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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
Apr 59 min read


SwanFS Report: Potential Impacts of February 2026 Regulatory Developments on CASP Business Models and Revenue Generation
Executive Summary February 2026 represented a structural inflexion point for the global digital asset industry. Regulatory frameworks across major jurisdictions—from the Parliamentary enactment of the UK’s Final Crypto Regime Statutory Instrument to the EU’s AMLA data collection initiatives and the operational onset of the U.S. Treasury’s broker tax reporting—have definitively transitioned from conceptual rulemaking to active enforcement and structural market integration. For
James Ross
Mar 64 min read


SWANFS REGULATORY BRIEFING: The New UK Cryptoassets Regime
1. Executive Summary The Financial Conduct Authority (FCA) has concluded its introductory webinar outlining the definitive roadmap for the UK’s transition from the limited Money Laundering Regulations (MLR) to a comprehensive Financial Services and Markets Act (FSMA) regime. The headline message is critical: The regulatory bar has been raised significantly. There is no automatic transfer (“grandfathering”) for currently registered firms. Every Crypto Asset Service Provider
James Ross
Feb 14 min read


Strategic Implications of the EU Market Integration Package on Crypto-Asset Service Provider Business Models and Revenue Architectures
1. Executive Summary: 1. The Macro-Strategic Shift: From “Move Fast” to Industrial Policy The EU’s “Market Integration and Supervision” package (MiCA 2.0) represents a fundamental pivot from consumer protection to geopolitical industrial strategy. Grounded in the Draghi Report’s call to close the EU’s investment gap, this regulation aims to “sanitise” the crypto sector to mobilise household savings. Strategic Implication: The era of “move fast and break things” is foreclosed.
James Ross
Dec 16, 202516 min read


The Property (Digital Assets etc) Act 2025: A Jurisprudential and Commercial Paradigm Shift
Executive Summary The Royal Assent granted to the Property (Digital Assets etc.) Act 2025 on December 2, 2025, marks a significant turning point in the history of English private law. Although this legislation is relatively brief, it has a profound impact on the United Kingdom’s legal and commercial landscape, effectively resolving a long-standing doctrinal stalemate that had threatened to separate the common law from the realities of the modern digital economy. By formally b
James Ross
Dec 5, 202515 min read


Swan FS Global Regulatory Developments Report: November 2025
Executive Summary November 2025 represents a watershed moment in global financial regulation, characterised by a stark bifurcation in regulatory philosophy between the Atlantic powers. In the European Union, the transition to granular operational enforcement reached its zenith with the designation of Critical ICT Third-Party Providers (CTPPs) under the Digital Operational Resilience Act (DORA) and the finalisation of technical standards under the Markets in Crypto-Assets Regu
James Ross
Dec 3, 20257 min read


The Great Re-Platforming: A Strategic and Operational Analysis of the UK’s Transition to FSMA Part 4A for Cryptoasset Service Providers
Executive Summary The UK’s financial services sector is undergoing a major regulatory shift as Cryptoasset Service Providers (CASPs) move from limited AML registration to full authorisation under FSMA. This “re-platforming” transforms the industry. This report provides a detailed analysis, clarifies misconceptions, highlights omissions, and redefines strategic directions for firms in this space. The analysis based on consultation papers and HM Treasury drafts shows this trans
James Ross
Nov 27, 202518 min read


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 11, 202518 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 2, 20258 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 31, 202527 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 2, 202523 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 1, 202513 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 7, 20254 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 29, 20258 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 12, 20256 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 11, 20254 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 10, 20256 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 10, 20258 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 31, 20253 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 29, 20254 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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