Global Trustee and Fiduciary Services Bite-Sized Issue 2 2025

14 QUICK LINKS BENCHMARKS REGULATION CRYPTOASSETS DORA EMIR FSB MIFID II/MIFIR MMF SUSTAINABLE FINANCE/ESG T+1 ASIA EUROPE INTERNATIONAL LUXEMBOURG NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 2 | 2025 ESMA: NewQ&As Available On 10 January 2025, the ESMA published or updated the following Questions and Answers: Alternative Investment Fund Managers Directive (AIFMD) • Permission of AIFMs to delegate portfolio or risk management to non-supervised undertakings established outside of the EU (2229) • AIFMs safekeeping client money (2230) Central Securities Depositories Regulation (CSDR) • Change of beneficial ownership (714) Digital Operational Resilience Act (DORA) • Questions on Microenterprises and RMF (2219) • ICT-related incidents (management/classification/reporting) – Critical Services Affected (EBA 2024_7047) • ICT-related incidents (management/classification/reporting) – Duplicate ICT Incident Reporting (EBA 2024_7050) • Oversight framework of CTPPs – Exemption for Non-EU ICT Intra-group Service Providers (EBA 2024_7096) Markets in Crypto-Assets Regulation (MiCA) • Possibility of natural persons and trusts/trustees to be authorised as CASPs (2342) • Minimum capital requirements for CASPs (2343) • Audit/certification of CASP financial statements (2344) OTC derivatives, central counterparties and trade repositories (EMIR) – CCPs • Calibration of confidence interval for CCP margin requirements (2010) Link to ESMA Update here INTERNATIONAL GFXC Updates FX Global Code and Enhances Disclosure Cover Sheets for Liquidity Providers and Platforms On 24 January 2025, the Global Foreign Exchange Committee (GFXC) announced it had completed its review of the FX Global Code (the Code). The December 2024 version of the Code, which will supersede the July 2021 version, updates its principles of good practice in the foreign exchange market in two key areas. Alongside the revised Code, the GFXC will also publish enhanced Disclosure Cover Sheets (DCS) for Liquidity Providers and Platforms. Updates have been made to five of the Code’s fifty-five principles to strengthen the Code’s guidance on FX Settlement Risk, as well as to increase transparency around certain types of FX transactions and the use of client-generated data on electronic trading platforms. In addition, the DCS for Liquidity Providers and Platforms were also extended with the objective to enhance transparency and comparability across providers on the use of FX data. The GFXC encourages the uptake of the DCS, which are available on the GFXC website.