Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

2 AIFMD CRYPTOASSETS FINTECH FUND LIQUIDITY OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2026 Quick Links • Greater transparency in costs; and • Proportionate requirements for staking, lending and borrowing, including through disclosure obligations. ESMA says these measures would provide clearer information on costs, risks, rewards, collateral arrangements, and potential losses before investment decisions are made. Reinforcing supervision ESMA recommends strengthening supervisory powers and address the risks arising from unauthorised services, online fraud and non-compliant stablecoins, by: • Enhancing the EU’s capacity to detect, block and deactivate fraudulent websites and freeze crypto assets in cases of suspicion of market abuse or terrorist financing; • Obtaining reinforced supervisory powers to deal with third-country firms which solicit EU investors without being authorised under MiCA, and; • Introducing explicit rules to prevent regulated crypto firms from offering services linked to stablecoins that do not comply with MiCA requirements. ESMA says these measures would support faster and more consistent supervisory action across the EU, better protecting investors, and reducing opportunities for regulatory arbitrage. Evolving towards De-Fi and improving crypto-asset classification As crypto markets evolve and activity around DeFi and stablecoins grow, ESMA advocates for the introduction of clearer criteria for determining which activities can be considered genuinely decentralised. It also recommends creating a new regulated crypto asset service for firms that provide users with access to DeFi protocols. To reduce uncertainty and support harmonised supervision across the EU, ESMA suggests adopting rules on how crypto-assets should be classified, including new products such as hybrid tokens. It also includes granting ESMA the ability to issue binding opinions on token classification to ensure the same products are treated consistently within the EUmarket. Simplification and burden reduction In line with the EU’s simplification and burden reduction agenda, ESMA proposes to streamline parts of the existing rules, including simplifying crypto-asset white-paper notification procedures, reducing duplicative authorisation requirements for some regulated firms, and improving the consistency of prudential requirements. Development of an integrated European tokenised capital market Finally, and looking beyond the immediate MiCA review, ESMA highlights the need for a framework for tokenised securities and on-chain settlement that can support the development of an integrated European tokenised capital market and facilitates cross-border activity in the future. Link to ESMA’s Recommendations here Federal Reserve Board Requests Public Comment on Two Proposals Related to Establishing a Regulatory Framework for Board-supervised Payment Stablecoin Issuers Under the GENIUS Act On 24 September 2026, the Federal Reserve Board (FRB) requested public comments on two proposals related to establishing a regulatory framework for Board-supervised payment stablecoin issuers under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The FRB says the first proposal would require that Board-supervised payment stablecoin issuers fully back their stablecoins with certain permissible reserve assets, such as short-term Treasury bills and certain other high-quality liquid assets. The proposal would also establish standardized capital requirements to address certain credit and operational risks of payment stablecoin activities, as well as risk management standards, in accordance with the law. Separately, the proposal would introduce rules for Board-supervised firms that safekeep the assets backing payment stablecoins. It would also clarify the permissibility of stablecoin and related activities for Board-supervised banks.