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ECB 2022 Climate Stress Test Calls European Banks to Action

On July 8, 2022, the European Central Bank ("ECB") released the results from its annual stress tests, this year focused on banks' ability to incorporate climate risk stress testing into their risk management frameworks. The...more

EU Extends Travel Rule to Crypto-Assets

On June 29, 2022, the European Parliament, the Commission, and the Council reached a provisional agreement on the European Union proposal to update Regulation 2015/847 on information accompanying the transfer of funds ("TFR")...more

The Latest in Italian Cryptocurrency Regulation: Mandatory Fees for Providers and Exchangers

On April 21, 2022 the Italian Organismo Agenti e Mediatori issued a circular implementing the Ministry of Economic and Finance decree regarding statutory registration, fees, and obligations of cryptocurrency providers and...more

Breakthrough in Italian Cryptocurrency Regulation: Statutory Registration for Providers and Exchangers

The Italian Ministry of Economy and Finance ("MEF") issued a new decree ("Decree") requiring that virtual asset/currency service providers promptly enroll in a soon-to-be established special section of the register held by...more

European Large Asset Managers Now Unable to Opt Out of Article 4 SFDR

After June 30, 2021, large asset managers will no longer have the option to "explain" noncompliance with Article 4 of EU Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector...more

Temporary Post-Brexit Regime Applies to UK Financial Institutions Operating in Italy

In Short  The Situation: As of the close of the Brexit transition period ending on December 31, 2020 ("Withdrawal Date"), UK banks, UK investment firms, and UK electronic money institutions ("UK Financial Institutions") can...more

Getting Cautious on Cloud Outsourcing: ESMA Consults on Proposed Guidelines

The Situation: On June 3, 2020, the European Securities Market Authority ("ESMA") published a consultation paper on Outsourcing to Cloud Service Providers ("Proposed Guidelines"), which will apply to any institution under the...more

"To Be or Not to Be": Determining When a European Bond is a PRIIP

On October 24, 2019, the European Supervisory Authorities ("ESAs"), consisting of the European Securities and Markets Authority, the European Banking Authority, and the European Insurance and Occupational Pensions Authority,...more

Reforming Euribor: The Complicated Transition to Hybrid Methodology

The Situation: The updating of the Euro Interbank Offer Rate ("Euribor") to align it with the EU Benchmark Regulation 2016/1011 ("EU BMR") is in full swing. Under the EU BMR, only EU and third country BMR compliant benchmarks...more

Leveling the Financial Institutions Playing Field: EBA Publishes Revised Guidelines on Outsourcing Arrangements

The Situation: The European Banking Authority ("EBA") published its Final Report on EBA Draft Guidelines on Outsourcing Arrangements ("Guidelines") on February 25, 2019, which will eventually replace the existing CEBS...more

EU Council Releases Anti-Money Laundering Action Plan

The Situation: In response to recent cases of money laundering in European banks, the European Union has released an action plan to reinforce its recently proposed anti-money laundering ("AML") and Countering Financing of...more

Sustainable Finance Regulations, Rules, and Guidelines in the European Union and United States—Time to Get Prepared

Due to the increasing awareness of the importance of environmental, social, and governance ("ESG") initiatives, the European Commission came forward at the end of May 2018 with a proposal related to this topic. The proposal...more

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