Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

2 QUICK LINKS AI CRYPTOASSETS CYBER EMIR FINTECH FUND LIQUIDITY MICA SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 5 | 2026 The AFM also notes that for the time being, institutions do not expect significant immediate cost savings. They see the main benefits in working more efficiently and quickly, better data processing and improved internal processes. In the longer term, the AFM states that AI can contribute to better portfolio choices and more in-depth market analyses and that transparency towards investors regarding the role of AI remains essential in this regard. Finally, the AFM says that as AI grows, so do the risks. According to the AFM these include poor data quality, algorithmic bias, limited explainability and dependence on a small number of technology providers. At the same time, it appears that many organisations are not yet adequately prepared for this. The AFM says that a quarter of institutions have no policy regarding the use of AI by employees. For generative AI applications, that proportion is even higher: over two-thirds. Furthermore, more than half do not have an ethics handbook or code of conduct that specifically addresses artificial intelligence. The AFM therefore calls on the sector to assess whether it is sufficiently equipped to apply AI, for example by drawing up clear policies on its use, ensuring good data quality, carefully vetting suppliers and ensuring that staff work with explainable and verifiable models. Link to AFM Press Release here Link to AFM Press Release on ‘Human involvement and clear responsibility crucial when deploying AI in capital markets’ here (13 April 2026) CRYPTOASSETS Dutch AFM: Areas for Improvement in Information Disclosure by CASPs On 16 April 2026, in a report published by the Dutch Authority for the Financial Markets (AFM), it noted that crypto-asset service providers (CASPs) are taking steps to improve their advertisements and cost disclosures, but that deficiencies still remain. The AFM says that they are still falling short, particularly when it comes to balanced risk disclosure, preventing misleading information and presenting costs clearly. Based on this study, the AFM states that it is imposing appropriate measures on the CASPs concerned. The key findings include: 1. Misleading or unclear advertisements, for example the use of terms such as ‘safe trading’ without further explanation, or advertising for ‘commission-free’ or ‘free of charge’ trading in crypto-assets without clearly stating any possible additional costs and/or restrictions. 2. Insufficiently balanced risk disclosures, whereas volatility and complex products require clear warnings. 3. Cost information that is impossible or difficult to find, for example when it is hidden in terms and conditions or when it can only be found by using external search engines. 4. No clear, full presentation of costs, including the omission of standard cost components, such as deposit and withdrawal fees and recurring charges, and the lack of disclosure of the applicable fee rates. 5. Risk of confusion regarding services that fall within and outside the scope of regulatory supervision, for example where staking or lending are offered alongside regulated services. In its report, the AFM highlight five points for improvement, and include good practices: 1. Avoid misleading claims and ensure that information is clearly substantiated; 2. Disclose the risks in a balanced way; 3. Ensure that information on costs is easy to find; 4. Provide consumers with clear and transparent information on costs; and 5. Ensure clear information disclosure on services within and outside the scope of supervision.