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In AML & Financial Services Regulatory

United States: No Action, Big Impact – CFTC Harmonizes Cross-Border Rules

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On 9 December 2025, the U.S. Commodity Futures Trading Commission (CFTC) issued No-Action Letter 25-42 to streamline compliance for cross-border swap transactions.
The letter aligns with the 2020 Cross-Border Rule by standardizing key definitions such as “U.S. person” and “guarantee,” removes the need for conduit affiliate analysis, and allows continued reliance on prior classifications beyond the original 2027 sunset date. It also supersedes older no-action letters, reducing regulatory inconsistencies and simplifying compliance processes for market participants.

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In Antitrust / Competition

United States: Department of Justice Reaches Proposed Settlement with RealPage Pertaining to Algorithmic Pricing Tools

by , , , and 4 Mins Read

On 24 November 2025, the U.S. Department of Justice (DOJ) announced a proposed settlement with RealPage Inc. over alleged antitrust violations tied to its rental pricing algorithms. The agreement, effective for seven years, includes no fines or admission of wrongdoing.
Key terms restrict RealPage to using data at least 12 months old, prohibit real-time lease data, and ban geographic modeling below the state level. The company must avoid identical pricing recommendations, remove features discouraging price cuts, and stop sharing nonpublic, forward-looking data. A court-appointed monitor will oversee compliance.
This settlement underscores DOJ’s focus on algorithmic collusion and AI-driven pricing practices.

In AML & Financial Services Regulatory

European Union: SFDR 2.0 — simplified disclosures, new categories and stricter marketing rules

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On 20 November 2025, the European Commission proposed major changes to the Sustainable Finance Disclosure Regulation (SFDR) to simplify disclosures and strengthen investor protection. The new framework introduces three product categories—Transition, Sustainable, and ESG Basics—each requiring a 70% investment commitment and exclusion of harmful industries. Simplified two-page templates will replace current disclosure rules, and entity-level obligations like principal adverse impacts are removed.
Only products in these categories may use sustainability-related terms in marketing. Taxonomy disclosures become optional, with a 15% safe harbor for aligned assets. Application is expected 18 months after adoption, likely in 2028, marking a significant shift toward clearer, stricter sustainability standards.

In Corporate Compliance

SFO Issues Updated Guidance on Evaluating Corporate Compliance Programmes

by , , , and 5 Mins Read

On 26 November 2025, the Serious Fraud Office (SFO) published updated Guidance on Evaluating a Corporate Compliance Programme. The new guidance replaces the previous guidance introduced in January 2020 and sets out six scenarios in which the SFO may assess an organisation’s compliance programme. Following the introduction of the “failure…

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In Anti-Corruption

Colombia: Strengthening of the fight against smuggling and facilitation of smuggling — risks, prevention, and key recommendations for companies

by , and 5 Mins Read

On 19 November 2025, Colombia reinforced its legal framework to combat smuggling and the facilitation of smuggling, emphasizing risks, prevention, and corporate accountability.
The measures target unauthorized import/export practices and concealment of goods, with penalties escalating for goods exceeding statutory thresholds. Companies face heightened criminal liability for executives and representatives, even if goods are later regularized, alongside intensified enforcement by DIAN and the Prosecutor’s Office.
The framework underscores obligations for traceability, documentation, and internal compliance controls, while promoting employee training and reporting mechanisms. These actions aim to safeguard tax collection, fair competition, and economic integrity, signalling a strategic push toward stricter customs compliance and corporate governance.

In ESG

Brazil: CONAR announces new rules to combat greenwashing

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On 22 November 2025, Brazil’s National Council for Advertising Self-Regulation (CONAR) introduced new rules to combat greenwashing in advertising. The changes cover biodiversity, climate change, and waste disposal, reinforcing the sector’s commitment to environmental protection.
Two new articles encourage responsible socio-environmental communication and set guidelines for sustainability claims and technical terminology.
Advertisers must provide detailed data on emissions, carbon offsets, and product life cycles, along with specific deadlines and action plans for environmental goals. These changes aim to ensure transparency and prevent misleading sustainability claims.

In AML & Financial Services Regulatory

Taiwan: Amendment to Personal Data Protection Act

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On 17 October 2025, Taiwan’s Legislative Yuan passed amendments to the Personal Data Protection Act (PDPA), establishing the Personal Data Protection Commission (PDPC) as the new supervisory authority for personal data matters.
These changes respond to a 2022 Constitutional Court ruling and aim to strengthen independent oversight while enhancing data protection standards across both public and private sectors.
Key updates include mandatory appointment of Data Protection Officers (DPOs) for government agencies, new breach notification and reporting obligations for non-government entities, expanded inspection powers for the PDPC, and a six-year transition period for certain supervisory functions.
The PDPC will also issue baseline security regulations and serve as the appeals body for administrative decisions. The effective date will be set by the Executive Yuan, with implementation expected in 2026.

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In Tax

United States: After the Federal Circuit IEEPA tariff ruling, what comes next?

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On August 29, 2025, the US Court of Appeals for the Federal Circuit (CAFC) issued a 7-4 en banc opinion in VOS Selections, Inc. v. Trump, holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose broad, indefinite tariffs. The case was initially brought in the Court of International Trade (CIT) by private businesses and the US state attorneys general. The President invoked IEEPA on various grounds, including concerns about drug enforcement, border security, and trade deficits. In a May decision granting summary judgment to the VOS Selections plaintiffs, the CIT found that IEEPA does not authorize the President to impose the tariffs at issue, which the US Government appealed.

In Corporate Compliance

Singapore: Health Sciences Authority issues update on products found by overseas regulators to contain potent ingredients | June and July 2025

by and 3 Mins Read

On 15 August 2025, Singapore’s Health Sciences Authority (HSA) issued an update listing overseas health products found to contain potent, prohibited ingredients. These may cause harmful side effects. The HSA advises consumers to avoid such products and buy only from trusted sources. Sellers in Singapore face severe penalties for supplying adulterated products. The HSA continues monitoring global enforcement to protect local consumers and urges suppliers to assess any overseas regulatory impacts.

In Cybersecurity, Data and Tech

Fraud in the Modern Era and a Proactive Approach to Anti-Fraud Practices

by , and 4 Mins Read

Fraud poses significant legal, financial, and reputational risks for organizations. The FBI’s 2025 Internet Crime Report highlights over $16 billion in losses due to internet-related crimes, including phishing, extortion, and personal data breaches. ISO 37003, published in May 2025, provides guidelines for managing fraud risks through prevention, detection, response, and evaluation. Effective fraud control systems help organizations comply with legal standards and mitigate liability. ISO 37003 can integrate with other ISO standards to create a comprehensive Governance, Risk, and Compliance framework, aiding organizations in safeguarding against both internal and external fraud.

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