GRC Report Staff

On September 15, 2026, BaFin published Circular 12/2026 (WA), which addresses the licensing procedure for alternative investment fund (AIF) management companies under Section 22 of the German Capital Investment Code (KAGB). Only the title and metadata were available, and the PDF was not accessible, so the specific requirements are unconfirmed. Compliance teams at current and prospective German AIF managers should obtain the full text promptly to assess its effect on authorization applications and ongoing licensing obligations.

When the Securities and Exchange Commission settled with SG Americas Securities in August 2023, one paragraph of the order concerned a document that did not yet exist. The firm had agreed to hire a consultant to test its repairs and to send the written results to the Commission’s staff. The order said the report was intended to remain nonpublic, with four exceptions, including a court order, the parties’ written agreement, a Commission determination that disclosure would further its duties, or a legal requirement. It gave the reasons. The report would likely contain confidential commercial information, and publication could discourage cooperation or impede government investigations.

Apple and Amazon were fined a combined €194 million by Spain's competition regulator in July 2023 and ordered to remove restrictions on the sale and advertising of Apple products. Nearly two years passed before the companies removed two sets of the offending clauses. That delay has brought both companies back before the National Commission on Markets and Competition (CNMC), which announced on November 3 that it had initiated new sanction proceedings over their failure to comply with the original order.

The penalties against iSignthis have survived another round in court. Nearly six years after Australian regulators brought proceedings against the payments company and its former chief executive, a federal appeals court has upheld approximately $7.7 million (A$11 million) in combined penalties and a six-year ban on the former CEO managing corporations.

A firm expecting to earn £500,000 or more from environmental, social and governance ratings will have just over a month next summer to submit its application for authorization under the UK's new regulatory regime. Smaller providers will have a separate window. By June 2028, firms carrying out regulated ESG ratings activities in the country will generally need permission from the Financial Conduct Authority to continue.

ESMA has published Q&A 2919 asking whether MiFID II investor protection rules apply when EU-based, EU-authorized investment firms serve clients outside the EU. The entry is marked "Forwarded to EC/Public Consultation/Other," so no definitive ESMA answer has been issued. Compliance teams with cross-border client bases should treat the territorial scope of their conduct obligations as unresolved and monitor for further guidance.

ASIC's Form 361 is the mechanism by which registered agents notify ASIC that they have ceased to act for one or more companies. It is not a new rule: the document is a form and guide dated 2011 and 2015, though it is labeled as a 2026 press release. Compliance teams should treat it as a reminder to confirm that agent offboarding and corporate records processes are accurate and current.