Global Trustee and Fiduciary Services Bite-Sized Issue 9 2025

5 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 This is why, they explain, the FCA is proposing AI Live Testing – a practical, collaborative way for firms and the FCA to explore methods to assure AI systems together. In their blog update on the FCA website, they then set out why firms should apply to take part. Areas covered include: • The promise of AI; • The regulatory challenge: clarity without closure; • A collaborative path forward: AI Live Testing; • Why you should take part; • What AI Live Testing isn’t; and • Frommodel evaluation to AI system evaluation. The FCA launched its request for interest by firms in submitting their AI systems for live testing as part of its AI Lab on 7 July 2025. The current round of applications closed on 5 September 2025 and the FCA published a Feedback Statement, following its Engagement Paper in AI Live Testing, on 9 September 2025. Link to FCA Blog here Link to FCA AI LabWebpage here SEC Creates Task Force to Tap AI for Enhanced Innovation and Efficiency Across the Agency On 1 August 2025, the Securities and Exchange Commission (SEC) announced the launch of a task force on AI that will spearhead its efforts to enhance innovation and efficiency in its operations through the responsible use of AI. Recognising the transformative potential of AI, the SEC’s AI Task Force will accelerate AI integration to bolster the SEC’s mission. It will centralize the agency’s efforts and enable internal cross-agency and cross-disciplinary collaboration to navigate the AI lifecycle, remove barriers to progress, focus on AI applications that maximize benefits, and maintain governance. The task force will support innovation from the SEC’s divisions and offices and facilitate responsible AI integration across the agency. Link to Press Release here MIFID/MIFIR (UK) Multi-firmReview of Algorithmic Trading Controls: FCA High-level Observations On 21 August 2025, the Financial Conduct Authority (FCA) published its high-level observations based on its multi-firm review of algorithmic trading controls. The FCA reviewed a sample of principal trading firms to assess their compliance withMiFID Regulatory Technical Standards (RTS) 6 and identify any areas of weakness in firms’ algorithmic control frameworks. The FCA also sought to identify good practices among algorithmic trading firms. In terms of the FCA’s findings, there were a number of areas where it says that it found good practice and also room for improvement. These were: • Governance. – Self-assessment and validation. – Role of the compliance function – Algorithmic inventories. – Deployment of algorithms (including material changes).