安永:2024全球金融服務監管展望報告(英文版)(頁).pdf

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安永:2024全球金融服務監管展望報告(英文版)(頁).pdf

1、2024 Global financial services regulatory outlook 2ContentsContactsIntroductionDigitalization of finance and greater use of artificial intelligenceThe digital asset ecosystemEnvironmental,social and governanceConsumer impactFinancial crime Operational resilienceNew prudential developmentsResolution

2、and recoveryBoard and management oversightSupervisory effectiveness3IntroductionPolitical and economic issues are creating a more complex environment for financial services regulators in 2024.Geopolitical tensions have increased over the past few years,amid deteriorating diplomatic ties between the

3、United States and China,war in Ukraine,conflict in the Middle East and tensions in Africa a possible harbinger of greater financial segregation.Many countries are regulating data,technology and climate issues in ways that follow national agendas and add layers to this complexity.Running a global org

4、anization has required the ability to tailor a generally consistent business model to the needs of individual markets.That tailoring is becoming increasingly important in terms of people,processes,data and technology.In some cases,the pressures may force organizations to become more focused and alig

5、ned to one set of markets.At the same time,an uncertain economic outlook characterized by rising energy costs and stubborn inflation in some jurisdictions,which could lead to higher customer indebtedness levels is raising questions about asset quality in 2024.Several high-profile bank failures are a

6、lso leading to increased scrutiny both of financial services firms and the regulatory bodies that oversee them.These challenges impact the regulatory outlook for 2024.This year we highlight nine priority topics driven by a mix of events and longstanding regulatory interests.Regulatory and supervisor

7、y focused priorities have become heightened due to recent market events,including prudential,resolution and recovery,board and management oversight and supervisory effectiveness.Other priorities include consumer impact,environmental,social and governance(ESG),digital assets,digitalization of finance

8、(payments and artificial intelligence or AI),financial crime and operational resilience.We highlight where firms should focus their attention in relation to the priorities identified for 2024.4New prudential developments Following the banking volatility of 2023,authorities will be recalibrating both

9、 regulation and supervisory approaches.Recent events underline the threats to viability at firms with significant conduct and reputational challenges in times of stressed market sentiment,even if prudential requirements appear satisfied.Although global authorities do not show any intention to move t

10、oward a zero-failure regime,they may need to reassess the risk of contagion arising from the failure of non-systemic institutions,while at the same time managing the potential moral hazard accompanying government and taxpayer support.Regulators globally will address how to respond to the accelerated

11、 pace of deposit outflows due to technology and social mediaat stressed banks.In hindsight,some liquidity regulation and most internal liquidity stress tests did not fully reflect changes in technology that impacted consumer behavior and increased the speed of digital runs across customers and produ

12、cts.In addition to continued reporting of liquidity and other metrics,we expect firms to see an uptick in more sophisticated and arguably thoughtful approaches to stress-test scenarios incorporating cultural and other non-financial risk considerations.In addition,US regulators are reemphasizing thei

13、r focus on liquidity risk management,through cash flow modeling and internal assumptions regarding deposit outflows,deposit segmentation,and asset monetization and testing.5Eventually,firms could see some targeted changes to outflow rates on uninsured deposits and the qualitative language around mon

14、etization;firms should understand this topic further,particularly in respect to potential vulnerabilities.But,actual changes to liquidity coverage ratios are likely to be small,with long time horizons.An area that firms will need to give more consideration to is specific stress scenarios.In addition

15、,there are questions about the scope of application for smaller banksfor example,in the US,Basel-equivalent standards could be extended down to banks with US$100b in assets.Where firms should focus their attention:Expect increased scrutiny from regulators on prudential issues,including exposures.Pre

16、pare for more stringent scenario-and stress-testing.Engage proactively with regulators on these issues.Engagement is always important,but,at a time of increased scrutiny,it can build credibility.Stress testsMore banks to be included in stress tests:EU:The 2023 European Banking Authority(EBA)stress t

17、est included 20 banks more than in the past,1 and introduced top-down elements for net fees and commission income(NFC)and a detailed analysis on banks sector exposure.UK:The Bank of England is considering testing more banks in 2024.2 It will conduct a desk-based stress-test exercise rather than an a

18、nnual cyclical scenario(ACS)test in 2024,but intends to return to the ACS format in 2025.3Future stress tests to evolve or be enhanced to include additional themes,risks and players:EU:The EBA may introduce supplementary proportionality considerations for the 2025 stress tests.It will also develop a

19、nd execute a(regular)climate stress test.4 EU:A stress test for European banks to test their cyber resilience will be launched in 2024 by the European Central Bank(ECB).5 UK:The Bank of England is launching its first system-wide stress test of the financial sector that will include not only banks bu

