Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

21 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 The CSSF said that, as of 2 March 2026, any request/application received by it that does not include these minimum documents and information will not be considered as complete and the analysis of the file will not start until reception of a complete application. Link to the Guidance here NORTH AMERICA FINRA Launches Financial Intelligence Fusion Center to Combat Cybersecurity and Fraud Threats On 31 March 2026, the Financial Industry Regulatory Authority (FINRA) announced the launch of the Financial Intelligence Fusion Center (FIFC), a secure portal for FINRA and its member firms to share timely intelligence about cybersecurity and fraud threats and coordinate responses. Building on FINRA’s continued commitment to help member firms combat cyber and financial crime threats, the FIFC will collect, analyze and disseminate threat intelligence to bolster member firms’ awareness and ability to quickly respond to these threats. The FIFC will also leverage FINRA’s existing partnerships, enabling input from other government and private sector partners. The platformwas developed as part of FINRA Forward, a series of initiatives to further improve FINRA’s effectiveness and efficiency in achieving its mission of protecting investors and safeguarding market integrity. FINRA began piloting the FIFC last year with a diverse group of member firms, whose participation and feedback have helped strengthen the portal’s functionality and effectiveness for member firms of all sizes. Through the pilot program, member firms have accessed FINRA’s threat intelligence products and actively shared cybersecurity and fraud threat intelligence via the FIFC, enabling timely threat mitigation. FINRA encourages member firms to opt into the FIFC to gain access to this centralized portal for intelligence sharing among firms and FINRA. The FIFC expands on the range of resources FINRA provides its members, including guidance for establishing cybersecurity programs, addressing vulnerabilities, combating cyber-enabled fraud and identifying emerging scams, among others. Link to the Financial Intelligence Fusion Center here US Department of Labor Proposes Landmark Rule to Democratize Access to Alternative Investments in 401(k) Plans On 30 March 2026, the U.S. Department of Labor’s Employee Benefits Security Administration issued a historic proposed regulation increasing potential retirement investment options for more than 90 million Americans. The proposed regulation explains the steps that managers of 401(k) plans should take when considering alternative assets as a component in their investment lineups and establishes a set of process-based safe harbors for plan fiduciaries to use when selecting designated investment alternatives. The proposal follows President Trump’s Executive Order, “Democratizing Access to Alternative Assets for 401(k) Investors. ” The proposed regulation reflects long-standing retirement law principles. Prudence under ERISA is grounded in process and plan fiduciaries are given maximum discretion and flexibility in selecting any particular investment as a designated investment alternative. Under the proposed rule, when selecting investment alternatives, plan fiduciaries would need to objectively, thoroughly, and analytically consider, and make determinations on factors including performance, fees, liquidity, valuation, performance benchmarks, and complexity. While managers of defined contribution plans have always had the authority to consider alternative assets, historically, almost none have done so. In 2022, a compliance release was issued that warned fiduciaries about including cryptocurrency options in 401(k) plans. The guidance deviated from the Employee Retirement Income Security Act’s requirements and marked a departure from the department’s decades-long approach to fiduciary investment decisions. Link to the Notice of Proposed Rulemaking here