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


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


Global Regulatory Developments in Digital Assets: December 2024Executive Summary: Global Regulatory Developments in Digital Assets - December 2024
There was significant regulatory activity in December 2024. Globally, on establishing comprehensive frameworks for digital assets,...
James Ross
Jan 14 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 Issuer Disclosure and Beyond - Part 3
The European Securities and Markets Authority (ESMA) has unveiled its 2025 work program, setting a demanding agenda for financial firms...
James Ross
Oct 4, 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


CrowdStrike's System Crash: A Wake-Up Call for Firms' DORA Projects
A recent system crash experienced by CrowdStrike's Falcon sensor, as detailed in their technical root cause analysis, serves as a stark...
James Ross
Aug 8, 20242 min read


The Future of Finance: Key Regulatory Developments in July 2024
The financial landscape is rapidly transforming, driven by technological advancements and evolving market dynamics. In July 2024, several...
James Ross
Aug 1, 20243 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 4: Mastering the Art of ICT Third-Party Risk Management (Articles 28, 29, 30, & 45)
The Digital Operational Resilience Act (DORA) is not only about protecting your digital infrastructure; it's also about strengthening...
James Ross
Jul 22, 20243 min read


Pillar 3 of DORA: Putting Your Cyber Resilience to the Test - (Articles 24, 25, 26, 27)
The Digital Operational Resilience Act (DORA) sets a new standard for cyber resilience in the EU's financial sector. One of its most...
James Ross
Jul 21, 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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