Global Trustee and Fiduciary Services Bite Sized Issue 8 2025

4 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 ECB Commits to Distributed Ledger Technology Settlement Plans with Dual-track Strategy On 1 July 2025, the European Central Bank (ECB) Governing Council announced that it had approved a plan that will enable settling distributed ledger technology (DLT) transactions using central bank money. The initiative follows a two-track approach: • “Pontes” which provides a short-term offering to the market linking DLT platforms and TARGET Services to settle transactions in central bank money – including a pilot phase to launch by the end of the third quarter of 2026; and • “Appia” which focuses on a potential long-term approach for an innovative and integrated ecosystem in Europe that also facilitates safe and efficient operations at the global level. The decision is in line with the Eurosystem’s commitment to supporting innovation without compromising on safety and efficiency in financial market infrastructures. The EBC says that to ensure continuous dialogue with the market, the Eurosystemwill establish dedicated market contact groups for both Pontes and Appia. A call for expressions of interest in participating in the Pontes contact group will be published soon. Link to Announcement here FSB FSB Publishes Recommendations to Address Financial Stability Risks Created by Leverage in Nonbank Financial Intermediation On 9 July 2025, the Financial Stability Board (FSB) published three reports related to its work programme to enhance resilience in nonbank financial intermediation (NBFI). Final policy recommendations to address financial stability risks created by NBFI leverage The recommendations on NBFI leverage set out an integrated approach for addressing financial stability risks created by NBFI leverage. Under this approach, authorities should identify such risks and have appropriate policy measures in place to address the risks they identify. The recommendations provide authorities with flexibility to tailor their policy responses to their jurisdiction-specific circumstances. This includes selecting, designing, and calibrating policy measures – or combinations of measures – that address financial stability risks, while considering potential adverse effects. Authorities will share their policy responses, for example, through FSB supervisory discussions. The recommendations are directed at FSB member authorities and focus on markets, entities, and activities where NBFI leverage poses financial stability risks. The recommendations reflect feedback from a public consultation. In particular, the FSB acknowledges the high degree of heterogeneity of nonbanks; that leverage in some NBFI segments is relatively limited and is not likely to pose financial stability risks; the differences between banks and various types of nonbanks, which have motivated different regulatory approaches; and that certain leveraged activities by nonbanks can facilitate hedging, enhance efficiency and support liquidity in financial markets. Annual NBFI progress report The 2025 NBFI Progress Report notes that the work carried out to date largely completes the original policy elements of the FSB’s NBFI work programme, which were agreed upon in response to the March 2020 market turmoil. The FSB’s work will now shift from policymaking to assessing vulnerabilities, addressing data challenges, sharing members’ policy insights, and evaluating the implementation and impact of reforms. Workplan to address nonbank data challenges In carrying out the NBFI work programme, the FSB identified several data challenges that hinder authorities’ ability to effectively assess vulnerabilities in the nonbank sectors. To address this, the FSB has established the Nonbank Data Task Force (NDTF), chaired by the FSB Chair, Andrew Bailey. The NDTF has three objectives:

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