Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

6 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 FSB FSB Chair: Incomplete Reform Implementation Leaves Financial SystemVulnerable to Shocks On 13 October 2025, the Financial Stability Board (FSB) published a letter from its Chair to G20 Finance Ministers and Central Bank Governors ahead of their meeting on 15 16 October. The FSB says that the letter is accompanied by an interim report from the G20 strategic review of the FSB implementation monitoring work, led by the former FSB Chair. In the current environment of elevated risks and uncertainty, the Chair’s letter highlights the importance of global standards and cooperation, not just to prevent crises, but also as a foundation to support sustainable growth. However, the FSB says that the preliminary results from the G20 strategic review of its implementation monitoring work show that full, timely and consistent implementation of G20/ FSB reforms has not been completely achieved, despite the active programme of implementation monitoring by the FSB and standard-setting bodies. The FSB says that significant inconsistencies in the implementation of global financial reforms can pose risks to market efficiency, financial stability and the integrity of the global regulatory framework. The FSB’s Chair reaffirms that the FSB remains steadfast in its mandate to promote timely and consistent implementation. The next phase of the G20 strategic implementation monitoring review will reflect on why implementation gaps exist and make specific recommendations to strengthen the FSB’s monitoring and implementation processes. The FSB also says that the adoption of artificial intelligence in the financial sector or the increasing use of stablecoins for payment and settlement purposes, for example, put a premium on the monitoring of emerging risks. To address this, the FSB will enhance its surveillance capabilities by improving its agility to recognise and respond to emerging vulnerabilities and strengthening engagement with stakeholders, including the private sector. Link to Letter here Link to G20 Implementation Monitoring Review–InterimReport here Link to Monitoring Adoption of AI and Related Vulnerabilities in the Financial Sector here MIFID/MIFIR (UK) FCA: PS25/13: The MiFID Organisational Regulation On 9 October 2025, the Financial Conduct Authority (FCA) published its Policy Statement on the MiFID Organisational Regulation (PS25/13). In CP25/13 the FCA summarises the feedback it received to CP24/24 and Chapter 4 of CP24/11 and sets out the FCA’s final rules to transfer the firm-facing requirements of the MiFID Org Reg into FCA Handbook rules. The FCA says that it is keeping the substance of the MiFID Org Reg requirements the same without any policy or scope changes. Most of the changes that have been made are to reflect the FCA’s Handbook drafting style and to clarify drafting where possible. The few exceptions are set out in the derivation and changes table in Annex 4. The FCA also states that it is implementing two changes that it consulted on in Chapter 4 of CP24/11. The FCA are removing the requirement to report a 10% drop in portfolio value to a retail client from Conduct of Business Sourcebook (COBS) 16A.4.3UK so it no longer applies as a rule to optional exempt (Article 3) firms, in line with MiFID firms. The FCA are also amending the definition of ‘durable medium’ in the Glossary to make electronic communications the default mode of communication with retail clients, reflecting changes previously made to the MiFID Org Reg. The rules in PS25/13 came into force on the 23 October 2025. The FCA explains that the changes to the durable medium definition will come into force three months after publication of the final rules on 12 January 2026. The removal of COBS 16A.4.3UK will come into force at the same time as the rest of the MiFID Org Reg transfer on 23 October 2025.