20、t also non-bank financial institutions,such as insurers,central counterparties and a wide variety of funds.Findings are expected to be published in 2024.6 Australia:Australian Prudential Regulatory Authority(APRA)announced it will develop a cross-industry stress testing framework.7 US:While the US 2

21、023 stress test was devised prior to the banking crisis,banks with large trading operations and exposure to the commercial real estate market were also a concern.In July 2023,the Federal Reserve called for stress tests to better capture risk and to test for a wider range of risks.8 Global:The Financ

22、ial Stability Board(FSB)announced it will develop and run a global bank stress test.96Although predating the global financial crisis(GFC),the concept of banks that are“too big to fail”(TBTF)became widespread following the crisis.Regulators in major jurisdictions committed to solving the principal pr

23、oblem of TBTF,removing the expectation of government support and in turn protecting the public purse.Authorities developed an international framework for more effective resolution,which directly targeted the impact of the failure of systemically important financial institutions.Guided by the Financi

24、al Stability Boards(FSBs)Total Loss-Absorbing Capacity(TLAC)principles and term sheet,regulators of globally systemically important banks(G-SIBs)used the regulatory consensus after the GFC to put in place minimum requirements for loss absorbent resources in resolution in addition to resolution plann

25、ing requirements.Alongside these resolution reforms,the Basel Committee on Banking Supervision strengthened the capital and liquidity standards for firms through the Basel III reforms.More recent developments include the US,where regulators issued notices of proposed rulemakings10 in August 2023 to

26、enhance resolution planning,particularly for large and regional banking organizations.If finalized,these would result in enhanced resolution planning requirements and new long-term debt requirements for some institutions.Resolution and recoveryIn the EU,regulators are focusing on liquidity as a key

27、element in making sure a bank is resolvable.According to recent guidance 11 banks internal frameworks,governance and management information systems are expected to be able to forecast the net liquidity position across time periods and at short notice.While most European banks will have adequate capa

28、bilities in place by 2024,this may require specific IT system improvements and identification and recruitment of staff with appropriate experience.Looking ahead,its possible that authorities will reassess the accepted resolution strategies for G-SIBs as well as non-systemic firms.In the UK,we have s

29、een policymakers seek to bridge the gap between recovery planning and resolution for non-systemic firms with proposals currently under consultation for new“solvent exit analysis requirements.”These proposals aim to increase confidence that small and mid-tier firms can exit with minimal disruption to

30、 the market and customers.This,in turn,should enable regulators to continue to authorize new entrants,promoting a well-functioning and competitive market.Where firms should focus their attention:Prioritize recovery and resolution testing at executive and board levels.Crisis testing must become more

31、challenging,with dynamic simulations targeting business vulnerabilities.Review the credibility of the approach to crisis management,in particular assumptions around the timeliness of decision-making based on indicators and communications.7Supervisory focus and scrutiny will increase on firms board a

32、nd management oversight.In some cases,the changes involve compensation for senior leadership teams,while in other cases,they address an overall culture of risk.Regulators increasingly recognize culture and compensation as two significant factors influencing firms inappropriate decision-making.Firms

33、will need to think more carefully about how their performance and incentive structures work and whether there is alignment between stakeholder goals and firms fiduciary duties.We have seen that in Asia-Pacific and in Australia,there are plans to align remuneration and risk,while also addressing remu

34、neration design,deferral and claw backs.Australia is also revising a prudential standard sayingin essencethat firms need governance,processes and a board-level view on risk culture.In Hong Kong,a financial regulator can apply to the court to claw back remuneration for firms senior management if thei

35、r actions were intentional,reckless or negligent and caused or materially contributed to their institution ceasing to be viable.Board and management oversight In the UK as part of the Consumer Duty,boards are being scrutinized about their leadership and oversight of the changes required by the new p

36、rinciple and rules.In the US,some agencies have recently finalized board effectiveness guidance only two years ago.But recent events in the industry,are spurring regulators to focus more on board and management oversight effectiveness.In addition to these changes,we anticipate greater regulatory scr

37、utiny on firms that have long-standing,known issues,with an expectation from supervisors that boards take more explicit action to address these issues.Where firms should focus their attention:Consider the issues of board and management oversight with a fresh eye,not just relying on established pract

38、ices,and think about the consistency and evidence of oversight.Ask hard questions about oversight:In a fast-changing world,does the board understand the full range of regulations it must meet?Is management information effective and does it strike the right balance between simplicity and comprehensiv

39、eness?What culture is the board seeking to create?What training programs are in place?How does remuneration,reward and practice reinforce the culture?8Supervisory effectivenessSeveral regulators issued post-mortem reports on the bank failures of 2023,12 including comments about the speed at which re

40、gulators expect outstanding issues to be resolvedand how some banks have failed to do so in the past.A key trend looking ahead is the increased speed and agility of supervision,with a particular emphasis on self-identifying and addressing emerging risk-management issues and any weaknesses in oversig

