Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

3 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 SEC interpretation: • Provides a coherent token taxonomy for digital commodities, digital collectibles, digital tools, stablecoins, and digital securities. • Addresses how a “non-security crypto asset” —which is a crypto asset that itself is not a security —may become subject to, and how it may cease to be subject to, an investment contract. • Clarifies the application of federal securities laws to airdrops, protocol mining, protocol staking, and the wrapping of a non-security crypto asset. Market participants are advised to review this interpretation to better understand the regulatory jurisdiction between the SEC and CFTC. Link to Fact Sheet here Link to SEC Interpretation here Tokenomics and Blockchain Fragmentation On 10 March 2026, the Bank for International Settlements (BIS) published Working Paper No. 1335 on Tokenomics and Blockchain Fragmentation. In this paper, BIS examines whether blockchain-based systems can sustain the network effects that give money its social value, or whether the economics of decentralised consensus could lead to fragmentation of the monetary landscape. BIS found that the cost of decentralised consensus is irreducible: the more secure the blockchain is, the higher the rewards needed to sustain validator participation and the greater the congestion costs borne by users. New blockchains with less stringent consensus thresholds enter to serve users priced out of incumbent chains, producing fragmentation rather than consolidation. BIS said the analysis provides lessons for the design of future monetary infrastructure. Link to Tokenomics and Blockchain Fragmentation here Targeted Report on Stablecoins and UnhostedWallets – Peer-to-Peer Transactions On 3 March 2026, the Financial Action Task Force (FATF) published a report highlighting illicit finance risks linked to criminals’ misuse of stablecoins, particularly through peer-to-peer (P2P) transactions via unhosted wallets and sets out recommended actions for countries and the private sector to strengthen controls to protect the integrity of the financial system. The FATF’s Targeted Report on Stablecoins and Unhosted Wallets , highlights that stablecoins have expanded rapidly, with over 250 in circulation by mid-2025 and a market capitalisation exceeding USD 300 billion. The report highlights that only a limited number of jurisdictions have implemented targeted regulatory frameworks for entities operating within the stablecoins ecosystem, explicitly considering the features that distinguish stablecoins from other virtual assets. The FATF said that, while its Standards do not require jurisdictions to adopt regulatory frameworks for stablecoin arrangements beyond those already applicable to virtual asset service providers (VASPs), it urges countries to recognise the specific money laundering, terrorist financing and proliferation financing risks associated with stablecoins and to implement proportionate and effective mitigating measures that reflect their distinct characteristics. The FATF said that countries should fully implement Recommendation 15 of the Standards to ensure that stablecoin issuers, intermediary VASPs, financial institutions and other relevant participants in stablecoin arrangements are subject to clear anti-money laundering and countering the financing of terrorism obligations. In addition, good practices for jurisdictions and the private sector to mitigate the misuse of stablecoins are highlighted in the Targeted Report. The report also highlights case studies demonstrating how new technologies and blockchain analytical tools, along with other risk mitigation measures, have been used to detect and disrupt illicit activity involving stablecoins. Link to Report here