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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
4 days ago9 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


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


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: 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 9, 202515 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 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


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


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


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 2, 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


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 1, 20254 min read


Global Digital Assets Regulatory Developments - November 2024: Europe in Focus
Executive Summary: Global Digital Asset Regulatory Developments - November 2024 November 2024 witnessed significant regulatory progress...
James Ross
Dec 3, 20245 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


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


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


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


The SEC vs. Ripple: A Partial Victory and Regulatory Lessons for Crypto Firms
The cryptocurrency industry has closely watched the SEC's lawsuit against Ripple Labs. The recent ruling marks a pivotal moment with...
James Ross
Aug 8, 20242 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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