41、ht.13In July 2023,the Basel Committee released proposed revisions to its core principles for effective banking supervision.14 These are minimum standards of banking supervision and the revisions will focus,among others,on new risks,including climate-related financial risks and the digitalization of

42、finance.8Regulators are also moving to data-driven supervision and are enhancing their role as data hubs by focusing on improved data,information accessibility,usability and interoperability,along with data harmonization and standardization.For example,the regulators in the EU and Canada have establ

43、ished data strategies,15 while APRA and the Australian Securities and Investment Commission(ASIC,Australias conduct regulator)have a statutory mandate to cooperate and share information.All these measures are an indication that regulators will continue to strive to be more efficient and effective.Wh

44、ere firms should focus their attention:Engage proactively with regulators and other roundtables to understand best practices and developments.Monitor areas of regulator self-criticism for future areas of regulatory pressures on firms.9Status of finalization of Basel IIICanadaUSAAustraliaHong KongJap

45、anSingaporeSwitzerlandUKEurope(EU)North AmericaAsia-PacificEMEIARevised Standardized Approach(SA)for credit riskRevised Internal Ratings Based(IRB)approach for credit riskRevised Credit Valuation Adjustment(CVA)frameworkFundamental Review of the Trading Book(FRTB)/market riskOutput floorRevised oper

46、ational risk frameworkImplementation from:Q2 2023,except market risk and CVA risk in early 20241 July 2025 TBCEnd of 2022,except market and CVA risk 1 July 2024March 2024 for internationally active banks1 July 2024,except market risk and CVA risk in early 20241 January 20251 July 2025 TBC1 Jan 2025

47、TBCDraft regulation not published Draft regulation published and adoption in progressFinal rules published(but not yet implemented by banks)Final rules in force(published and implemented by banks)Basel III statusInternational insurance prudential regulations Insurance firms can expect some changes t

48、o prudential regulations in 2024.The global Insurance Capital Standard(ICS)19 is under final consultation ahead of its adoption of a group Prescribed Capital Requirement(PCR)for Internationally Active Insurance Groups(IAIGs)at year-end 2024.This will include changes to its three components:valuation

49、,capital requirements and capital resources.The International Association of Insurance Supervisors(IAIS)is launching public consultations on two Insurance Core Principles(ICPs).20 ICP 14 establishes supervisory requirements for the valuation of assets and liabilities for solvency purposes.ICP 17 est

50、ablishes requirements for regulatory capital resources and requirements.Key10As digitalization becomes business-as-usual,some firms are struggling to update legacy systems,leading to greater regulatory scrutiny.The latest EY/IIF global risk management survey found that 94%of chief risk officers say

51、they need“some”or“many”new skills and resources to meet the changing needs of the risk management function,with data science and cyber topping the list of most desirable skills.46 In 2024,regulators will continue raising the standard of digital resilience and tackle increased operational reliance on

52、 IT systems,third-party service providers and innovative technologies,which increases complexity and interconnections within the financial system and is driven by digital transformation.Firms will be required to reduce deficiencies in IT outsourcing,IT security or cyber risks and data governance.Whe

53、re firms should focus their attention:Decide on an overarching strategy for digital assets.Review changes to business models and updates to operational infrastructure.Confirm the target outcome and experience for customers.Understand the expectations of regulators under existing rulesand actively mo

54、nitor developments in technologies and regulatory guidance.Digitalization of finance and greater use of artificial intelligence11PaymentsIn June 2023,the EU published a revised Payment Services Directive(PSD3),a new payments regulation and a proposal for a new regulation on a Framework for Financial

55、 Data Access(FiDA).47 The FiDA introduces“open finance,”the next stage of the evolution of open banking.It expands data access and usage beyond payment and transaction data,while also including other areas of financial activity,such as insurance.Several jurisdictions are developing open finance fram

56、eworks.Currently,the EU,UK,Australia,Hong-Kong,Indonesia,Philippines and Brazil have adopted a regulatory-driven approach for open finance.As such,a global standard approach may be required to avoid regulatory fragmentation.Open finance regulation will require firms to set up multi-year strategic,op

57、erational and technological transformation programs.In Southeast Asia,a growing number of initiatives are underway to link domestic payment systems and enable frictionless cross-border payments.For example,Singapores PayNow system is linked with Indias UPI and Thailands PromptPay.UPI is expected to

58、become an important payment system in the region,as India seeks to monetize its platform by selling it to other countries to jumpstart adoption of digital payments.In the US,digital payments are dominated by two sets of competitors:FinTechs(including big tech firms)and traditional banks.Both groups

