Global Trustee and Fiduciary Services Bite-Sized Issue 9 2025

6 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 • Development and testing. – Conformance testing. – Simulation testing. – Controlled deployment of algorithms. • Risk controls. • Market abuse surveillance. – Surveillance systems and governance and oversight. The FCA says that most firms it reviewed had a good understanding of their obligations under RTS 6. There was, however, significant variation in the sophistication of firms and their level of compliance, even taking account of the nature, scale, and complexity of their trading activities. The FCA says that it gave all reviewed firms individual feedback. Where appropriate, the FCA used attestations to make sure that progress is made to meet the requirements. Link to FCAMulti-firmReview here SUSTAINABLE FINANCE/ESG Transition Finance Council Consults on Entity-level Transition Finance Guidelines On 18 August 2025, the Transition Finance Council (TFC), which was co-launched by the City of London Corporation and the UK Government with the aim of driving forward the roadmap and recommendations set out in the Transition Finance Market Review and to establish the UK as the global hub for raising and deploying transition finance, published a consultation paper on draft transition finance guidelines designed to support capital allocation to credibly transitioning entities across different asset classes and jurisdictions. The TFC says that there is currently no consistent framework capable of application across asset classes for identifying and evaluating credible transition finance at entity-level, therefore it has developed the draft guidelines to help address this gap. The TFC states that the consultation is the first step in its aim to work with interested markets to define the most effective guidelines to support capital allocation to transitioning entities across different asset classes and jurisdictions. The TFC says the draft guidelines are voluntary and designed to complement existing global and domestic frameworks. They are interoperable with key disclosure frameworks – such as those developed by the Transition Plan Taskforce and the International Sustainability Standards Board. The guidelines set out four principles that each address a dimension of credibility: • Credible Ambition; • Action into Progress; • Transparent Accountability; and • Addressing Dependencies. These principles are supported by six universal factors containing practical criteria which are evidence points for assessing whether the principles are satisfied: Interim Targets & Metrics; • Implementation; • Financial viability; • Engagement; • Disclosure; and • Governance.