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

14 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 The CSSF states that this update also modifies question 1.14 specifying the conditions under which a UCITS may hold ancillary liquid assets. The CSSF clarifies that, for the sole purpose of processing subscriptions or redemptions, UCITS may also hold e-money tokens as defined in Article 3(1)(7) of MiCAR. Such e-money tokens shall be converted to bank deposits at sight or invested in eligible assets as soon as practicable. Link to Updated FAQ here NORTH AMERICA SEC Adopts Final Rules for the Holding Foreign Insiders Accountable Act On 27 February 2026, the Securities and Exchange Commission (SEC) adopted final rule and form amendments to reflect the requirements of the recently enacted Holding Foreign Insiders Accountable Act (HFIA), which will increase transparency into the holdings and transactions of directors and officers of foreign private issuers (FPIs). Directors and officers of FPIs with a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934 (Exchange Act) must begin disclosing their holdings and transactions in the FPI’s equity securities on 18 March 2026, the effective date of the HFIA Act. The HFIA Act, enacted on 18 December 2025, amended Section 16(a) of the Exchange Act to require every person who is a director or an officer of an Exchange Act reporting FPI (but not “10 percent holders” who beneficially own more than 10 percent of any class of equity securities of such FPIs) to file Section 16 reports electronically and in English. The HFIA Act eliminates a previous exemption for insiders at foreign companies by requiring these types of disclosures. Link to Adopting Release here CFTC Staff Reissues its No-Action Position for Commodity Pool Operator Registration for Certain Investment Managers to Qualified Eligible Persons to Add Additional No-Action Position on CPO Delegation Arrangements On 26 February 2026, the Market Participants Division (MPD) of the Commodity Futures Trading Commission (CFTC) issued No-Action Letter No. 26-06, which clarifies that commodity pool operators (CPOs) may deregister with respect to an existing pool, or determine not to register with respect to a new pool, pursuant to the CFTC’s recently issued No-Action Letter 25-50 without disrupting CPO delegation arrangements. No-Action Letter 25-50, which was issued on 19 December 2025, provides targeted relief from Commodity Pool Operator (CPO) and Commodity Trading Advisor (CTA) registration requirements for certain private fund managers whose funds are offered exclusively to Qualified Eligible Persons (QEPs). It serves as an interimmeasure while the CFTC considers reinstating the former QEP Exemption (CFTC Regulation 4.13(a)(4)), which was rescinded in 2012. This relief offers significant benefits to SEC-registered private fund managers meeting the specified criteria, promoting regulatory consistency between the CFTC and SEC, especially concerning sophisticated investors. Link to CFTC Staff Letter here SEC’s Division of Enforcement Announces Updates to Enforcement Manual On 24 February 2026, the SEC’s Division of Enforcement announced significant updates to its Enforcement Manual. These updates underscore the SEC’s ongoing commitment to fairness, transparency, and efficiency in the investigations conducted by the Division. They include changes to investigative procedures that are intended to enhance consistency and uniformity in the Division’s practices and to create greater efficiencies in support of the SEC’s mission to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. The Enforcement Manual, which was last revised in 2017, will undergo yearly reviews going forward. Link to Updated Enforcement Manual here