59、have developed new payment solutions and revamped the customer experience.Regarding the regulation of AI,there is significant debate but little clarity.Globally,organizations like the OECD and United Nations are actively developing guidelines to support coordinated approaches to the responsible use

60、of AI.Local governments are pushing ahead with new legislation.China included a draft AI law in their 2023 legislative work plan,though the process timeline is unclear.Canada also seeks to establish legislation through an AI and Data Act.48 However,other countries are weighing how to future-proof in

61、tervention and avoid stifling innovation.The US,Japan,South Korea and Singapore are focused on voluntary guidelines.The UK is proposing a framework of responsible AI principles for specific regulators.49Greater use of artificial intelligence In several markets,digital payments systems are accompanie

62、d by a digital identity initiative,such as Aadhar in India,BankID in Sweden and Norway,MitID in Denmark,and Interac Digital ID in Canada.Digital IDs generally work best when backed by governments and delivered in a way that improves the user experience.Countries that do not have yet a digital ID pro

63、gram are considering one.In a recent report on account closures,the FCA encourages the UK government to speed up its consideration of a robust digital ID as a tool to fight crime and improve the experience for financial services customers.Along with sector-agnostic regulation,financial regulators ar

64、e considering the need for new rules to complement their existing powers.Many are clarifying how their existing rules apply.Regulators will continue to refine their approaches,and international organizations may play a more active role.12Where firms should focus their attention:Strengthen resilience

65、 with senior management accountability.Develop and implement an enhanced operational resilience framework to address operational disruptions and meet new requirements.Form cross-functional teams for AI projects to address risk and compliance.Establish a governance framework for digital or new techno

66、logical adoption to maximize upside value and minimize risk.The EU AI act The European Commission has introduced the AI Act,which is set to position the EU as a leading regulator of AI for the foreseeable future.The Act seeks to standardize regulations surrounding AI development,market placement,ado

67、ption and use,while addressing the social,ethical,and security challenges posed by the technology through a three-tier categorization system.While the Act is still being finalized,it is expected to be completed by late 2023.Companies will have 18 to 24 months to comply with the new requirements foll

68、owing its implementation.1313The market for digital assets is maturing,with greater clarity about the different categories and options,but regulatory approaches vary by region.Although timelines remain unclear in some jurisdictions,the clear direction of travel is toward stronger regulatory framewor

69、ks.Digital asset ecosystemFungibleNon-fungibleFungible tokens are identical to each other and,therefore,can be used and transacted interchangeably.CryptocurrencyCryptocurrency assets are either the native asset of a blockchain or created as part of a platform that is built on an existing blockchain.

70、Native|governance|utilityStablecoinStablecoin assets are crypto tokens that are designed to mirror the price of a fiat currency like the US dollar.CBDC and digital fiatCentral Bank Digital Currency(CBDC)assets are on chain representations of a fiat currency.Digital fiat assets are tokenized fiat(e.g

71、.,US dollars)legally recognized as cash and are backed 1:1 with fiat currency.Security TokenSecurity tokens are on chain representation of traditional securities that exist off chain.Non-fungible tokens(NFTs)are unique and non-interchangeable assets stored and transmissible on a blockchain,and can r

72、epresent digitally native items or physical items that exist in the real world(e.g.,supply chain products).ChainlinkEtherbitcoinUniswapIn-game itemsMemorabiliaMetaverse landTicketsSand dollarARCoinArtDigital YuanUSDCDAIUSDTe-kronaDigital assets14Stablecoins Stablecoins are potentially the furthest a

73、long in terms of cross-jurisdictional alignment.The FSB issued high-level recommendations in July 2023 for the regulation,supervision and oversight of global stablecoin arrangements.34 Several regulators,particularly in Europe and Asia,are considering the recommendations with the goal of implementin

74、g them by the end of 2025,creating a clear regulatory boundary around stablecoins,focusing on capital requirements,disclosures and the redemptions for stablecoins.For example,Japans legal framework came into effect in early 2023.Singapores regulator issued a stablecoin framework in August 2023,35 in

75、cluding a requirement for disclosures.Hong Kong is also developing a stablecoin framework with a target implementation date of 2024.Whereas in the US,there is little agreement across partiesor even within partieson the basic tenets of stablecoin legislation,which is seen by many observers as a relat

76、ively straightforward first step on the path to more comprehensive crypto-asset legislation.Crypto-assetsThe FSBs latest framework36 follows the principle of“same activity,same risk,same regulation.”The framework seeks to bring crypto-asset activities and stablecoins under a regulatory umbrella that

77、 is proportionate to the risks they pose.In the US,there is still a debate about whether crypto-assets should be considered as commodities or securities,though there is greater clarity about how they should be taxed.The U.S.Department of the Treasury and the Internal Revenue Service(IRS)released pro

