Global Trustee and Fiduciary Services Bite-Sized Issue 3 | 2026

12 QUICK LINKS AI DIGITAL ASSETS EMIR FINTECH FSB IOSCO MIFID II/MIFIR SUSTAINABLE FINANCE/ESG ASIA PACIFIC EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 3 | 2026 SFC Forges Stronger Industry Collaboration to Shape a Compliant and Innovative Future On 2 February 2026, the SFC hosted its third broker forum to foster a culture of compliance and a spirit of collaboration to facilitate market developments and financial innovations in Hong Kong’s capital markets. The SFC says that as part of its ongoing industry engagement, more than 600 participants from the financial sector attended the forum at the SFC’s office and online. For the first time, the forum featured a panel discussion sharing industry’s views on regulatory issues and commercial implications arising from the growing prevalence of finfluencers. The SFC says that the forum also covered other industry developments and regulatory updates. These included the latest developments of the Integrated Fund Platform, IPO sponsors’ conduct issues, and controls for client onboarding and prevention of potential layering activities. Link to SFC Press Release here EUROPE ESMA Issues a Supervisory Briefing on Algorithmic Trading On 26 February 2026, the European Securities and Markets Authority (ESMA) published a supervisory briefing to support consistent supervision of algorithmic trading across the EU. ESMA says that the briefing provides National Competent Authorities (NCAs) with practical tools and clarified expectations for supervising firms engaged in algorithmic trading under MiFID II. It focuses on key areas where supervisory practices have diverged, including pre-trade controls, governance arrangements, testing frameworks and outsourcing of algorithmic trading systems. Given the extended use of artificial intelligence (AI) in algorithmic trading, ESMA says that the briefing also touches upon these emerging technological developments, outlining considerations for the use of AI. This section aims to help supervisors assess new risks and ensure that firms adopt robust and responsible approaches when deploying advanced technologies in their trading operations. ESMA says that it will share the supervisory briefing with NCAs to support day to day supervision. Link to Supervisory Briefing here ESMA Reminds Firms of Their Obligations Under CFD Product Intervention Measures Amid Rising Offerings of Perpetual Futures On 24 February 2026, ESMA issued a statement reminding firms of their obligation to assess whether newly offered products fall within the scope of existing product intervention measures on contracts for differences (CFDs). ESMA says that the statement responds to the increased offering of derivatives, often marketed as perpetual futures or perpetual contracts, that provide leveraged exposure to underlying values, including crypto-assets such as Bitcoin. These financial instruments are likely to fall within the scope of the existing national product intervention measures on CFDs adopted by national competent authorities. ESMA states that where these derivatives meet the definition of a CFD, they are subject to the applicable product intervention requirements, including leverage limits, a mandatory risk warning, a margin close-out and negative balance protection, and the prohibition of monetary and non- monetary benefits. ESMA’s statement also reminds firms that: • Given their complexity, derivatives require a narrow target market, supported by an aligned distribution strategy; • When providing non-advised services, an appropriateness assessment must be carried out in accordance with the relevant requirements for complex financial instruments; and