Clifford Chance

Welcome to this week's global fintech round-up, summarising fintech regulatory developments that have happened around the world along with our Clifford Chance fintech publications and upcoming events.

Details of these and previous developments can also be found on our Fintech Topic Guide on the Clifford Chance Financial Markets Toolkit.

CLIFFORD CHANCE BRIEFINGS AND MATERIALS

• (9 Jun 2025) Clifford Chance Insurance Insights blog post – Insurance sector: AI regulation update
• (5 Jun 2025) Talking Tech article – EDPB Draft Guidelines on Personal Data Processing through Blockchain
• (4 Jun 2025) Clifford Chance briefing – Asset Backed Securitisation for European Digital Infrastructure – What's Next?

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

APAC

Australia:

• (3 Jun 2025) Australian Transaction Reports and Analysis Centre (AUSTRAC) press release on measures to tackle scams, fraud and other illicit activity relating to crypto ATM providers, including an AUD 5,000 limit on cash deposits and withdrawals, enhanced customer due diligence obligations, mandatory scam warnings, and requirements for more robust transaction monitoring.

Hong Kong:

• (6 Jun 2025) Stablecoins Ordinance (Commencement) Notice, which has been gazetted by the Hong Kong Government and states that the Stablecoins Ordinance will commence on 1 August 2025. The Stablecoin Ordinance introduces a supervisory and licensing regime for regulated stablecoin activities in Hong Kong. Alongside the Notice, the Hong Kong Monetary Authority has launched two consultations on proposals for the detailed regulatory requirements of the stablecoin licensing regime and for guidelines on the supervision of licensed stablecoin issuers. Deadline for comments: 30 June 2025.

Japan:

• (6 Jun 2025) Japan Fair Trade Commission report setting out results of a market study on generative AI.

Singapore:

• (6 Jun 2025) The Monetary Authority of Singapore has issued a clarification on the applicable scope of its digital token service providers (DTSPs) regime. | Press release

Europe

EU:

• (10 Jun 2025) European Banking Authority (EBA) No Action letter on the overlap of provisions relating to electronic money tokens (EMTs) under the Markets in Cryptoassets Regulation (MiCA) and the Payment Services Directive (PSD2). The EBA states that, in the long term, EU law needs to avoid a dual authorisation under two pieces of EU law for transacting in EMTs. Until that point, the EBA advises national competent authorities to only enforce authorisation of PSD2 for certain crypto asset service providers (CASPs) that transact EMTs after a new transition period ending 2 March 2026, and that certain PSD2 provisions may then be deprioritised. This follows a letter from the EU Commission to the EBA in December 2024 requesting investigation of this issue. | Press release
• (10 Jun 2025) Commission Delegated Regulations setting out regulatory technical standards (RTS) on records that cryptoasset service providers (CASPs) are required to keep relating to their services, activities, orders and transactions, the policies and procedures on conflicts of interest for CASPs, and the policies and procedures on conflicts of interest for issuers of asset-referenced tokens (ARTs) under the Markets in Cryptoassets Regulation (MiCA), which have been published in the Official Journal.
• (5 Jun 2025) Draft Commission Delegated Regulation setting out RTS on the information required under MiCA in ART authorisation applications, which has been adopted by the EU Commission.
• (4 Jun 2025) European Securities and Markets Authority (ESMA)/Alan Turing Institute/Institut Louis Bachelier working paper on the use of large language models (LLMs) in the financial industry. | Webpage

Spain:

• (3 Jun 2025) The Government has submitted to Congress a Bill to transpose the eighth amendment of the EU Directive on Administrative Cooperation in Direct Taxation (DAC8) into Spanish law. The Bill will require CASPs to report user transactions and balances to the Treasury. | Summary of proceedings (Spanish)

Switzerland:

• (6 Jun 2025) The Federal Council has announced it has adopted a dispatch approving the list of 74 partner states with which it will automatically exchange information concerning cryptoassets. The arrangement will enter into force in 2026, with the first exchange of data taking place in 2027. | Press release

UK:

• (9 Jun 2025) The Financial Conduct Authority (FCA) has announced that it is collaborating with Nvidia to launch a new sandbox, intended to allow financial services firms to experiment with AI using Nvidia's accelerated computing and AI enterprise software. | Press release
• (9 Jun 2025) The Insolvency Service has announced that it has appointed its first dedicated crypto-intelligence specialist, based within its Investigation and Enforcement Services team, to help recover online assets such as Bitcoin in bankruptcy and criminal cases. | Press release
• (6 Jun 2025) The FCA has published a quarterly consultation proposing, among other things, to remove the restriction on the retail sale, marketing and distribution of cryptoasset exchange traded notes (cETNs) that are admitted to a UK recognised investment exchange. cETNs are proposed to be categorised as Restricted Mass Market Investments and would be subject to financial promotion rules among other requirements. Deadline for comments: 7 July 2025.
• (5 Jun 2025) Law Commission consultation on digital assets and electronic trade documents in private international law. The consultation focuses primarily on wholly decentralised applications of distributed ledger technology (DLT), which the Law Commission has identified as posing very particular and novel challenges to the current rules of private international law. Deadline for comments: 8 September 2025. | Press release
• (5 Jun 2025) Law Commission FAQs on property issues and permissioned DLT systems in private international law.
• (4 Jun 2025) UK Finance blog post on the EU AI Act and the strategic steps financial services institutions must take to ensure compliance and leverage the Act for innovation.

EVENTS

• Global Financial Markets Perspectives Series: Quantum state of play – emerging opportunities and threats (online, 25 June 2025): Quantum technology is here now, but transformational use cases exist more in theory than practice. Despite this, corporations and governments are investing billions in a technology that could radically reshape our world. What takeaways can we draw from the emerging confluence between computation and physics? How will quantum technologies impact data privacy, cybersecurity, IP, markets, and international trade? Our panellists will cut through the hype, exploring commercial and legal implications of the current state of technological progress and sharing concrete steps that you can implement in your organisation today. | To register, please see the event series registration form
• Global Financial Markets Perspectives Series: The impact of digital trade for lending, fintech, ESG and risk management – a new dawn? (hybrid, 1 July 2025): Major economies worldwide are changing their laws to implement UNICTRAL’s Model Law on Electronic Transferable Records (MLETR) to streamline trade flows and logistical steps with the aim of expanding access to financing, reducing fraud and achieving ESG compliance and reporting with transparent supply chains. Our global panel will share the status of MLETR take-up and market developments (including the world’s first syndicated borrowing base financing using the UK’s enactment of MLETR, Electronic Trade Documents Act 2023). We will provide practical insights into navigating a data-driven and paperless trade environment in 2025 and beyond. | To register, please see the event series registration form