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.

Spotlight: Webinar - Quantum state of play – emerging opportunities and threats

Join us on 25 June 2025 for our latest Global Financial Markets Perspectives webinar on quantum.

Governments and corporations are together investing billions to drive progress in realising the potential of quantum technology. Although truly transformational quantum use cases currently exist more in theory than practice, businesses investing in this technology or preparing for quantum disruption must already consider various legal obligations and restrictions – ranging from investment controls to cyber resilience requirements – as well as emerging regulatory guidance.                       

Our panel including Jaime Gómez García, Santander's Global Head of Quantum Threat Program, Andrew Mendelsohn, Researcher at Imperial College London and international Clifford Chance specialists 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.

Registration

CLIFFORD CHANCE BRIEFINGS AND MATERIALS

• (12 Jun 2025) Clifford Chance RegTalk blog post – UK FCA's proposals to reverse ban on sale of cryptoasset exchange-traded notes to UK retail investors

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

International

• (12 Jun 2025) Bank for International Settlements report providing a stocktake of the current use of generative artificial intelligence (AI) in financial supervision.

Americas

Brazil:

• (11 Jun 2025) The Brazilian Government has adopted Provisional Measure 1303 (in Portuguese) on the taxation of financial investments and virtual assets, which removes the exemption on crypto profits of up to R$35,000 and introduces a 17.5% flat rate on all capital gains from digital assets.

US:

• (17 Jun 2025) The Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, which is intended to establish a regulatory framework for payment stablecoins, has been passed by the US Senate. | Roll Call Vote
• (12 Jun 2025) US Senator Cynthia Lummis has introduced the Responsible Innovation and Safe Expertise (RISE) Act of 2025, which is intended to clarify liability rules for AI used by professionals. | Press release

APAC

Vietnam:

• (14 Jun 2025) The National Assembly has passed the Law on Digital Technology Industry, which is intended to increase the proportion of domestically produced technology products through strategic measures and targeted support policies. | Press release

Europe

EU:

• (18 Jun 2025) The EU Council's Committee of Permanent Representatives (Coreper) has approved the Council's negotiating mandate on the EU Commission's proposals for a new Payment Services Directive (PSD3) and Payment Services Regulation (PSR). Following the approval of the Council’s negotiating mandate by Coreper, the Council Presidency can start trilogue negotiations with the EU Parliament in order to reach a common position. | Press release
• (18 Jun 2025) Commission Delegated Regulation (EU) 2025/1190 setting out regulatory technical standards (RTS) on threat-led penetration testing (TLPT) under the Digital Operational Resilience Act (DORA) has been published in the Official Journal. In particular, the RTS specify the criteria used for identifying financial entities required to perform TLPT, the requirements and standards governing the use of internal testers, the requirements in relation to the scope, testing methodology and approach for each phase of the testing, results, closure and remediation stages and the type of supervisory and other relevant cooperation needed for the implementation of TLPT and for the facilitation of mutual recognition. Entry into force: 8 July 2025.

UK:

• (18 Jun 2025) Speech by Bank of England (BoE) Executive Director David Bailey, in which he discussed how the Prudential Regulation Authority (PRA) can support innovation in the UK banking and insurance sectors and how doing so can support firms becoming more resilient as well as promoting competition, UK competitiveness and growth.
• (16 Jun 2025) HM Treasury policy paper setting out its plans to amend the buy-now, pay-later (BNPL) regime in relation to domestic premises suppliers (DPS). Following industry engagement, the Government has concluded that DPS offering BNPL as a payment option present a low risk to consumers and therefore the approach set out in its original draft BNPL legislation was disproportionate. The policy paper sets out the Government's intention to lay an amending negative statutory instrument to remove the requirement for DPS to have credit broking permissions to offer BNPL products.
• (13 Jun 2025) The deadline for responding to the Financial Conduct Authority (FCA)'s discussion paper (DP25/1) on its proposed approach to regulating cryptoasset trading platforms, intermediaries, cryptoasset lending and borrowing, staking and decentralised finance, and the use of credit to purchase cryptoassets has now passed. Responses published to date include those from: BBA | GBBC | GDF & CCI | IA | ICAEW | TPA | WFE
• (10 Jun 2025) Speech by FCA Chief Data, Information and Intelligence Officer, Jessica Rusu, on the FCA's collaboration with Nvidia on a new AI-focused sandbox. Among other things, Rusu announced the launch of the FCA's AI digital repository, an interactive platform where firms can explore real-world AI solutions in financial services.
• (23 May 2025) The deadline for commenting on HM Treasury's draft Financial Services and Markets Act 2000 (Regulated Activities and Miscellaneous Provisions) (Cryptoassets) Order 2025 has now passed. Responses published to date include those from: CryptoUK | FMLC | GBBC | GDF & CCI | IRSG | ISDA | UK Finance

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