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


Potential Impacts on CASP’s Business Models and Revenue Generation (March Regulatory Developments)
Executive Summary The global regulatory environment in March delivered an asynchronous, aggressive push toward integrating Crypto-Asset Service Providers (CASPs) into the traditional financial services (TradFi) perimeter. The sheer volume and severity of cross-jurisdictional updates—ranging from the European Union’s Digital Operational Resilience Act (DORA) and MiCA enforcement preparations, to the UK’s FSMA regime transition and the FATF’s targeted crackdown on offshore liqu
James Ross
3 days ago9 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 9, 202515 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 2, 20257 min read


Navigating the Shifting Sands: A Deep Dive into the EBA's 2025 Work Program and its Implications for Financial Institutions
The European Banking Authority (EBA) has released its work program for 2025, signalling a significant shift in the regulatory landscape...
James Ross
Oct 7, 20243 min read


2024: A Year of Regulatory Reckoning in Digital Markets
The digital landscape underwent significant changes in 2024 as regulators worldwide tightened their control over the industry. Every...
James Ross
Sep 29, 20245 min read


September's Global Regulatory Whirlwind: Key Developments in Digital Finance and Markets
September 2024 proved to be a whirlwind month for financial regulation across the globe. From the rise of digital currencies to the fight...
James Ross
Sep 28, 20243 min read


Key International Reports on Digital Markets and Assets Regulation (July 2024)
July 2024 marked a significant month for international reports addressing the evolving landscape of digital markets and assets. These...
James Ross
Aug 6, 20243 min read


Landmark FCA Fine for Coinbase Subsidiary Over Financial Crime Control Breaches
The UK's Financial Conduct Authority (FCA) has imposed a significant £3.5 million fine on CB Payments Ltd (CBPL), a subsidiary of...
James Ross
Jul 26, 20242 min read


EU Takes Strong Action Against Financial Crime: Get Ready for Tougher Anti-Money Laundering Regulations
The European Union has just unveiled a sweeping package of anti-money laundering (AML) regulations, signalling a significant shift...
James Ross
Jun 9, 20242 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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