78、posed regulations in August 2023 on the sale and exchange of digital assets by brokers.37 This is part of a broader effort at the Treasury to close the tax gap,address the tax evasion risks posed by digital assets and help ensure that everyone plays by the same set of rules.We continue to see superv

79、isory actions in the US for the marketing practices of crypto-assets.Other jurisdictions,such as the UK,have also begun to focus on this;the FCA issued rules regarding the marketing of crypto,which came into force in October 2023.38 IOSCO,in a similar vein,also states that the marketing of crypto-as

80、sets should follow similar treatment as securities regulation.39 In the EU,firms are getting ready for MiCA40 to apply.While in Australia,ASIC has applied product design and distribution obligations to the marketing of margining of crypto assets.41 Traditional financial firms will have to decide soo

81、n on how they will engage in the crypto-asset markets and what areas they can engage in prudently in a manner consistent with existing risk management and compliance frameworks as well as regulatory requirements.Failure to make a decision could lead to losing a competitive advantage.Regulators are i

82、ssuing communications about the safety and marketing of pure crypto tokens to the public.Regulations will continue to expand to include AML/CFT risks,market conduct,resilience,cybersecurity and sales conduct.15Central bank digital currencies(CBDCs)Currently emerging markets are leading in the adopti

83、on of CBDCsthe Bahamas,Eastern Caribbean,Jamaica and Nigeria all have live retail CBDCsbut domestic acceptance is rather low.In developed markets,there is still a lack of clarity about which problems CBDCs can solve that faster modern payment systems havent already solvedand which potential problems

84、 they might create.Many central banks are seeking to understand how CBDCs fit into existing legal frameworks and financial market infrastructure.The primary focus thus far has been on retail CBDCs,rather than wholesale,due to a shift in consumer payments away from cash and toward cards,digital payme

85、nts and online marketplaces.Recent CBDC developments:For economies where retail CBDCs are live(such as China and India),the focus is on increasing adoption by getting the private sector to integrate CBDC payments options.The Peoples Bank of China recently announced42 that e-commerce platforms(like W

86、eChat and Alipay)need to facilitate CBDC payment options for the digital yuana measure aimed at boosting adoption.The Reserve Bank of Indias retail CBDC(Digital Rupee43)can now be accessed by one of Indias fastest growing commercial banks(Yes Bank)via its integration into the countrys Unified Paymen

87、ts Interface(UPI),which interoperates with the CBDC.The Reserve Bank of Australia(RBA)published a report with the key findings from its CBDC pilot program44.The key focus of the project was to engage with the industry to explore use cases for a retail or wholesale CBDC.Unlike other proofs of concept

88、,the Australian pilot was a real legal claim on the RBA.Four key themes were:enabling smarter payments;supporting innovation in financial and other assets;promoting private digital money innovation;and enhancing resilience and inclusion in the digital economy.The Bank of Japan(BOJ)completed its PoC

89、Phases 1 and 2 in March 2023 and entered into the pilot phase in April 2023.In the US,the Fed is researching CBDC system architectures,but has not made a decision about issuing a CBDC.The ECB announced45 the digital euro has reached its preparation phase,which is expected to take about two years.The

90、 pace has slowed down and careful consideration will be taken before deciding to create the digital currency.16There is also a growing supervisory focus on carbon markets.Enhancing supervisory oversight is expected to ensure that carbon markets function efficiently and transparently,boosting partici

91、pation.The International Organization for Securities Commissions(IOSCO)has made recent recommendations on compliance with carbon markets,24 and its upcoming final report on voluntary carbon markets will drive regulatory intervention by financial regulators and make these markets more consistent and

92、credible,addressing factors that have limited firms participation so far.Carbon markets BiodiversityBiodiversity loss is increasingly seen as a systemic risk to economies and financial systems.Although less established than climate,it will receive increased attention,with the International Sustainab

93、ility Standards Board(ISSB)identifying it as an upcoming focus area in its draft work plan.Furthermore,if the recently published Task Force on Nature-related Financial Disclosures(TNFD)recommendations25 follows the same path as the TCFD,it will likely become an element of mandatory reporting and dis

94、closures.Globally there is a greater regulatory oversight on ESG-related reporting and climate-risk management.Transition plans Financial regulators worldwide are focusing on net-zero transition planning.This could be driven by authorities requiring firms to have transition plans in place to manage

95、their exposure to financial risks or as a means to effect social change whereby finance institutions are leveraged to transition society to a lower carbon future.Key jurisdictional developments include the EUs proposed Corporate Due Diligence Directive(CS3D)21 which if approved will start to apply f

96、rom 2026,the HKMAs guidance on net-zero transition planning,22 and the Transition Plan Taskforces(TPT)disclosure framework,23 a gold standard for private sector transition plans in the UK.Environmental,social and governance17Reporting and disclosuresFrom international to national levels,there are co

