Global Trustee and Fiduciary Services Bite-Sized Issue 12 2025

3 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 Key Findings of the Report are: • Tokenisation is growing but remains nascent. Commercial interest is rising, but adoption is still limited. Interoperability challenges and the lack of credible settlement assets hinder scalability. • Efficiency gains are uneven. Tokenisation can shorten settlement cycles and improve collateral mobility, but many market participants still rely on traditional infrastructure for trading and post-trade processes. • Risks are familiar but evolving. Legal uncertainty, operational vulnerabilities, and cyber risks mirror existing risk categories but manifest differently under distributed ledger technologies requiring tailored risk controls. • Regulatory approaches vary. Some IOSCOmembers apply existing frameworks; others have issued new guidance, sandbox programs, or bespoke requirements. Consistent with the principle of “same activities, same risks, same regulatory outcomes”, IOSCO encourages regulators to consider applying its Policy Recommendations for Crypto and Digital Asset Markets and Policy Recommendations for Decentralised Finance in the context of tokenised financial assets. Link to Report here Bank of England Launches Consultation on Regulating Systemic Stablecoins On 10 November 2025, the Bank of England (the Bank) published a consultation paper setting out its proposed regulatory regime for sterling-denominated systemic stablecoins. Such stablecoins are a new type of digital money designed to maintain a stable value and could be used for retail payments and wholesale settlement in the future. The Bank says its regime would not cover stablecoins used as assets for non-systemic purposes, such as the buying and selling of cryptoassets, which is the predominant use of stablecoins today. Those will be supervised by the Financial Conduct Authority (FCA). Key policy proposals covered in the consultation paper include: Backing Assets: In response to feedback, systemic stablecoin issuers will be permitted to hold up to 60% of backing assets in short-termUK government debt. For the remaining 40%, the Bank will, as previously proposed, provide issuers unremunerated accounts at the Bank of England, ensuring robust redemption and public confidence, even under stress. Additionally, those issuers considered systemic at launch, or transitioning from the FCA regime, will initially be able to hold up to 95% of backing assets in short-termUK government debt, to support their viability as they grow. In a new proposal, the Bank is also considering central bank liquidity arrangements to support systemic stablecoin issuers in times of stress. These arrangements would reinforce financial stability by providing a backstop should systemic issuers be unable to monetise their backing assets in private markets. Holding Limits: To safeguard continued access to credit as the financial system gradually adapts to new forms of digital money, the Bank is proposing temporary holding limits of GBP 20,000 per coin for individuals and GBP 10 million for businesses (with an exemptions regime to allow the largest businesses to hold more if required). These limits would be removed once the transition no longer poses risks to the provision of finance to the real economy. These limits would not apply to stablecoins used for settling wholesale financial market transactions in the Bank and FCA’s Digital Securities Sandbox. Additionally, on the same day, the Bank published an approach to quantifying the risks to the provision of finance to the economy from potentially significant and rapid outflows of bank deposits into new forms of digital money. The Bank says this analysis has shaped the proposed holding limits, and the consultation paper also invites feedback on alternative mechanisms for managing these risks.