Global Trustee and Fiduciary Services Bite-Sized Issue 1 | 2026

15 QUICK LINKS AI BENCHMARKS REGULATION (UK) CRYPTOASSETS EMIR FSB FUND LIQUIDITY MIFID/MIFIR IOSCO RETAIL INVESTMENT STRATEGY SAVINGS & INVESTMENTS UNION SUSTAINABLE FINANCE/ESG ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 1 | 2026 ASIC says that the updated Regulatory Guide 181 sets out clear, principles-based guidance for Australian financial services (AFS) licensees and it aims to help licensees fulfil their licensing obligation to have robust arrangements and tailored conflict management strategies in place. Key updates include: • How the law applies to conflicts of interest, including the scope of the conflicts management obligation and links to other related obligations; • The types of conflicts AFS licensees should identify and manage; • The need for robust, tailored arrangements to manage conflicts; • Practical steps for effective conflict management; and • A non-exhaustive ‘catalogue’ of related legal obligations and information. ASIC says that the revised Regulatory Guide 181 replaces guidance issued in August 2004 and is part of ASIC’s ongoing regulatory maintenance and simplification agenda – making it easier for businesses to access regulatory information and understand their obligations. Link to Regulatory Guide 181 here EUROPE ESMA Publishes 2024 Data on Cross-border Investment Activity of Firms On 22 December 2025, the European Securities and Markets Authority (ESMA), in cooperation with National Competent Authorities (NCAs), completed an analysis of the cross-border provision of investment services in 2024. ESMA says that data was gathered from investment firms across 30 jurisdictions in the EU/EEA. The main findings include: • Around 370 financial firms provided cross-border services to retail clients. • Approximately 10.5 million clients in the EU/EEA received investment services from firms located in other Member States. • Compared to 2023: – The number of firms decreased by 4%. – The number of retail clients rose by 32%. – Complaints increased by 46%. • Cyprus leads as the primary location for firms providing cross-border investment services in the EU/ EEA, accounting for 21%of passporting firms, followed by Luxembourg (15%) andGermany (13%). • Germany, France, Spain, and Italy are the most significant destinations for retail clients receiving cross-border services in other Member States. ESMA says that these insights will allow it and the NCAs to better understand and monitor cross- border investment services provided by firms in the EU/EEA. Link to Report here