Compliance & Ethics

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.

The Bank of England has announced a long-term framework under which sterling banknotes will be backed primarily by gilts held directly on the Issue Department balance sheet, supplemented by a small Issue Deposit. The change follows the MPC's September 2026 decision to set a multi-year path for fully unwinding the Asset Purchase Facility. It is explanatory guidance rather than a new rule for firms, but compliance teams should assess its indirect effects on gilt markets, collateral availability, and reserves supply.

The FCA published good and poor practice findings from its review of payments and e-money firms' support for consumers in vulnerable circumstances under the Consumer Duty. No new rules are introduced, but the FCA expects firms to evidence that they understand customer needs, provide appropriate support, and deliver good outcomes, and it warns of supervisory intervention where expectations are not met. Compliance teams should use the findings to benchmark and close gaps now.