Global Trustee and Fiduciary Services Bite-Sized Issue 9 2025

11 QUICK LINKS CRYPTOASSETS CYBERSECURITY EMIR (UK) FINTECH MIFID/MIFIR (UK) SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC AUSTRALIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 9 | 2025 ASIC to Review Superannuation Investment Requirements On 13 August 2025, ASIC announced that it had commenced a targeted review that may help boost investment in property by Australia’s superannuation funds. ASIC says that the review will focus on requirements to disclose stamp duty payments in Regulatory Guide 97 Disclosing fees and costs in PDSs and periodic statements (RG 97) . ASIC explains that concerns have been raised that the disclosure impacts performance test results and discourages investment in property by superannuation funds. The review will be led by ASIC and include industry representatives, and Treasury. The review will report by 30 November 2025. Link to ASICMedia Release here EUROPE ESRB Publishes EU NBFI Risk Monitor 2025 On 1 September 2025, the European Systemic Risk Board (ESRB) published the EU Non-bank Financial Intermediation Risk Monitor 2025 (NBFI Monitor), highlighting key cyclical and structural risks related to non-bank financial intermediation. The ESRB says that leverage, liquidity mismatches and interconnectedness remain key vulnerabilities across the NBFI sector. Though typically associated with alternative investment funds, high leverage is also prevalent in certain undertakings for collective investment in transferable securities (UCITS funds) designed for retail investors. These funds pursue hedge fund-like strategies, exposing them to significant market and liquidity risks. The ESRB also says that this year’s report examines the role of captive financial institutions (i.e. subsidiaries of non-financial companies providing financial services exclusively to the parent and its affiliates) in facilitating liquidity and financing within transnational corporations. It explores their interconnectedness with private equity and real estate funds and the systemic risks this could pose. The ESRB says that these topics, alongside carry trade activity by global hedge funds and the use of bank lending by real estate investment funds, are covered in five special features. Additionally, the report looks at the growing importance of private finance, with non-bank credit provision increasingly complementing traditional bank funding. Link to NBFI Risk Monitor 2025 here LUXEMBOURG Dedicated Data Entry Form for Updating Investment Firm Information On 8 August 2025, the Commission de Surveillance du Secteur Financier (CSSF) announced that, with a view to optimising processes, it has developed a dedicated data entry form for updating investment firm information. Any update/change subject to prior authorisation or notificationmust henceforth be communicated to the CSSF using the duly completed dedicated data entry form. Examples of information updates or requests for change concerned (non-exhaustive list) which must be submitted using the Excel files: • Update of the general entity information (e.g., company name, address, contact persons, date of the General Meeting, articles of incorporation, etc.); • Request to change the services and activities provided; • Request to change the management bodies (Board of Directors and authorised management); • Request to change the shareholders with a qualifying holding; • Update of the information on the shareholders, including those without a qualifying holding;