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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


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


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 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


FCA Crypto Roadmap
The FCA Crypto Roadmap outlines the planned policy publications and timelines for regulating crypto assets in the UK. It sets out a...
James Ross
Nov 26, 20241 min read


Mansion House 2024: A New Era for UK Financial Services
Executive Summary The Chancellor's Mansion House 2024 speech and accompanying documents signal a significant shift in the UK's approach...
James Ross
Nov 17, 20247 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


Will MiCA be the MiFID I of Digital Markets and Assets?
MiFID, implemented in 2007, revolutionised European capital markets by increasing competition, transparency, and investor protection....
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


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
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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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