97、ncerted efforts to improve sustainability reporting and disclosure standards.The ISSBs Sustainability Disclosure Standards will take effect in 2024 with the aim of becoming a universal standard.26 EY SourceVarious jurisdictions have announced their intention to adopt the standards as mandatory discl

98、osure requirements.The UK,Hong Kong,Australia and Singapore are already working toward implementing them domestically.However,firms operating across multiple jurisdictions face the challenge of reconciling different reporting frameworks.Currently,policy-setters are struggling to establish a minimum

99、baseline for reporting,with uncertainty from the US SEC in setting its final climate disclosure rules adding to the delay in setting a common framework.17TCFDISSBSECCSRDCurrent status of standardsFinalFinalDelayedFinalTypeVoluntaryVoluntaryMandatoryMandatoryPrimary audienceInvestorInvestorInvestorMu

100、lti-stakeholderMaterialityEnterprisePrimary users of general purpose financial reportsEnterpriseSocietalDisclosure locationAnnual ReportAnnual Report MixedManagement re-port(within the Annual report)AssuranceN/AN/AMandatoryMandatoryGovernance,strategy,risk narrativeRequiredRequiredRequiredRequiredSc

101、enario analysisRequiredRequiredConditionalRequiredGHG Scope 1,2RequiredRequiredRequiredRequiredGHG Scope 3ConditionalRequiredConditionalRequired2C,or lower,alignmentRecommendedRequiredNot requiredRequiredIndustry-specific disclosureRecommendedRequiredNot requiredRequiredSummary of key differences IS

102、SB,SEC and EU approaches to climate disclosure Definition of materiality(i.e.,enterprise vs.societal)Alignment with international climate agreements (e.g.,Paris)Mandatory disclosure of Scope 3 GHG or scenario analysis Industry-specific overlay Location of disclosures(i.e.,financial statements,separa

103、te sustainability report,or both)Key elements of the TCFD,ISSB,SEC and CSRD proposed approaches to climate disclosure18Climate as a financial riskGreenwashingRegulators continue to perform deep dives and stress tests on financial institutions to assess their climate risk management.APRA requires ent

104、ities to consider their businesss governance and risk management implications in relation to climate change.The ECB Banking Supervision stresses that banks must meet their supervisory expectations for climate-related risks by year end 2024 or face potential penalties.In line with the NGFS,some regul

105、ators are exploring shorter-term,more actionable climate risk stress tests.Regulators are addressing greenwashing risks caused by the misalignment of ESG-related fund names and objectives.New regulations are likely to address sustainable investment labels,disclosure requirements and restrictions on

106、the use of sustainability-related terms in product naming and marketing.The US SEC adopted amendments to the Investment Company Names Act,effective 10 December 2023(the compliance date for the final amendments is 10 December 2025 for larger entities and 10 June 2026 for smaller entities).27 The UKs

107、FCA anti-greenwashing rule28 is expected to be published in Q4 2024,while the European Supervisory Authority is reviewing greenwashing practices with final reports expected in May 2024.29 In the Asia-Pacific region,the HKMAs anti-greenwashing circular30 was issued in December 2022,with another consu

108、ltation ongoing,while ASIC in Australia has expanded its surveillance and enforcement activities related to greenwashing.19In keeping with the“S”element of ESG,policymakers are also focusing on specific areas to address human rights and global environmental impacts as captured by the EUs proposed CS

109、3D.The proposal,which also covers third-country companies,could pose a significant business compliance challenge.Diversity,equity and inclusion(DEI)is a topic of current interest in Europe and could gain traction in the US.In the UK,new rules on diversity and inclusion31 are likely to come into forc

110、e by Q3/Q4 2025.The regulator plans to extend non-financial misconduct rules,introduce a new regulatory framework on diversity The“S”in ESGWhere firms should focus their attention:Set robust transition plans with clear targets,embedding biodiversity and climate-related risks.Manage climate and envir

111、onmental risks through an institution-wide approach covering business strategy,governance,risk management,and clear targets and disclosures.Develop a data-sourcing strategy to support sustainability disclosures,including third-party providers,ESG rating providers,and other participants.Invest in fun

112、ction-specific ESG training targeted at key personnel.and inclusion and increase regulatory reporting on certain characteristics for larger firms.In the EU,the EBA is consulting on guidelines on the benchmarking of diversity practices.The guidelines will address the collection of data on diversity p

113、olicies,diversity practices and the gender pay gap at the level of the management body,and apply to institutions and investment firms.32 The U.S.Securities and Exchange Commission released its first Diversity,Equity,Inclusion,and Accessibility Strategic Plan in September,which could signal new regul

114、ations relating to DEI.3320Regulators are expanding their focus beyond strict compliance with existing regulations to a broader and more proactive assessment of how firms products affect different types of consumers.With a focus on securing consumers best interests,regulators are considering the imp

