Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

2 QUICK LINKS CMU CONDUCT CRYPTO ASSETS EMIR FINTECH FUND LIQUIDITY IOSCO OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 4 | 2026 CONDUCT Non-financial Misconduct in Financial Services On 23 March 2026, the UK Financial Conduct Authority (FCA) published a webpage explaining what firms should do before rules and guidance intended to tackle non-financial misconduct (NFM) come into effect on 1 September 2026. The webpage details how NFM is covered by the FCA’s requirements via: • Code of Conduct (COCON) rules; • Fit and Proper Test (FIT); and • New guidance covering: – The boundary between work and private life; – How NFM can breach the conduct rules; – Reasonable steps for managers; and – Fitness and propriety assessments, including private life, social media and unproven allegations. The FCA reminds firms that they should ensure their staff and managers understand how the changes apply to them, and review their approach to: • Staff policies. • Conduct breach reporting. • Fit and proper assessments. • Regulatory references. Link toWebpage here CRYPTO ASSETS CFTC Issues FAQs Concerning Registrant and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies On 20 March 2026, the U.S. Commodity Futures Trading Commission (CFTC) Market Participants Division and Division of Clearing and Risk published responses to frequently asked questions (FAQs) concerning registrant and registered entity activities relating to crypto assets and blockchain technologies. The responses 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 the FAQs here SEC Clarifies the Application of Federal Securities Laws to Crypto Assets On 17 March 2026, the Securities and Exchange Commission (SEC) issued an interpretation clarifying how the federal securities laws apply to certain crypto assets and transactions involving crypto assets. The SEC said this is amajor step in its efforts to provide greater clarity regarding the SEC’s treatment of crypto assets, and complements Congressional endeavors to codify a comprehensivemarket structure framework into statute. The CFTC joined the interpretation to provide guidance that the CFTC and its staff will administer the Commodity Exchange Act consistent with the SEC’s interpretation.

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