Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

2 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 • Market engagement: collaborating with payment providers, merchants and consumers to finalise the rulebook, conduct user research and test the system through pilot activities; and • Legislative process support: continue providing technical input to EU co-legislators and assist the legislative process as required. The ECB says that the Eurosystem’s continued preparation for a digital euro will be implemented flexibly, ensuring alignment with the legislative process. To this end, work will be structured in modules to enable gradual scaling and limit financial commitments. Link to ECB Press Release here CRYPTOASSETS FSB Finds Significant Gaps and Inconsistencies in Implementation of Crypto and Stablecoin Recommendations On 16 October 2025, the Financial Stability Board (FSB) published ‘Thematic Peer Review on the FSB Global Regulatory Framework for Crypto-asset Activities’. The FSB says that the thematic report describes the findings of a peer review to evaluate progress in implementing the FSB’s 2023 global framework, including recommendations on crypto-asset service providers and stablecoin arrangements, data reporting and collection, and cross-border cooperation and coordination. The FSB states that crypto-asset markets and regulation are changing rapidly, and the review shows that, as of August 2025, jurisdictions have made progress in regulating crypto-asset activities and to a lesser extent global stablecoin arrangements (GSCs). However, it also reveals significant gaps and inconsistencies that could pose risks to financial stability and to the development of a resilient digital asset ecosystem. While jurisdictions have made notable advancements toward implementing the recommendations on crypto-asset markets and activities, the FSB says that few have finalised their regulatory frameworks for GSCs. Even where regulatory frameworks are finalised, full alignment with the FSB recommendations remains limited, especially with regard to stablecoin arrangements and crypto- asset service providers. Moreover, jurisdictions may continue to update, modify, or refine their frameworks. The thematic review calls on the FSB and its member jurisdictions to prioritise work in this area and to do more to reach full and consistent implementation. Specifically, it puts forward some recommendations to address outstanding issues in terms of implementation progress, comprehensiveness and consistency, and cross-border cooperation and coordination. On the same day, the International Organization of Securities Commissions (IOSCO) (see next item) also released the results of a thematic review on the implementation of IOSCO’s Crypto and Digital Asset framework. A joint information note provides an overview of the scope and the findings of the FSB and IOSCO’s complementary reports. Link to Thematic Review here Link to Joint Information Note here IOSCO Reviews Implementation of Recommendations for Crypto and Digital Asset Markets On 16 October 2025, IOSCO published its Final Report (“Final Report”) on its Thematic Review Assessing the Implementation of IOSCO Recommendations for Crypto and Digital Asset (CDA) Markets. IOSCO says that its Thematic Review was conducted jointly by its Fintech Task Force and Assessment Committee. With a focus on investor protection and market integrity, the Thematic Review examined how twenty jurisdictions, from both advanced and emerging economies, have implemented a set of IOSCO’s 2023 Policy Recommendations for Crypto and Digital Asset Markets.