Clifford Chance

Welcome to this week's global fintech round-up, summarising fintech regulatory developments that have happened around the world along with our Clifford Chance fintech publications and upcoming events.

Details of these and previous developments can also be found on our Fintech Topic Guide on the Clifford Chance Financial Markets Toolkit.

CLIFFORD CHANCE BRIEFINGS AND MATERIALS

• (11 Mar 2025) Talking Tech article – The OCC eases cryptoasset guidance – new opportunities for banks
• (10 Mar 2025) Talking Tech article – Regulatory challenges for data centres in Spain
• (6 Mar 2025) Talking Tech article – Transatlantic Data Transfers: EU raises concerns over U.S. oversight changes (again)

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

International

• (12 Mar 2025) The International Organization of Securities Commissions (IOSCO) has published its work programme for 2025. One of IOSCO's priorities will be to address risks in fintech, which will include launching a pilot Crypto and Digital Assets (CDA) Implementation Monitoring initiative and working with the Committee on Payments and Market Infrastructures (CPMI) to strengthen the operational resilience of financial market infrastructures (FMIs). | Press release
• (12 Mar 2025) IOSCO consultation report on the rise of artificial intelligence (AI) use in capital markets and its impact on investors globally. Deadline for comments: 11 April 2025. | Press release

Americas

US:

• (12 Mar 2025) The Boosting Innovation, Technology, and Competitiveness through Optimized Investment Nationwide (BITCOIN) Act of 2025 has been introduced as a Bill in the US Senate. The Bill would establish a Strategic Bitcoin Reserve and other programmes in order to ensure the transparent management of Bitcoin holdings of the Federal Government.
• (10 Mar 2025) An updated version of the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, which is intended to establish a regulatory framework for payment stablecoins, has been introduced in the US Senate. |  Press release
• (10 Mar 2025) Speech by Securities and Exchange Commission (SEC) Acting Chairman Mark T. Uyeda, in which he discussed the SEC's 2022 proposal to amend the regulatory definition of an 'exchange'. Uyeda noted that the proposed expanded definition of an 'exchange' would have picked up various protocols used with respect to cryptoassets and argued that this was a mistake. He indicated that he has asked SEC staff for options on abandoning the crypto-related parts of the proposal.
• (7 Mar 2025) The Office of the Comptroller of the Currency (OCC) has published Interpretive Letter 1183 to confirm that cryptoasset custody, certain stablecoin activities, and participation in independent node verification networks such as distributed ledger are permissible for national banks and federal savings associations. The letter also rescinds the requirement for OCC-supervised institutions to receive supervisory nonobjection and demonstrate that they have adequate controls in place before they can engage in these cryptocurrency activities. | Press release
• (6 Mar 2025) President Trump has issued an Executive Order on the establishment of a Strategic Bitcoin Reserve, as well as a United States Digital Asset Stockpile, which is intended to serve as a secure account for the management of the United States’ other digital asset holdings.

Europe

EU:

• (10 Mar 2025) The European Supervisory Authorities (ESAs) guidelines on explanations and opinions, and the standardised test for cryptoassets under the Markets in Cryptoassets Regulation (MiCA) have been translated into the official EU languages. Date of application: 12 May 2025.
• (6 Mar 2025) European Central Bank (ECB) President Christine Lagarde has indicated that the ECB's deadline for its work on a digital euro is October 2025, although she noted that the ECB will not be in a position to issue a digital euro before the EU Commission, Parliament and Council complete the legislative process. | Transcript of press conference

UK:

• (10 Mar 2025) The Financial Conduct Authority (FCA) and Information Commissioners Office (ICO) have published a joint letter on supporting AI, innovation, and growth in financial services. They emphasise the need for regulatory clarity to support responsible innovation and public benefits. Both organisations have collaborated extensively, including participation in FCA TechSprints and the Digital Regulation Cooperation Forum’s AI and Digital Hub pilot. A recent survey identified data protection and the Consumer Duty as major regulatory constraints to AI deployment in financial services. To address these challenges, the FCA and ICO will host a roundtable with industry leaders in London on 9 May 2025 to discuss regulatory uncertainties, collaboration opportunities, and areas needing more support for innovation and technology adoption.

EVENTS

• Global Financial Markets Perspectives Series: Navigating US and EU regulatory regimes for tech and ESG/sustainability – managing risk and divergence (online, 25 March 2025): Our panel will examine legal considerations for global businesses navigating regulatory change on technology (including AI), data and on ESG/sustainability in the US and the EU. We will discuss practical steps in managing the extra-territorial effects of key regimes in the context of a rapidly changing policy environment in both the US and the EU, areas of enforcement prioritisation and de-prioritisation, and risk mitigation strategies for boards and management. | To register, please see the event series registration form
• Global Financial Markets Perspectives Series: AI Series: AI litigation and enforcement – the latest trends (online, 3 April 2025): As artificial intelligence becomes mainstream and increasingly advanced, organisations face changing litigation and regulatory enforcement risks. Our panel will discuss key areas of AI-related litigation and enforcement, including privacy issues, cybersecurity, intellectual property, consumer protection and 'AI washing'. Looking at recent cases and enforcement and anticipating potential hotspots in 2025, we will discuss practical approaches to AI risk management for organisations using AI and for financial investors. | To register, please see the event series registration form
• Global Financial Markets Perspectives Series: In conversation with Kenn Cukier – human advantage in an age of technology and turmoil (London, 29 April 2025): As part of Clifford Chance's Ethics Series, we are delighted that Kenn Cukier, Deputy Executive Editor at The Economist, and an AI, technology and data expert, will be in conversation with Clifford Chance lawyer Herbert Swaniker. They will discuss ethical considerations in AI by reference to Kenn's latest book 'Framers: Human Advantage in an Age of Technology and Turmoil' during which he will consider the important role that humanity will continue to play in an age of increasingly sophisticated Artificial Intelligence. | To register, please see the event series registration form