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

• (16 Sep 2025) Talking Tech article – Property Rights Law in Digital Assets Under International Standards
• (12 Sep 2025) Talking Tech article – Draft ICO guidance and consultations: September update
• (11 Sep 2025) Talking Tech article – Transatlantic Data Transfers: Where the DPF Stands Post-Latombe
• (10 Sep 2025) Talking Tech article – Pseudonymized data after EDPS v SRB

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

Americas

US:

• (10 Sep 2025) Speech by Securities and Exchange Commission (SEC) Chairman Paul Atkins, in which he discussed "Project Crypto" and emphasised that providing certainty regarding the security status of cryptoassets was a priority for the SEC, noting that most crypto tokens are not securities. He also indicated that the SEC will work with other agencies so that a platform can offer trading in cryptoassets (whether or not they are securities), along with services like staking and lending, under a single regulatory umbrella.

Europe

EU:

• (16 Sep 2025) European Central Bank (ECB) working paper on central bank money as a catalyst for fungibility – the case of stablecoins.
• (15 Sep 2025) The French Autorité des Marchés Financiers (AMF), the Austrian Finanzmarktaufsichtsbehörde (FMA) and the Italian Commissione Nazionale per le Società e la Borsa (CONSOB) have put forward proposals aimed at ensuring a more effective supervision of cryptoasset markets, strengthening the competitiveness of European market participants and providing better investor protection. The three authorities believe that the first few months of application of the Markets in Cryptoassets Regulation (MiCA) have revealed major differences in how crypto markets are being supervised by national authorities. | Press release
• (15 Sep 2025) Commission Delegated Regulation (EU) 2025/1125 setting out regulatory technical standards (RTS) under MiCA specifying the information to be included in an application for authorisation to offer asset-referenced tokens (ARTs) to the public or to seek their admission to trading and Commission Implementing Regulation (EU) 2025/1126 setting out implementing technical standards (ITS) on the standard forms, templates and procedures for that information have been published in the Official Journal. Entry into force: 4 October 2025.
• (11 Sep 2025) Association for Financial Markets in Europe (AFME) position paper on the DORA Register of Information setting out implementation lessons learnt during the first register submission in early 2025 and future principles that AFME believes could achieve mutual benefits and better position both industry and authorities for a successful next submission in early 2026.

France:

• (12 Sep 2025) AMAFI-AFPDB-FBF response (in French) to the Autorité des marchés financiers (AMF) consultation on the marketing of crypto exchange traded notes.
• (Sep 2025) Paris Europlace Cryptoassets Regulation Working Group position paper on Europe’s response to the rise of dollar stablecoins, which provides an initial analysis of the potential implications for the competitiveness of the financial sector, the autonomy of monetary policy, the protection of savings and the sound financing of businesses.

UK:

• (17 Sep 2025) Financial Conduct Authority (FCA) consultation (CP25/25) on the proposed application of existing FCA Handbook rules to firms conducting regulated cryptoasset activities. The consultation sets out how existing FCA Handbook rules will apply to firms, including High Level Standards such as the Senior Management Arrangements, Systems and Controls (SYSC) Sourcebook (including governance, Senior Managers and Certification Regime, financial crime and operational resilience), and Business Standards (specifically the Environmental, Social and Governance Sourcebook). The FCA has also opened a discussion on how the Consumer Duty should apply to crypto and on how complaints should be managed, including whether consumers should be able to refer them to the Financial Ombudsman Service. The FCA has invited comments on the discussion proposals (chapters 6-7) by 15 October 2025 and feedback on the consultation proposals (chapters 1-5) by 12 November 2025. | Webpage | Press release

Middle East

UAE:

• (9 Sep 2025) The Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) has published Consultation Paper No. 9 of 2025, proposing several enhancements to the regulatory framework governing regulated activities involving fiat-referenced tokens (FRTs). The proposals build on the existing FRTs issuance framework introduced in December 2024 and reflect the FSRA’s evolving approach to digital assets. FRTs are defined as stablecoins pegged to a fixed amount of a single fiat currency and backed by high-quality, liquid assets in that same currency. Deadline for comments: 7 October 2025.

EVENTS

• Global Financial Markets Perspectives Series: Stablecoins – navigating the evolving global regulatory framework (online, 30 September 2025): New frameworks for stablecoins are emerging across global financial centres, including the US GENIUS Act for payment stablecoins, Hong Kong’s new regime for stablecoin issuers and a developing UK framework. As regulatory clarity grows, so do opportunities to leverage stablecoins for fast, cost-effective cross-border payments and transaction settlement, enhanced liquidity and collateral use. Join our international panel as they explore how different jurisdictions are approaching stablecoin oversight, including the lessons learned from more established regulatory frameworks such as the EU's Markets in Cryptoassets Regulation (MiCA), highlight key compliance challenges, and look at the future of stablecoin adoption. | To register, please see the event series registration form
• Global Financial Markets Perspectives Series: Strategic AI infrastructure – building, regulating, and monetising the future (online, 9 October 2025): AI’s growth demands purpose-built infrastructure. This session focuses on AI-ready data centres (high-density compute, advanced networking, liquid cooling, software-defined operations) and AI factories (the layer that turns data into models and services, providing the engine or "brain" which turns raw data into actionable intelligence through AI processes). We will cover the legal, strategic, and technical frameworks that shape them: data sovereignty and national security, regulation and risk, monetisation and deployment models, and sector-specific duties, with practical takeaways. | To register, please see the event series registration form
• Global Financial Markets Perspectives Series: Beyond the buzz – smart strategies for AI-driven deals (online, 6 November 2025): As artificial intelligence becomes a more frequent driver of deal value, investors and dealmakers are re-thinking how they assess and negotiate transactions. From concerns around AI washing to the rise of acquihires – where companies are bought primarily for the skills of the employees – market dynamics and regulatory concerns are shifting. Our panel will discuss the legal and regulatory developments that could have an influence on AI-oriented business models and provide practical insights on maximising value in AI-driven M&A and investment. | To register, please see the event series registration form