Compliance & Ethics

De Nederlandsche Bank (DNB) has required trust company Erez Corporate Service BV to pay a EUR $100,000 penalty because it failed to cure serious violations of the Trust Offices Supervision Act 2018 within the six-month period set by an April 2024 Penalty Payment Order. The case shows that regulators will follow up on remediation deadlines and escalate when firms do not fix deficiencies in risk assessments, procedures, and client due diligence. The decision is now irrevocable because Erez withdrew its appeal.

Japan's Financial Services Agency ordered a recipient of information from an issuer's officer to pay an administrative surcharge of JPY $6.56 Million for insider trading in Goodspeed Co., Ltd. shares ahead of a tender offer. The case shows that tippees, not only corporate insiders, face enforcement under the Financial Instruments and Exchange Act (FIEA). Compliance teams should treat it as a prompt to review controls over material non-public information (MNPI) and personal trading.

The SEC issued an order creating time-limited exemptions that allow tokenized National Market System (NMS) stocks to trade onchain through a new category of entity called "tokenized securities venues" (TSVs). TSVs are exempt from the Exchange Act definition of "exchange," and certain liquidity providers are exempt from the definition of "dealer." Compliance teams at broker-dealers, trading venues, and issuers should assess whether to participate, how to opt out, and how to prepare for the permanent rules that will follow.

Japan's Financial Services Agency ordered ENECHANGE Co., Ltd. to pay an administrative monetary penalty of JPY $91,495,000 for false statements in its quarterly reports, following a recommendation from the Securities and Exchange Surveillance Commission (SESC). The respondent acknowledged the facts and the penalty amount, which allowed the matter to conclude through a streamlined adjudication. The case shows that disclosure accuracy remains a priority enforcement area for issuers and their control functions.

DNB and the Netherlands Forensic Institute (NFI) outlined a three-line defense against explosive ATM attacks: hardened machines, banknote-staining systems with ink, glue, and synthetic DNA, and refusal of soiled notes by businesses and consumers. This is an awareness-focused press release rather than a new rule, but it signals supervisory expectations on cash security, physical risk, and handling of stolen-note proceeds. Compliance teams at banks, cash handlers, and retailers should confirm that their controls reflect these expectations.

The Bank of England has published its 2027 Monetary Policy Committee (MPC) calendar, with eight announcement dates running from February through December 2027. The calendar will anchor rate-sensitive planning, treasury, and market-risk activity. The Bank also confirmed that historical MPC transcripts and staff inputs for all 2018 meetings will be released on 7 January 2027.

The FCA published findings from its consumer vulnerability review of payments and e-money firms. It found that the best outcomes came from firms that understood their customers and tested whether their support worked in practice, rather than relying on policies alone. Compliance teams should treat this as a supervisory signal that firms need evidence of good outcomes for customers in vulnerable circumstances, regardless of firm size.