Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

6 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 SFC Unveils New Regulatory Framework to Allow Secondary Trading of Tokenised SFC- authorised Investment Products On 20 April 2026, the Securities and Futures Commission (SFC) launched a new regulatory framework to pilot the secondary trading of tokenised SFC-authorised investment products (tokenised products) in Hong Kong, aiming to boost trading activity in the city’s expanding digital asset ecosystem over time. Set out in its Circular, the SFC says its new guidance aims primarily to facilitate secondary trading of tokenised SFC-authorised open-ended funds on SFC-licensed virtual asset trading platforms (VATPs), not least broadening access to regulated trading services for retail investors. However, the SFC says that it may also consider over-the-counter secondary trading arrangements on a case- by-case basis. Since it first set out its tokenisation-related regulatory framework in late 2023, the SFC says that product issuers in Hong Kong have been keen on tokenising their products and the resulting market opportunities. As of March 2026, the SFC says that 13 tokenised products were offered to the public in Hong Kong, with the assets under management of their tokenised classes increasing around seven-fold to $10.7 billion over the past year. Against this backdrop, the SFC says that it is an opportune time to pilot 24/7 secondary trading to further integrate tokenised products with the Web3 ecosystem through the potential use of regulated stablecoins and tokenised deposits for trading. To address the liquidity and investor protection issues of secondary trading of tokenised open- ended funds in general, and trading beyond regular trading hours of the underlying securities, in particular, the SFC says that newmeasures are built into the framework which is drawn from trading of exchange-traded funds and SFC-licensed VATP infrastructure. The measures cover fair pricing, orderly trading, liquidity provision and disclosure. The initial batch of products is expected to focus on tokenised money market funds. The SFC will review their operation and consider expanding the product scope in due course. The SFC says that product issuers and intermediaries, including SFC-licensed VATPs, are encouraged to consult or notify it beforehand on endeavours related to this regulatory framework. Link to Circular here FUND LIQUIDITY CSSF Communique: Communication to the Investment Fund Industry On 10 April 2026, the Commission de Surveillance du Secteur Financier (CSSF) published a communiqué which follows up on the CSSF Communiqué published on 18 March 2026, announcing the launch of a dedicated “Liquidity Management Tool (“LMT”) eDesk procedure”, comprising both an “LMT selection” and an “LMT activation” module. The “LMT selection” module was launched on 23 March 2026, requiring 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 by 16 April 2026. In its latest communiqué, the CSSF informs market participants that the “LMT activation” module has now been launched. UCITS, or where applicable their management company, and authorised AIFMs that manage open‑ended AIFs, are required to notify the CSSF as from 16 April 2026, via the “LMT activation” module, of the activation or deactivation of the following: • Suspensions of subscriptions, repurchases and redemptions; • 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.