Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

3 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 The FRB says the second proposal would establish a tailored application process for Board- supervised banks applying to issue payment stablecoins. These applicants would be required to submit a business plan and financial information, among other documents. The proposal would also create a process governing appeals, hearings, and final determinations for applications. The comment period will close on 30 November 2026 . Link to Proposed Rule: Implementing the Federal Reserve Board’s Responsibilities Under the GENIUS Act here CFTC Staff Releases Updates to FAQs Concerning Registrants and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies On 24 September 2026, the Commodity Futures Trading Commission (CTFC) Market Participants Division, Division of Market Oversight, and Division of Clearing and Risk released updates to the FAQs Concerning Registrant and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies to address investments of customer funds in tokenized forms of permitted investments and the use of blockchain technologies to satisfy a registrant’s recordkeeping requirements. These FAQs were originally released on 20 March 2026 and included responses to frequently asked questions concerning registrant and registered entity activities relating to crypto assets and blockchain technologies to provide further clarity to market participants on topics addressed in CFTC Staff Letter 25-39 (Tokenized Collateral Guidance) and CFTC Staff Letter 26-05 (Staff No- Action Position Regarding Digital Assets Accepted as Margin Collateral). Link to CFTC Staff Releases Updates to FAQs Concerning Registrants and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies here EurosystemBrings Central Bank Money to Tokenised Finance On 21 September 2026, the European Central Bank (ECB) Eurosystem announced the launch of Pontes, a solution that enables wholesale transactions in tokenised assets to be settled in central bank money. The ECB says Pontes is the first initiative under the Eurosystem’s strategic programme to make central bank money fit for a tokenised future and to support the development of this rapidly evolving financial ecosystem. The ECB says Pontes builds on the outcome of the Eurosystem’s 2024 tests using DLT for central bank money settlement, during which stakeholders from the public and private sectors indicated that access to a risk-free settlement asset was crucial for the wider adoption of this new technology. The ECB says that Pontes will initially offer a core set of services, to be expanded over time in line with market needs and technological developments. Enhanced features and longer operating hours will be introduced gradually, with full implementation expected by 2028. Link to the ECB Pontes Webpage here Cryptoasset Perimeter Guidance On 16 September 2026, the FCA published it final guidance on when cryptoasset activities need FCA authorisation. From 25 October 2027, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 will introduce new regulated activities for cryptoassets into the FCA’s perimeter. Anyone wishing to carry on these activities by way of business in the UK will need to apply for authorisation, unless there is a relevant exemption or they are able to use the savings or transitional run off provisions. The FCA says its guidance aims to help firms understand its regulatory perimeter and when authorisation may be required for cryptoasset activities. The FCA says the guidance is relevant to: • Firms carrying out, or planning to carry out, regulated cryptoasset activities in the UK, such as safeguarding cryptoassets, operating a trading platform, or arranging deals or staking;