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

• (19 Aug 2025) Dealcast: The M&A Podcast – Old and new banking pressures spur changes in sector M&A | In this podcast interview with Mergermarket, Thomas Krecek shared insights on how fintech innovation is converging with traditional banking, driving a wave of strategic dealmaking across the sector.
• (13 Aug 2025) Clifford Chance briefing – Latin America's digital infrastructure revolution: Financing the next wave of connectivity

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

International

• (19 Aug 2025) A group of major trade associations including, amongst others, AFME, FIA, GBBC, GFMA, GDF, IIF and ISDA has published a joint letter to the Basel Committee on Banking Supervision (BCBS) calling for a pause and recalibration of the cryptoasset exposures standard and an accompanying report highlighting the potential of distributed ledger technology (DLT) in capital markets. | Press release
• (18 Aug 2025) The Bank for International Settlements (BIS) Innovation Hub Hong Kong Centre has launched Project Noor, which is intended to equip financial supervisors with independent, practical tools to evaluate and interpret the inner workings of artificial intelligence (AI) models used by banks and other financial institutions. By combining explainable AI methods with risk analytics, the project aims to deliver a prototype through which supervisors can verify model transparency, assess fairness, and test robustness. | Project webpage
• (13 Aug 2025) BIS Bulletin setting out an approach to anti-money laundering compliance for cryptoassets. | Webpage

Americas

US:

• (19 Aug 2025) Speech by Federal Reserve Board Governor Michelle Bowman, in which she discussed the Federal Reserve's approach to technology and tools like blockchain in the context of bank supervision, including recent developments, the cost of supervisory focus on 'reputational risk', and principles for a tailored regulatory framework that accommodates technology. Amongst other things, Bowman argued that banks and regulators must be open to engaging in new technologies and depart from an overly cautious mindset.
• (18 Aug 2025) The US Department of the Treasury has issued a request for comment under the GENIUS Act, seeking feedback on innovative or novel methods, techniques, or strategies that regulated financial institutions use, or could potentially use, to detect illicit activity involving digital assets.  In particular, the Treasury is inviting comments on application program interfaces, artificial intelligence, digital identity verification, and the use of blockchain technology and monitoring. | Press release
• (15 Aug 2025) The Federal Reserve Board has announced that it will sunset its novel activities supervision programme, which was intended to supervise certain crypto and fintech activities in banks, and return to monitoring banks' novel activities through the normal supervisory process. | Press release
• (13 Aug 2025) Industry Letter to the Chairmen and Ranking Members of the US Senate Committee on Banking, Housing & Urban Affairs and Digital Assets Subcommittee, urging them to use the upcoming market structure legislation to strike Section 16(d) of the GENIUS Act and to oppose any expansion of its scope in this or future legislation. Section 16(d) allows any state-chartered uninsured depository institution with a stablecoin subsidiary to perform traditional money transmission and custody activities nationwide through that subsidiary. The signatories to the letter warn that this is an unprecedented overriding of state law and supervision which weakens vital consumer protections, creates opportunities for regulatory arbitrage, and undermines state sovereignty. The signatories are: Americans for Financial Reform, the Conference of State Bank Supervisors, the Independent Community Bankers of America, the Money Transmitter Regulators Association, the National Conference of State Legislatures and the National Consumer Law Center.

APAC

Hong Kong:

• (15 Aug 2025) Securities and Futures Commission (SFC) circular to licensed virtual asset trading (VATP) platform operators on custody of virtual assets, which provides examples of good practices along with the SFC's expected minimum standards that VATP operators must meet, covering senior management responsibilities, client cold wallet infrastructure and operation, use of third-party wallet solutions, and real-time threat monitoring. | Press release
• (14 Aug 2025) Hong Kong Monetary Authority (HKMA) and SFC joint statement on recent market movements in relation to stablecoins.
• Republic of Korea:
• (19 Aug 2025) The Financial Services Commission (FSC) has sent an administrative guidance letter to virtual asset exchanges calling on them to suspend all new virtual asset lending services until its final guidelines in this area are published. | Press release (in Korean)

Europe

EU:

• (20 Aug 2025) Commission Delegated Regulation (EU) 2025/885 setting out regulatory technical standards (RTS) under the Markets in Cryptoassets Regulation (MiCA) specifying the arrangements, systems and procedures to prevent, detect and report market abuse, the templates to be used for reporting suspected market abuse, and the coordination procedures between the competent authorities for the detection and sanctioning of market abuse in cross-border market abuse situations has been published in the Official Journal. | Entry into force: 9 September 2025.

UK:

• (19 Aug 2025) Financial Conduct Authority (FCA) Synthetic Data Expert Group report on generating and using synthetic data for models in financial services. | Webpage
• (19 Aug 2025) UK Finance blog post on AI’s role in fighting financial crime.
• (14 Aug 2025) FCA summary of discussions held in 2024 with members of its Cyber Coordination Group (CCG) programme, which includes industry insights on (i) reconnection frameworks and third-party management; (ii) threat and vulnerability management, including threat-led penetration testing; and (iii) the adoption of AI and emerging technologies.

EVENTS

• Calling all GENIUSes back to school; lets get CLARITY on Digital Assets! (New York, 10 September 2025): Confused between a central bank currency and a stablecoin, or a digital commodity and a tokenized security? Women in RegTech NYC join forces with Clifford Chance to unpack where we are in digital asset legislation and regulation including the GENIUS and CLARITY Acts. How will the new rules change the marketplace as well as existing technical requirements? Hear from our expert panel including Steven Gatti, Partner, Clifford Chance, Jamie Udinson, Head of Crypto Asset Investigation, FINRA and Kerry Gendron, JP Morgan (moderator). Both newcomers and experts are welcome as we work to understand the new crypto regime. |  Register for event.