Global Trustee and Fiduciary Services Bite Sized Issue 8 2025

3 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 The rules, and guidance contained in a supervisory statement on Fundamental Rules for FMIs, will take effect on 18 July 2026. Link to Policy Statement here EMIR Ensuring the Resilience of CCPs On 18 July 2025, the Bank of England (BoE) published a consultation on key elements of the UK’s future regulatory framework for Central Counterparties (CCPs). The BoE is consulting on proposals to restate certain CCP-facing requirements in UK EMIR in its rules, alongside other policy changes outlined in the consultation paper. These proposed policies aim to support financial stability and the economy more broadly, including by increasing the effectiveness of the BoE’s supervisory practices, enhancing the financial resilience of CCPs and encouraging innovation. The consultation paper also contains a discussion section on eligible collateral for posting to CCPs. The response period for the consultation closes on 18 November 2025. Link to Consultation here FINTECH FCA Invites Applications for AI Live Testing On 9 July 2025, the Financial Conduct Authority (FCA), invited interested firms to submit their artificial intelligence (AI) systems for live testing as part of the FCA’s AI Lab. The FCA says it will provide participants with access to appropriate AI expertise in addition to regulatory expertise. It says it will also seek to understand the nature of any emerging regulatory challenges firms may face. The FCA says AI Live Testing involves the deployment of AI systems in controlled live market environments and engaging with real customers and is designed as a service to help those firms further along in the process of developing an AI system and who are ready to begin using AI in real- world contexts. To be eligible firms must demonstrate that they: • Produce and distribute financial products and services or provide AI models that are material to financial services and markets. • Actively use AI within their specific use case. • Have a material AI use case that is relevant to financial services and markets. • Have a use case that is likely to further one or more of the FCA’s operational objectives and has the potential to positively contribute to UK economic growth. • Have already developed an AI solution Proof of Concept and have plans to deploy it. • Have already considered pre-deployment testing and be willing to share their approach and findings to ensure readiness for live market rollout. • Have considered post-deployment monitoring plans, including demonstrating how this would be carried out. • Are open to work collaboratively with the FCA and share their findings with the FCA during live testing. The current round of applications is open until 20 August 2025. Link to AI LabWebpage here