115、act of pricing,clear product information,the vulnerability and financial literacy of consumers,and climate within the overall consumer impact remit.The introduction of the UKs Consumer Duty in July 2023 by the FCA is a prime example of this move toward more outcome-based regulation.Central banks are

116、 also making changes to their consumer protection codes,with the Central Bank of Ireland focusing on products that secure the best interests of consumers,16 the Monetary Authority of Singapore(MAS)consulting in December 2022 on its Fair Dealing Guidelines17.Similarly in the US,the Consumer Financial

117、 Protection Bureau(CFPB),Federal Reserve and the Office of the Comptroller of the Currency(OCC)are considering similar changes,though there is a question about whether such regulations would come to pass or withstand a challenge in the Supreme Court.Hong Kong has also long emphasized the importance

118、of firms acting in the interests of customers,even though these principles have not been articulated into a set of rules.Firms should also expect wider regulatory reach but arguably a more level playing field for those competing in the same spaces irrespective of direct licensing requirements.For ex

119、ample,buy-now-pay-later(BNPL)and embedded finance players will face the same level of scrutiny,as retail financial services players do.Australia already regulates BNPL in this manner,and the UK is in the final stages of a protracted consultation18 on the issue.In the EU,the European Securities and M

120、arkets Authority(ESMA)is looking at alternative marketing channels,such as social media through the consumer-impact lens.Consumer impact Where firms should focus their attention:Shift the mindset with top-down training and firm-wide commitment,in light of regulatory focus on culture.Ensure the full

121、implications are considered before implementing new products and services.21Financial crime remains a priority,and global regulators consistently see areas for improvementalong with,in some cases,supervisory action and fines.Some firms faced supervisory scrutiny in 2023 over AML breaches,and regulat

122、ors are maintaining their focus on economic sanctions and are revisiting the treatment of politically exposed persons.Technology complicates the regulatory picture as well.While it creates new types of threats,it also offers new tools in the fight against financial crime.Adoption of data and AI solu

123、tions for financial crime compliance will grow.More recently,fraud has become a hot topicwith criminals looking to capitalize on economic instability.Australians lost a record sum of more than US$2b to scams in 2021,scams are made possible by a wide variety of technologies.Bank transfers accounted f

124、or the majority of scam payments.This is an area of much deeper management and concern for the financial system,especially at the retail level.Firms are preparing for a rise in fraud and investment scams as economic stress pushes customers toward risk-taking behavior.Financial crime Other key financ

125、ial crime trends Instant payments will require instant monitoring and analysis.Focus on crypto crime prevention and regulatory scrutiny will surge.For example,some regulators are expanding current guidance to include new players,such as crypto asset providers.Even as technology creates new types of

126、threats,it also offers new tools in the fight against financial crime.Adoption of data and AI solutions for financial crime compliance will grow.The regulatory focus on environmental crime is increasing.Financial crime compliance will include industries beyond financial services.2222Where firms shou

127、ld focus their attention:From a strategic point of view,dedicate resources to follow the proposals.This would mean;systems,controls,policies,procedures,people and technology can all be adapted or enhanced ahead of implementation.Consider the use of more sophisticated technology to support fraud dete

128、ction,such as AI.The EU AML package The EU“single rulebook”regulation50 provides guidelines for completing customer due diligence,disclosing the identities of beneficial owners,using anonymous instruments like crypto assets and introducing new entities,such as crowd funding platforms.The sixth Anti-

129、Money Laundering directive51 includes national provisions on oversight,Financial Intelligence Units and information sharing requirements.The regulation52 establishing the European Anti-Money Laundering Authority(AMLA)with supervisory and investigative powers,to ensure compliance with AML/CFT require

130、ments.Amendment of the EU Transfer of Funds regulation53 on the information accompanying the transfers of funds and certain crypto-assets,in order to make it possible to trace respective transfers.23Operational resilience Operational resilience remains a key regulatory focus area globally.Financial

131、regulatory bodies across the globe have witnessed how interconnected global financial ecosystems are updating guidance to protect them.54 The recent bank crisis highlighted gaps in banks risk oversight and risk and resilience governance and controls.There is also a shift away from treating operation

132、al resilience as merely a compliance activity;regulators view it through a consumer harm lens,and firms should also treat it this way.In the US,for example,some firms now include a chief resilience officer among the C-suite.In Australia,APRA has made operational resilience a heightened focus,finaliz

133、ing prudential standards and guidance to strengthen recovery and resolution planning and the preparedness of the Australian financial services sector to respond to crises.55 In Canada,most banks are still in the early stages of developing their operational resilience programs.A draft guideline from

