Regulatory Blog

On 6 May 2026, the Cyprus Securities and Exchange Commission issued Circular C776, confirming its adoption of the ESMA Guidelines on Liquidity Management Tools of UCITS and open-ended AIFs. The Guidelines, published by ESMA on 12 March 2026, are directed at UCITS management companies (including self-managed UCITS) and alternative investment fund managers (including internally managed AIFs).

On 9 April 2026, the Bermuda Monetary Authority issued a Consultation Paper on asset tokenisation. The Consultation Paper aims to promote responsible innovation in tokenised assets while maintaining robust investor protections, market integrity, and alignment with international standards, by enhancing regulatory clarity and addressing tokenisation-specific risks within Bermuda's existing legislative frameworks. Notably, the paper does not propose an entirely new regulatory regime. Rather, it advances targeted clarifications and amendments within existing legislative frameworks, including the Investment Business Act 2003, the Investment Funds Act 2006, the Digital Asset Business Act 2018, the Digital Asset Issuance Act 2020, and related statutes.

The BVI has taken a significant step forward in its data protection journey. Effective as of 11 May 2026, the BVI Government officially appointed Melissa Brewley as the BVI’s first Information Commissioner under the Data Protection Act 2021. The public announcement was issued on 9 June 2026.

The European Union announced a series of restrictive measures targeting individuals and entities involved in significant violations of international law, human rights, and cybersecurity. These measures were adopted on 16 March 2026, reflect the EU's commitment to safeguard global security, human rights, and the rule of law. These measures form a distinct package of measures from the 20th Package on Russia, which was released on 23 April 2026.

On 14 June 2026, a broad coalition of states, including the United Kingdom and European Union member states, issued a joint statement responding to the announcement of a memorandum of understanding between the United States and Iran, calling for the detailed negotiations to be concluded and the agreement to be implemented rapidly and comprehensively, indicating their readiness to support that effort.

On 21 May 2026, the Court of Justice of the European Union delivered two significant sets of judgments addressing the interaction between trust structures and, respectively, EU restrictive measures and anti-money laundering transparency obligations. Taken together, these rulings reinforce the EU's substance-over-form approach to financial regulation and carry important implications for trustees, fiduciary service providers, and compliance professionals across the Member States.

On 24 April 2026, the UK Office of Financial Sanctions Implementation issued a new General Licence (INT/2026/9512597) under the Sanctions and Anti-Money Laundering Act 2018, replacing the previous Legal Services General Licence which expired on 28 April 2026. The licence allows UK law firms and counsel to receive payments from designated persons under the UK Autonomous Sanctions Regimes listed in Annex 1 including, notably, Russia, without needing a separate OFSI-specific licence, provided all terms are met.

On 3 June 2026, the Bermuda Monetary Authority published a Consultation Paper, together with an illustrative draft Banks and Deposit Companies Amendment Bill 2026, proposing a series of amendments to the Banks and Deposit Companies Act 1999. Comments are due by 3 July 2026.

On 1 April 2026, the BVI Financial Services Commission published its Q1 2026 newsletter, detailing significant updates and initiatives in the financial services sector. The publication highlights the BVI FSC's proactive approach to global stakeholder engagement, legislative reforms, and compliance enhancement.

The Bermuda Monetary Authority introduced an Approval in Principle process to streamline the establishment of new investment funds in Bermuda. This initiative aims to balance efficient decision-making with robust regulatory oversight.

On 17 April 2026, the European Securities and Markets Authority published a statement clarifying its supervisory expectations as the MiCA transitional period reaches its EU-wide expiry on 1 July 2026.

On 3 June 2026, the British Virgin Islands Financial Services Commission issued Industry Circular 16 of 2026, advising stakeholders of the Government of the Virgin Islands' initiative to develop a National Financial Services Strategy. The Strategy is directed at enhancing the Territory's competitiveness, resilience, and global standing within the international financial services landscape.