Global Trustee and Fiduciary Services Bite-Sized Issue 2 2026

2 QUICK LINKS AIFMD BENCHMARKS REGULATION CRYPTOASSETS FINTECH FUND LIQUIDITY MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 2 | 2026 BENCHMARKS REGULATION Transitional Provisions Under the BMR Review On 21 January 2026, the European Securities and Markets Authority (ESMA) published a statement on the transition to the revised Benchmarks Regulation (BMR). The statement includes: • A table of entities’ applications for recognition and endorsement by third country administrators for which, as of the date of publication, the decision by ESMA is still pending. • A list of administrators that are still included in the BMR Register but, based on current information on the use of their benchmarks, are outside the scope of the BMR and will be removed from the register as of 1 October 2026, except if: » Any of their benchmarks will fall within the scope of BMR in the meantime; or » The EU administrator requests to opt-in one or more benchmarks that it provides and fulfil the relevant conditions under Article 24(7) BMR. Link to Statement here CRYPTOASSETS SEC’s Statement on Tokenized Securities On 28 January 2026, the staff of the US Securities and Exchange Commission (SEC) Division of Corporation Finance, Division of Investment Management, andDivision of Trading andMarkets issued a joint statement designed to provide clarity on the regulatory treatment of “tokenized securities.” The statement addresses the growing practice of representing traditional financial instruments, such as equities and bonds, as digital assets on a blockchain. The statement indicates that the technological format of a security does not alter its fundamental nature or the application of federal securities laws. Whether a stock is issued on paper or as a digital token, it remains a stock, and all existing rules regarding registration, custody, and trading continue to apply. The statement further provides a useful framework by distinguishing between securities tokenized by their original issuer and those created by unaffiliated third parties, reinforcing that all paths lead back to the established regulatory regime. Link to Statement here FCA Seeks Feedback on Further Rules for Cryptoasset Firms On 23 January 2026, the UK Financial Conduct Authority (FCA) issued a consultation paper – CP26/4 – seeking views on further rules for cryptoasset firms as the final step in its consultations on its crypto rules. In CP26/4, the FCA sets out its proposals on how the Consumer Duty, conduct standards, redress and safeguarding will apply to cryptoasset firms. The FCA is also seeking feedback on its proposed approach to international cryptoasset firms. The FCA states that the proposals continue its progress towards an open, sustainable and competitive crypto market that people can trust. The Consumer Duty sets appropriate standards for crypto firms by ensuring they deliver good outcomes for customers while supporting them to navigate their financial lives. At the same time, risks remain, and the FCA said it wants a market where innovation can thrive, but where people understand the risks. CP26/4 follows a package of proposals set out in December on how the FCA intends to apply a similar approach to cryptoassets as it does in traditional finance, with clear information for consumers, proportionate requirements for firms and flexibility to support innovation. The consultation period is open until 12 March 2026. Link to CP26/4 here