Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

9 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 • UCITS, or where applicable their management company, and authorised AIFMs managing open-ended AIFs shall also implement detailed policies and procedures for the activation and deactivation of any selected LMT and the operational and administrative arrangements for the use of such tool. UCITS, or where applicable their management company, and authorised AIFMs managing open-ended AIFs shall communicate to the CSSF their selection of LMTs, along with detailed policies and procedures governing their activation and deactivation. They shall also provide information on actual activations or deactivations of LMTs, in accordance with the provisions of the 2010 and 2013 Laws. The CSSF also announced of the launch of a dedicated “Liquidity Management Tool” eDesk procedure, for the digital communication to the CSSF of the LMT-related information required under the 2010 and 2013 Laws. This eDesk procedure comprises two modules: 1. The “ LMT selection ” module, which launched on 23 March 2026. It will require UCITS or where applicable their management company, and authorised AIFMs to communicate their selection of LMTs to the CSSF, together with their detailed policies and procedures governing their activation and deactivation. This information must be communicated to the CSSF by 16 April 2026. After the initial communication and in case of amendments, UCITS and authorised AIFMs remain responsible for ensuring that the information provided is kept up to date. 2. The “ LMT activation ” module, which will be launched on 16 April 2026. It will require UCITS or where applicable their management company, and authorised AIFMs to notify to the CSSF, as from that date, the activation/deactivation of: • Suspensions of redemptions, repurchases and subscriptions; • Any LMT referred to in Annex III, points 2 to 8 of the 2010 Law or Annex V, points 2 to 8 of the 2013 Law, in a manner that is not in the ordinary course of business , as envisaged in the UCITS or AIF rules or instruments of incorporation; and • Side pockets, while ensuring that in accordance with Article 15-1 of the 2013 Law, and Articles 12 and 28 of 2010 Law, the CSSF is notified within a reasonable timeframe before the activation or deactivation of this LMT. The CSSF reminds market participants that the information of activations or deactivations of LMTs they provide through the eDesk procedure will be subsequently used to notify the required competent authorities, ESMA and the European Systemic Risk Board in accordance with the provisions of the 2010 and 2013 Laws. In addition, Luxembourg-domiciled funds subject to Part II of the 2010 Law, specialised investment funds governed by the Law of 13 February 2007 and investment companies in risk capital governed by the Law of 15 June 2004, which do not qualify as AIFs or are not managed by a Luxembourg- domiciled authorised AIFM, shall also notify the CSSF of the activation or deactivation of suspensions of redemptions, repurchases and subscriptions, as well as the creation of side pockets, as required under the respective sectoral laws under the “LMT activation” module. Link to the Communiqué here IOSCO IOSCO Publishes Consultation Report on Good Practices Concerning Over-the-counter Commodities Derivatives Markets On 19 March 2026, IOSCO published a Consultation Report on Good Practices concerning over- the-counter (OTC) Commodity Derivatives Markets. This report invites comments on proposed good practices intended to support the effective implementation of IOSCO’s Principles for the Regulation and Supervision of Commodity Derivatives Markets, with a particular focus on strengthening the implementation of Principles 12, 15, and 161 in the context of related OTC markets. Feedback received will inform the final report, which will provide guidance to support effective implementation of the principles and strengthen the integrity and stability of global commodity markets.