Global Trustee and Fiduciary Services Bite Sized Issue 8 2025

10 QUICK LINKS CBDC CRYPTOASSETS CSDR EMIR FINTECH FSB OPEN FINANCE OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG ASIA PACIFIC NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 8 | 2025 Dutch AFMCSRD Sustainability Report Provides Valuable Insights On 3 July 2025, the Dutch Authority for the Financial Markets (AFM) published the results of a thematic review of 2024 sustainability reports, focusing on the identification and assessment of sustainability impacts, risks and opportunities, the related disclosures and the effect on strategy and business models. In the report, the AFM complimented companies on their progress, and noted that the information is more structured, more accessible, and more visual than in previously published sustainability reports. At the same time, the AFM highlighted the following three focus areas in its report to enable companies to further strengthen their sustainability reporting: 1. Materiality assessment : explain how impacts, risks and opportunities are identified. This will make it easier to understand the choices made regarding the material topics. 2. Assessment: clarify the considerations for each sustainability topic (such as biodiversity and pollution). Explain how assessments were made. This will make the assessment more transparent and easier to follow. 3. Effects : disclose the interaction between impacts, risks and opportunities with the strategy and business model. Investors and other stakeholders want to know how sustainability risks and opportunities impact the business model. Companies that clearly demonstrate this interaction provide valuable insights for the future. Link to Report here ASIA PACIFIC ASIC Seeks Feedback on Proposed Updates to Conflicts Management Guidance On 30 July 2025, the Australian Securities & Investments Commission (ASIC) published proposed updates to its conflicts management guidance for financial services businesses. ASIC says the proposed changes will align the guidance with developments in law and policy and have been informed by ASIC’s private markets surveillance work. The updated guidance sets out how Australian financial services (AFS) licensees should comply with their conflicts management obligation and explains: • How the law applies, including its scope and interaction with other related obligations; • The types of conflicts AFS licensees need to identify and manage to meet their obligation; • The need to have robust and tailored arrangements that are adequate to manage conflicts; and • How licensees can effectively manage conflicts. The updated guidance includes a roadmap that sign-posts other related conflicts management obligations that AFS licensees need to be aware of. The response period for the consultation closes on 5 September 2025. Link to Consultation here SFC Consults on Financial Resources Rule Enhancements to Foster Market Developments for OTC Derivatives and Other Products On 14 July 2025, the Securities and Futures Commission (SFC) published a consultation on draft amendments to the Securities and Futures (Financial Resources) Rules (FRR) and related guidelines for implementing a set of internationally comparable capital requirements for licensed corporations (LCs) engaging in over-the-counter derivative activities (OTCD capital requirements). Under the proposal, the OTCD capital requirements previously proposed in 2017 have been fine- tuned with reference to recent changes to Hong Kong’s Banking (Capital) Rules and the Basel Framework. The capital requirements for inter-dealer brokers will also be lowered and transfer pricing treatments for LCs will be simplified to reflect the comments received during the SFC’s 2017 consultation.