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In AML & Financial Services Regulatory

United States: IRS issues 2025 transition relief and hints at future tips and overtime information reporting obligations

by , and 1 Min Read

On 16 December 2025, the Internal Revenue Service (IRS) issued two Notices addressing reporting obligations for tips and overtime under the Overtime and Bonus-Based Benefits Act (OBBBA).
The guidance provides transition relief for 2025, recognizing that employers and payors may not have updated systems or forms to comply with new requirements. It also explains how taxpayers can calculate deductions for tips and overtime when employer reporting is unavailable.
In addition, the notices signal future mandatory reporting obligations, indicating that structured compliance processes will be introduced in subsequent years.

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In AML & Financial Services Regulatory

Brazil: BCB and CMN establish additional cyber security requirements

by , and 3 Mins Read

On 18 December 2025, Brazil’s Central Bank (BCB) and National Monetary Council (CMN) issued new resolutions strengthening cybersecurity for financial institutions. The rules mandate 14 security controls, including encryption, intrusion detection, and monitoring of the Deep/Dark Web. Additional requirements apply to PIX and RSFN systems, cloud computing isolation, and annual independent intrusion tests. Institutions must comply by 1 March 2026.

In AML & Financial Services Regulatory

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

by , and 4 Mins Read

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.

In AML & Financial Services Regulatory

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

by , , and 4 Mins Read

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.

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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

by and 3 Mins Read

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 Tax

Vietnam and United States: Framework for an Agreement on Reciprocal, Fair, and Balanced Trade

by and 2 Mins Read

On 26 October 2025, the United States and Vietnam concluded a framework agreement aimed at establishing reciprocal, fair, and balanced trade relations. The final commitments are expected to be signed and ratified by both parties before the end of 2025.
This framework introduces comprehensive commitments across digital trade, services and investment, intellectual property, labor, environment, customs and trade facilitation, regulatory practices, and state-owned enterprise conduct. It includes reciprocal tariff arrangements, preferential market access for US exports, and the removal of technical barriers affecting US goods. These developments reflect a strategic effort to deepen bilateral economic cooperation while aligning regulatory standards and market access terms.

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In Tax

United States: White House publishes plan for the taxation of cryptocurrencies and other digital assets

by , and 1 Min Read

Earlier this summer, the US Administration’s Working Group on Digital Asset Markets published a report, entitled Strengthening American Leadership in Digital Financial Technology. The Report contains recommendations for revising existing legislation and IRS guidance regarding trusts engaged in cryptocurrency staking, Code provisions that may deny recognition of gains or losses by active securities traders, and reporting requirements for participants in digital asset transactions and for the exchanges that facilitate such activities

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