London Investigations Horizon Scan May 2026
The UK Crime and Policing Act 2026, enacted on 29 April, expands the senior‑manager test to every criminal offence, dramatically widening corporate liability. The Serious Fraud Office, now led by interim director Graham McNulty, is prioritising AI‑driven investigations, crypto‑asset capabilities, and a refreshed business plan for 2026‑27. OFSI has doubled its maximum sanctions penalties, introduced a settlement scheme and new end‑use licence rules to curb diversion of goods to sanctioned destinations. Meanwhile, the EU Omnibus Directive raises CSRD and CS3D thresholds, excluding roughly 80% of companies from mandatory sustainability reporting.
PASS or Fail? Making the Most of the FCA’s Pre-Application Meetings for Crypto Firms
The FCA has revived its Pre‑Application Support Service (PASS) to help crypto‑asset firms navigate the new authorisation regime. PASS provides free, informal meetings where firms can discuss business plans, compliance, staffing and risk with the FCA’s digital assets team. Sessions,...
PSR Publishes Proposed Direction and Guidelines: Regulatory Financial Reporting in Relation to the Market Review of Card Scheme and Processing...
On 21 May 2026 the Payment Systems Regulator (PSR) issued a draft direction and accompanying guidelines to implement its Regulatory Financial Reporting (RFR) remedy for card‑scheme and processing fees. The proposal trims reporting obligations, dropping annual balance‑sheet submissions deemed unnecessary, while retaining...
ECB Updates Good Practices for Climate and Nature-Related Risk Management
On 8 May 2026 the European Central Bank updated its non‑binding compendium of good practices for climate and nature‑related risk management and stress testing. The revision adds detailed guidance on physical and nature‑related risks and offers proportional tools for smaller, less exposed...
PRA Publishes Dear CEO Letter Reaffirming Its Position and Clarifying Expectations on Innovations in the Use of Deposits, E-Money and...
On 18 May 2026 the Prudential Regulation Authority issued a new Dear CEO letter that supersedes its 2023 guidance on deposit‑takers’ use of deposits, e‑money and regulated stablecoins. The PRA stresses that innovations must be offered only to retail customers as deposits, and...
PRA Publishes Dear CEO Letter on the Prudential Treatment of Tokenised Assets, Stablecoins, and Other Cryptoasset Exposures
On 18 May 2026 the Prudential Regulation Authority issued a new Dear CEO letter updating its prudential expectations for tokenised assets, stablecoins and other crypto‑asset exposures. The guidance reaffirms the 2022 risk‑control and Pillar 1/2 frameworks, maintains a 100 % capital charge for unbacked crypto,...
BoE Consultation – Extending RTGS and CHAPS Settlement Hours – Next Steps Towards Near 24×7 Settlement
On 18 May 2026 the Bank of England released a consultation paper outlining its roadmap to near‑24‑hour RTGS and CHAPS settlement. An early‑morning extension will push CHAPS opening to 01:30 am from September 2027, expanding daily coverage to 16.5 hours. The paper proposes two next‑step...
ESMA Updates Manual on Pre-Trade and Post-Trade Transparency Under MiFID II/MiFIR
On 12 May 2026 ESMA published an updated Manual on pre‑trade and post‑trade transparency under MiFID II/MiFIR, highlighting a series of changes in a dedicated table. The most notable amendment is paragraph 143, which defines “end of the trading day” (EoD) for on‑venue and...
ESMA Resolution Briefing for CCPs
On 13 May 2026, ESMA released a resolution briefing for central counterparties, outlining a methodology for national resolution authorities to incorporate into CCP resolution plans. Issued under Article 25 of the ESMA Regulation and EU Regulation 2021/23, the guidance is non‑binding and...
The New EU Anti-Corruptive Directive – What UK and Global Companies Need to Know.
On 21 April 2026 the EU Parliament adopted a new Anti‑Corruption Directive that creates a harmonised criminal framework across all Member States, defining nine corruption‑related offences including a stand‑alone “trading in influence” crime. Corporate liability can trigger fines of at least 5%...
Podcast | EU/UK Split the Difference – Two Regimes, One Market: The UK–EU Crypto Authorisation Divide
The latest episode of Norton Rose Fulbright’s *Split the Difference* podcast kicks off a two‑part series comparing crypto‑asset authorisation in the United Kingdom and the European Union. Part 1 outlines the structural and scope differences between the UK’s FCA‑centric regime and the EU’s...
New Commission FAQs on MMFs’ Minimum Liquidity Levels and on How Liquidity Buffers May Be Used
On May 11, 2026, the European Commission released a report and a set of FAQs on money‑market fund (MMF) liquidity management. The new guidance builds on the 2023 assessment that the MMF Regulation survived COVID‑19‑related turmoil and recent interest‑rate shocks,...
AMLA Consults on Draft RTS for Home-Host Supervisory Cooperation
On 11 May 2026 the EU Anti‑Money Laundering Authority released a consultation paper proposing draft regulatory technical standards (RTS) that define the duties of home and host supervisors for cross‑border financial groups under Directive 2024/1640 (AMLD). The RTS establish a baseline framework for...
ESMA Issues Results of CSA on the Compliance and Internal Audit Functions of Fund Managers
On 11 May 2026 ESMA published the final report of its 2025 Common Supervisory Action on compliance and internal audit functions of alternative investment fund managers and UCITS companies. The exercise involved all 27 EU and three EEA national regulators,...
The Football Governance Act 2025 (Commencement No. 3) Regulations 2026
On 29 April 2026 the Football Governance Act 2025 (Commencement No. 3) Regulations were issued, bringing into force key sections of the Act on 5 May 2026. The measures activate Part 4, which gives the Independent Football Regulator authority to assess and remove unsuitable owners and officers...