Compliance & Ethics

Premier Payment Solutions Ltd (trading as PPS Money and MTBS), a UK small payment institution, entered voluntary liquidation on September 10, 2026, and joint liquidators from BTG Begbies Traynor have been appointed. Customer funds are not covered by the Financial Services Compensation Scheme (FSCS), and small payment institutions are not required to safeguard funds under the Payment Services Regulations 2017. Compliance teams at firms with exposure to PPS Money, whether as customers, counterparties, or agent networks, should assess their positions promptly.

Superintendent Routledge announced that OSFI is recalibrating its risk appetite. Financial system resilience remains the primary responsibility, but OSFI is adding an enhanced focus on supporting sustainable economic growth and on promoting competitive intensity. Compliance teams should expect capital amendments this fall and in 2027, easier market entry, and an annual regulatory burden reduction program. These changes will affect capital planning, supervisory engagement, and regulatory change management.

The SEC's Division of Examinations published a Risk Alert detailing observations on how investment advisers conduct the annual compliance review required under the Advisers Act compliance rule (Rule 206(4)-7). The alert identifies areas advisers should consider and encourages them to strengthen their review processes. Compliance teams should treat it as a preview of examination priorities and benchmark their current review practices against it.

The FSA's September 14, 2026 weekly review lists a draft partial amendment to the Comprehensive Guidelines for Supervision for Insurance Companies, new sustainability assurance and growth-funding council activity, and disaster-related measures for financial institutions. It also lists an unregistered money lending warning and draft EDINET Taxonomy updates for 2027. Compliance teams with Japanese operations should review the open consultation and the disaster reporting relief now, because several items carry action dates or likely downstream obligations.

The Netherlands Authority for Consumers and Markets (ACM) projects that households and businesses will pay an average of 20 percent more for electricity and natural-gas transport in 2027. For an average household, that is roughly EUR $89 more per year for electricity and EUR $52 more for gas. The increase is the first under a new revenue methodology and is driven by system operators' investment needs of approximately EUR $235 Billion over 15 years. Compliance teams with Dutch exposure should reassess energy cost assumptions, pass-through arrangements, and customer communications.

BaFin has published Circulars 10/2026 (BA) and 11/2026 (BA), setting out its administrative practice and expectations for appointing refinancing register administrators under the KWG and trustees under the PfandBG, including their deputies. Institutions must demonstrate that candidates are independent, reliable, and sufficiently expert. Compliance teams at covered institutions should review their appointment files and processes against these expectations.

The CNMV has completed its review of the first AML/CFT information reports (BCFT1, covering 2025) submitted by securities firms and agencies, asset managers, and crypto asset service providers. Overall report quality was adequate, but the CNMV found erroneous and inconsistent data and signs of possible compliance gaps, particularly in alert generation and special examinations. Compliance teams should expect these findings to inform further supervisory work.