measures is to strengthen investor protection through enhancing investor recourse avenues against market misconduct. MAS says that it has received feedback that retail investors face friction in commencing civil action, such as difficulty in self-organising, and finding sufficient funds for legal advice. Taking these into consideration, MAS is seeking feedback on proposals to strengthen the current investor recourse regime. At the same time, MAS says that whilst it is important to better enable investors to seek civil recourse, MAS has also heard feedback that there is also a need to guard against frivolous legal actions which would place undue burden on the market. MAS says that its proposals seek to put in place relevant safeguards to strike an appropriate balance. The consultation closes on 31 December 2025. Link to MAS Homepage here SFC Proposes to Enhance Hong Kong’s Retail Fund Code to Bolster Global Competitiveness On 22 October 2025, the Securities and Futures Commission (SFC) launched a consultation on proposed amendments to the Code on Unit Trusts and Mutual Funds (UT Code), which the SFC says will align Hong Kong’s regulatory regime for SFC-authorised funds with the latest international regulatory standards and broaden product offerings for investors. The SFC says that key revisions to the UT Code include allowing an alternative approach for managing derivative investments in retail funds, updating requirements for fund liquidity risk management, and enhancing the requirements for money market funds. Once implemented, the SFC states that the proposals will not only drive fund market growth but also strengthen the resilience of the Hong Kong’s asset management sector. The SFC will adopt a step-by-step approach to facilitate new fund offerings for retail access to private markets, first, by admitting listed closed-ended alternative assets funds, and then by allowing, on a case-by-case basis, greater flexibility for SFC-authorised unlisted funds to invest a larger portion in illiquid assets, subject to robust safeguards on the fund’s overall liquidity risk management.