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What we think
We distil and translate the latest developments in public policy, regulation and governance


SwanFS Analysis of the Bank of England’s Proposed Regulatory Regime for Systemic Sterling Stablecoins
Introduction: A ‘Multi-Money’ System and the Grand Bargain: Contextualising the November 2025 Consultation The Bank of England (BoE) consultation paper (CP) published on 10 November 2025, ‘Proposed regulatory regime for sterling-denominated systemic stablecoins’, represents a pivotal and pragmatic evolution in the United Kingdom’s approach to digital assets. This document is not a preliminary discussion; it is a mature, highly detailed, and commercially aware proposal. It has
James Ross
Nov 1118 min read


SwanFS: Key Considerations for Crypto Asset Service Providers, arising from recent developments
I. Executive Summary This week’s developments signal an evolution in the regulatory environment, shifting from theoretical risk to tangible enforcement actions and notable strategic divergence among key jurisdictions. For Crypto Asset Service Providers (CASPs), the global landscape now presents three primary areas of focus that merit careful consideration for our operational, product, and legal strategies. Enforcement and AML/CTF Scrutiny. The €21.46 million fine imposed by
James Ross
Nov 915 min read


SwanFS Report on October 2025 Regulatory Developments: Potential Impacts on Crypto-Asset Service Provider Business Models
Executive Summary October 2025 marked a material shift in the regulatory landscape for the crypto-asset industry, moving from high-level principles to binding technical implementation. The fragmented, principles-based guidance of the past has been supplanted by a wave of detailed, binding Regulatory Technical Standards (RTS), supervisory Q&As, and thematic reports. This transition fundamentally alters the operational, prudential, and economic landscape for Crypto-Asset Servic
James Ross
Nov 28 min read


SwanFS 2026 Risk and Compliance Framework for EU Crypto-Asset Service Providers: Navigating the Supervisory Trinity of MiCA, DORA, and AMLA
Executive Summary 2026 marks a pivotal year for EU Crypto-Asset Service Providers (CASPs), marking the culmination of a multi-year effort to establish comprehensive regulation for digital assets. The transitional “grandfathering” period under MiCA, as per Article 143(3), ends on July 1, 2026, removing legacy buffers and implementing a uniform licensing and conduct system across the Union. Meanwhile, the Digital Operational Resilience Act (DORA), which has been effective since
James Ross
Oct 3127 min read


SwanFS Digital Markets and Asset Risk Register 2025: A Technical Analysis of the Global Regulatory Implementation Wave
Executive Summary 2025 marks a pivotal shift for digital assets and financial markets, moving from regulatory development to strict...
James Ross
Oct 223 min read


Global Regulatory Developments: September 2025
Executive Summary September 2025 marked a critical phase in the maturation of the European Union’s digital asset regulatory landscape....
James Ross
Oct 113 min read


FCA Authorisation Gateway: Analysis of Evolving Prudential and Conduct Standards
I. Executive Summary The FCA's guidance shifts the standards for firms seeking authorisation or registration, marking a strategic change...
James Ross
Sep 1313 min read


UK Cabinet Reshuffle: Potential Implications for Digital Market Regulation and Economic Growth
Executive Summary This report analyses the potential implications of the recent UK cabinet reshuffle on the nation's digital market...
James Ross
Sep 74 min read


Global Regulatory Developments Report: August 2025
Executive Summary August 2025 witnessed a continuation of key regulatory and supervisory initiatives across major financial...
James Ross
Aug 298 min read


The U.S. Approach to the Regulation of Digital Asset Regulatory Framework
Executive Summary The year 2025 represents a watershed moment for digital asset regulation in the United States, marked by the...
James Ross
Aug 126 min read


UK Digital Asset Regulation: the Evolving Framework
Executive Summary The United Kingdom is executing a phased and comprehensive strategy to integrate digital assets into its established...
James Ross
Aug 114 min read


The United Kingdom's Strategy for Digital Assets and Financial Market Regulation
Executive Summary The United Kingdom government has initiated a comprehensive, multi-year strategy to re-engineer its financial services...
James Ross
Aug 106 min read


Global Regulatory Developments in Digital Assets and Markets: H1 2025 Strategic Impact Analysis
Executive Summary The first half of 2025 represents a pivotal inflexion point for the digital asset sector, characterised by a structural...
James Ross
Aug 108 min read


July Global Regulatory Developments Report
Global Regulatory Developments: July Executive Summary July marked a period of intense regulatory activity across the globe,...
James Ross
Jul 313 min read


Global Digital Asset Regulatory Developments: June 2025 Report
Executive Summary June 2025 marked a period of significant progress in establishing detailed regulatory frameworks for digital assets...
James Ross
Jun 294 min read


Global Digital Markets Regulation Intensifies in May with Focus on Stablecoins, Market Structure, and CBDCs
Global efforts to establish clear regulatory frameworks for digital assets gained significant momentum in May, with a concentrated focus...
James Ross
Jun 24 min read


Global Regulatory Developments - April 2025
April 2025 marked a period of significant regulatory progress and policy direction across key financial hubs, with a strong focus on...
James Ross
May 110 min read


Global Regulatory Developments - March 2025
March 2025 witnessed significant regulatory advancements in the global financial sector, particularly concerning digital finance. Key...
James Ross
Apr 27 min read


Report on Global Regulatory Developments - February
This report summarises key global regulatory developments in the financial sector during February. The focus is on publications,...
James Ross
Mar 28 min read


Global Regulatory Developments in January 2025
This report provides a comprehensive overview of the significant global regulatory developments in January, focusing on the key areas of...
James Ross
Feb 15 min read
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The posts listed on the 'What we think' webpages are our interpretation of key developments we have been reading about. They should not be considered legal, regulatory or other advice. Contact us if you want to understand the impact of public policy, regulation and governance changes for you.
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