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


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


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


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


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


ESMA's 2025 Agenda: A Deep Dive into Impacts for Investment Managers and Service Providers - Part 2
The European Securities and Markets Authority (ESMA) has set an ambitious agenda for 2025, with significant implications for investment...
James Ross
Oct 3, 20242 min read


ESMA's 2025 Work Program: A Comprehensive Guide for Financial Firms Part One
The European Securities and Markets Authority (ESMA) has set an ambitious agenda for 2025, with a work program that covers a wide range...
James Ross
Oct 2, 202414 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 Round-Up - Operational Resilience: More Than Just Weathering the Storm
The financial services landscape is grappling with various operational challenges, from cyberattacks and third-party failures to the...
James Ross
Sep 28, 20248 min read


September DeFi Roundup - Rethinking DeFi Regulation: Embedded Supervision and the Future of Decentralised Finance
The world of Decentralised Finance (DeFi) is rapidly evolving, pushing the boundaries of traditional finance and challenging existing...
James Ross
Sep 28, 202411 min read


ECB's Draft Guide on Governance and Risk Culture - Focus on Culture and Conduct Deep Dive
The ECB draft guide emphasises the critical role of robust governance and a strong risk culture in ensuring the safety and soundness of...
James Ross
Aug 7, 20248 min read


MiCA Q&A Updates: Key Points & Firm Implications
The European Securities and Markets Authority (ESMA) has released a series of Q&A updates regarding the Markets in Crypto-Assets (MiCA)...
James Ross
Jul 30, 20242 min read


2025: A Pivotal Year for DORA Implementation in the EU Financial Sector - A Round up of Developments in July
The European Banking Authority (EBA) has unveiled its 2025 supervisory priorities, emphasising the significance of the Digital...
James Ross
Jul 29, 20242 min read


DORA Pillar 1: The Blueprint for Robust Digital Operational Resilience in Finance
The financial sector increasingly relies on technology to deliver essential services in the ever-evolving digital landscape. This...
James Ross
Jul 19, 20243 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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