The EU has introduced Delegated Regulation (EU) 2025/1190, establishing the first harmonized standards for threat-led penetration testing ("TLPT") across the financial sector. The regulation aims to strengthen the cyber...more
7/31/2025
/ Credit Institutions ,
Cybersecurity ,
Digital Operational Resilience Act (DORA) ,
Enforcement ,
EU ,
EU Directive ,
Financial Institutions ,
Financial Services Industry ,
G-SII ,
Harmonization Rules ,
Regulatory Requirements ,
Risk Management ,
Technical Standards
The rise of crypto assets and decentralized finance has challenged traditional regulatory frameworks, particularly in the area of anti-money laundering and countering the financing of terrorism ("AML/CFT")....more
7/29/2025
/ AML/CFT ,
Anti-Money Laundering ,
Cooperative Compliance Regime ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
EU ,
Financial Crimes ,
Financial Markets ,
Money Laundering ,
Regulatory Requirements ,
Terrorist Financing Regulations
Following the recent focus on two major regulatory frameworks—the Guiding and Establishing National Innovation for U.S. Stablecoins Act (known as the GENIUS Act) in the United States, and Regulation (EU) 2023/1114 of the...more
7/28/2025
/ Cryptocurrency ,
Digital Assets ,
EU ,
Financial Markets ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Legislation ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Stablecoins ,
The GENIUS Act
The European Union Anti-Money Laundering ("AML") package includes Regulation (EU) 2024/1620 of the European Parliament and of the Council of May 31, 2024, establishing the Authority for Anti-Money Laundering and Countering...more
7/28/2025
/ AML/CFT ,
Anti-Money Laundering ,
Enforcement ,
EU ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
Money Laundering ,
New Regulations ,
Regulatory Authority ,
Regulatory Oversight ,
Regulatory Requirements
The European Union ("EU") Anti-Money Laundering ("AML") package adopted by the European Parliament and the Council on May 31, 2024, represents a major shift in the fight against money laundering and terrorist financing at the...more
DORA, the first EU regulation designed to establish a unified and robust digital resilience standard for the financial sector, becomes directly applicable on January 17, 2025, introducing significant penalties and...more
Against the backdrop of the comprehensive recast of European Union ("EU") banking legislation, the EU legislator is increasingly focused on Environmental, Social, and Governance ("ESG") risks. In this context, ad hoc...more
The Situation: Prior to the enactment of Capital Requirements Directive ("CRD") VI, corporate governance rules for the financial services industry were not harmonized across EU Member States....more
The Situation: The European Union ("EU") banking legislation has been substantially reviewed and provides notably for a new regime applicable to cross-border activities from non-EU jurisdictions....more
On May 28, 2024, the Chair of the Supervisory Board of the European Central Bank ("ECB"), Claudia Buch, announced the decision to reform the current process of annual review of credit institutions under direct ECB supervision...more
In Short -
The Situation: The European Union's Fourth Anti-Money Laundering ("AML") Directive (Directive (EU) 2015/849 of May 20, 2015) granted broad access to information relating to the beneficial owners of companies...more
On July 8, 2022, the European Central Bank ("ECB") released the results from its annual stress tests, this year focused on banks' ability to incorporate climate risk stress testing into their risk management frameworks. The...more
On June 29, 2022, the European Parliament, the Commission, and the Council reached a provisional agreement on the European Union proposal to update Regulation 2015/847 on information accompanying the transfer of funds ("TFR")...more
After June 30, 2021, large asset managers will no longer have the option to "explain" noncompliance with Article 4 of EU Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector...more
An interest group of EU banks that was formed to assist European financial institutions with their use of public cloud technology recently suggested model terms for the compliant use of cloud technology.
On May 17, 2021,...more
Regulation (EU) 2019/2033 on the prudential requirements of investment firms and Directive (EU) 2019/2034 on the prudential supervision of investment firms (collectively, "IFR/IFD Framework") significantly change the...more
The economic crisis caused by the spread of the coronavirus triggered an unprecedented response from European governments to support their economies with various measures of support.
This overview summarizes the various...more
7/6/2020
/ Business Interruption ,
Coronavirus Large Business Interruption Loan Scheme (the CLBILS) ,
Coronavirus/COVID-19 ,
EU ,
European Commission ,
Infectious Diseases ,
Member State ,
Public Health Emergency ,
Relief Measures ,
State Aid ,
State of Emergency
The Situation: On June 3, 2020, the European Securities Market Authority ("ESMA") published a consultation paper on Outsourcing to Cloud Service Providers ("Proposed Guidelines"), which will apply to any institution under the...more
The Situation: The European Banking Authority ("EBA") published its Final Report on EBA Draft Guidelines on Outsourcing Arrangements ("Guidelines") on February 25, 2019, which will eventually replace the existing CEBS...more
The Situation: In 2017, French authorities amended laws to permit the use of blockchain, or distributed ledger technology ("DLT"), for trading nonlisted securities.
The Result: The regulation governing the use of DLTs and...more
The Situation: In response to recent cases of money laundering in European banks, the European Union has released an action plan to reinforce its recently proposed anti-money laundering ("AML") and Countering Financing of...more
The Situation: The French government has presented a new bill in order to prepare for a "Hard" Brexit scenario.
The Result: If the United Kingdom leaves the European Union in March 2019 without an overall deal—or with a...more
11/9/2018
/ Consumer Financial Products ,
Cross-Border ,
EU ,
European Economic Area (EEA) ,
Financial Services Industry ,
France ,
Insolvency ,
ISDA ,
Legacy Contracts ,
Safe Harbors ,
UK ,
UK Brexit
The Court Decision: On September 25, 2018, the Higher Regional Court of Berlin held that bitcoins would not qualify as financial instruments for the purposes of the German Banking Act (Kreditwesengesetz, "KWG"), thus...more
11/1/2018
/ BaFin ,
Cross-Border Transactions ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
EU ,
German Banking Act ,
Germany ,
Initial Coin Offering (ICOs) ,
MiFID II ,
Securities Regulation ,
Token Sales
The EU Commission is proposing measures to increase financial sector supervision in the wake of money laundering incidents.
The European Commission recently proposed expanding the Europe Banking Authority’s ("EBA") mandate...more
10/2/2018
/ Amended Legislation ,
Anti-Money Laundering ,
Cross-Border ,
EU ,
European Banking Authority (EBA) ,
European Commission ,
European Securities and Markets Authority (ESMA) ,
European Supervisory Authorities (ESAs) ,
Financial Institutions ,
Member State ,
Risk Assessment
The Situation: The European Central Bank ("ECB") has announced that it will set bank-specific supervisory expectations for the provisioning of non-performing loans ("NPLs") in a consistent way across comparable banks, which...more