Global Trustee and Fiduciary Services Bite-Sized Issue 12 2025

20 QUICK LINKS COSTS & CHARGES CRYPTOASSETS FINTECH FSB IOSCO OPERATIONAL RESILIENCE SAVINGS AND INVESTMENT UNION SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 12 | 2025 SEC Chair Paul Atkins Delivers Remarks on Digital Asset Oversight On 12 November 2025, SEC Chair Paul Atkins delivered remarks describing the SEC’s direction for digital asset oversight under “Project Crypto.” In his speech, Chair Atkins addressed whether crypto assets should be considered securities, stating that “crypto asset” is not a term defined in the federal securities laws. Chair Atkins stated that he believes most crypto tokens trading are not themselves securities, but that a tokenmay have been sold as part of an investment contract in a securities offering. He noted, however, that investment contracts can be performed, and they can expire, and that they do not last forever because they trade on a blockchain. Chair Atkins then discussed his guiding principles when applying securities laws to crypto tokens and transactions: (i) securities, however represented, are securities; and (ii) economic reality trumps labels, which means that calling something a token or an NFT does not exempt it from current securities laws. Chair Atkins then outlined his thinking on the various categories of crypto assets, which are as follows: • Digital commodities or network tokens are not securities, because they are intrinsically linked to and derive their value from a programmatic operation of a crypto system that is functional and decentralized, and purchasers of digital commodities are not expecting profits from the efforts of others. • Digital collectibles are not securities, because they are designed to be collected or used and may represent or convey rights to artwork, music, videos, trading cards, among other things, and that purchasers of digital collectibles are not expecting profits from the efforts of others. • Digital tools are not securities, because they perform a practical functions such as membership, ticket, credential, title instrument or identity badge and purchasers are not expecting profits from the efforts of others. • Tokenized securities are securities because they represent ownership of a financial instrument enumerated in the definition of a security. Chair Atkins also discussed the regulation of crypto assets, voicing his support to the legislation before Congress related to crypto assets. He highlighted his hope that the SEC consider a package of exemptions to create a tailored offering regime for crypto assets that are part of or subject to an investment contract. He indicated his request to the SEC Staff to prepare recommendations for the SEC’s consideration that facilitate capital formation and accommodate innovation, while protecting investors. Link to Speech here UNITED KINGDOM RegData Access now Through My FCA On 27 November 2025, the Financial Conduct Authority (FCA) announced that its was making it easier for firms to access FCA regulatory reporting systems. Beginning 28 November 2025, access to RegData is through sign in to My FCA. The FCA said that over the coming months, this will also include Connect and Online Invoicing System, so that everything firms need will be in one place. All RegData sign-in links and bookmarked pages will automatically redirect to My FCA. After signing in, firms will be able to view their details and scheduled tasks along with the due date and status. There are also links to other resources in My FCA including system notices and regulatory updates. Link to My FCA here