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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


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


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


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 - 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


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


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


UK's Evolving Regulatory Framework for Digital Assets and Markets: A Deep Dive
The United Kingdom is forging a comprehensive regulatory framework for digital assets and markets to balance innovation, consumer...
James Ross
Aug 5, 20247 min read


Quarterly DeFi Review: International Developments Q2 2024
The decentralised finance (DeFi) landscape continues to evolve rapidly, with significant developments worldwide in the second quarter of...
James Ross
Aug 3, 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


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


UK's Crypto Future: A Deep Dive into the Government's Proposed Regulatory Framework
The UK government has set its sights on becoming a global hub for crypto innovation. But with innovation comes responsibility – and that...
James Ross
Jul 21, 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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