Compliance & Ethics

De Nederlandsche Bank has collected a penalty of EUR $100,000 from trust office Erez Corporate Service B.V. after it failed to remedy serious Wtt 2018 deficiencies within a six-month grace period. The deficiencies concerned its Systematic Integrity Risk Analysis (SIRA), procedures manual, and customer due diligence (CDD). The case shows that DNB will escalate from an order subject to penalty to financial penalties when remediation is inadequate, and that the decision is now final.

The CFTC's Market Participants Division has issued a broadly available no-action position for providers of passive trading software. Subject to specified conditions, staff will not recommend enforcement action for failure to register as an introducing broker (IB) or associated person (AP) of an IB. Compliance teams should confirm whether their software offerings or vendor relationships fit within the relief and whether the conditions are met.

The CNMV's September 2026 newsletter announces an agreement with Autocontrol to promote responsible financial advertising. It also covers AI-assisted reviews of advertising by investment management companies, results of an AML/CFT report review, and several published sanctions. The newsletter is a headline digest with little detail, but it signals where supervisory attention is heading.

The Hong Kong Monetary Authority set the Base Rate at 4.25% with immediate effect on September 17, 2026, following a 25-basis point increase in the US federal funds target range. The adjustment was driven by the pre-set formula, which tracks the US rate, rather than by local interbank conditions. Compliance teams should confirm that rate-linked products, disclosures, and liquidity procedures reflect the new rate.

Deutsche Bank has been fined €8 million by Germany’s financial regulator for failing to handle customer complaints promptly and delaying securities account transfers during the migration of Postbank customers to its shared IT platform in 2023.

The Deutsche Bundesbank, acting for the German federal government, will increase two federal bonds (2047 and 2056 maturities) through a multi-ISIN auction on September 23, 2026, targeting a combined EUR $2 Billion market maintenance quota. The notice is operational rather than a new regulatory obligation, but it matters to compliance teams at Federal Bidding Group member institutions, which must meet the bid submission rules, cutoffs, and settlement timeline.

At its second Proportionality Conference, BaFin said that simplified supervisory rules for less significant institutions (LSIs) give banks more freedom, but that freedom depends on responsible use. BaFin ties its push for a small bank regime in Europe to LSIs avoiding unnecessary restructuring and showing sound risk judgment. Compliance teams should expect a more principles-based, trust-driven supervisory dialogue in which citing legal provisions alone will not be enough.