134、the Office of the Superintendent of Financial Institutions(OSFI),was published in October 2023,and clarifies the operational resilience requirements for Canadian banks.56Looking ahead,regulators will improve cyber resilience across the financial sectorconducting cyber reviews on areas of weakness an

135、d remediation plans,pursuing breaches,sharing insights and issuing industry-wide guidance.In Australia,for example,as part of APRAs Cyber Strategy to uplift cyber resilience across the Where firms should focus their attention:Consider the risk appetite and which processes and procedures may pose res

136、ilience challenges.For instance,adapt change management,cybersecurity and data confidentiality procedures to remote working.Intensify scenario testing by considering a wider variety of scenarios and stretching their severity,such as a cyber outage during a pandemic.financial sector,APRA has commence

137、d a major exercise involving independent cyber reviews.Through the receipt of the first series of information security assessments(required by Prudential Standard CPS 234 Information Security),APRA will assess individual gaps and provide holistic insights into the state of cyber resilience across th

138、e industry and pursue breaches of the standard.Firms will also need to comply with the EUs Digital Operational Resilience Act(DORA)from 1 January 2025;2024 will be paramount for DORA readiness.In addition to cyber resilience,regulators will strengthen third-and fourth-party risk management.There are

139、 global efforts to reduce regulatory fragmentation across jurisdictions and sectors and strengthen financial institutions ability to manage third-party risks.FSBs final toolkit is expected by the end of 2023.24Contact the authorsChristopher Woolard CBEChair EY Global Regulatory Network EY EMEIA Regu

140、latory Lead,Partner,Ernst&Young LLP+44 207 760 8166 Marc SaidenbergEY Americas Financial Services Regulatory Lead,Principal,Ernst&Young LLP+1 212 773 9361 Eugne GoyneEY Asia-Pacific Financial Services Regulatory Lead,Associate Partner Ernst&Young LLP+852 9666 3434 Danielle Grennan EY EMEIA Financial

141、 Services Regulatory and Public Policy Lead Ernst&Young LLP+44 20 7197 9245 25Meena D Meena has over 35 years experience in government of which the last 23 years were in senior regulatory roles.She was the Executive Director of Enforcement and Anti-Money Laundering Supervision at the Hong Kong Monet

142、ary Authority.Prior to that,she was the Executive Director for Banking Conduct and Chief Executive Officer of the Hong Kong Deposit Protection Board.She also served as Deputy General Counsel and,before that,Senior Counsel.Prior to the HKMA,she was a Senior Government Counsel with the Department of J

143、ustice of the Hong Kong Government.Mario DMarios former roles include FROB(Spanish Banking Resolution Authority)Head of International Coordination and EBA and FSB representative;Spanish Ministry of Economy:Director of Office of the Secretary of State for the Economy in the Economic Affairs;Head of t

144、he Spanish Delegation in the Paris Club;and Deputy Head of Relations with the IMF.Eugne GEugne has over 20 years in government and senior regulatory roles.He was previously deputy head of enforcement at the Hong Kong Securities and Futures Commission(SFC).Prior to the SFC,Eugne worked at the Austral

145、ian Securities and Investments Commission and the Australian Attorney Generals Department.Alina HAlina worked for 20 years in financial services and legal roles before joining the global EY organization.She worked in senior leadership roles at the Australian Securities and Investments Commission and

146、 across regulatory enforcement and supervision,corporate finance and strategic policy.During this time,she led the advocacy for and,later,development of several key policies,including those relating to product governance,complaints and regulator funding and powers.Raghu KRaghu has over 20 years of c

147、onsumer banking and financial regulatory experience.He was the Acting Director of Banking for the State of New Jersey and served as the top banking official in the state overseeing state chartered banks,credit unions,consumer finance companies and real estate professionals.He also led the states eco

148、nomic relief efforts in response to the COVID-19 crisis.Prior to that,he was an executive at Wells Fargo Bank,where he led the public policy and consumer regulation practice groups for their mortgage division.Corinne KCorinne was head of policy analysis and coordination at the European Banking Autho

149、rity,where she negotiated various EU banking legislation(Capital Requirements Directive/Regulation,Financial Conglomerates Directive,Payment Services Directive,Anti-Money Laundering Directive)and supervisory policy on behalf of the EBA.Prior to that she was a banking supervisor at the Bank of Englan

150、d/Financial Services Authority,where she supervised various banking groups including UK,EMEIA,Japanese and Australian banks.Alejandro LAlejandro(Alex)has over 20 years of experience at the Federal Reserve Bank of New York in monetary policy,capital markets and financial supervision and regulation.He

151、 was a senior supervisor involved in the oversight of large and systemically important FBOs in the US.Prior to his role as a senior supervisor,he was involved in many of the Federal Reserves financial crisis management efforts.Jamila A.Mayfield Jamila was an Assistant Regional Director with the US S

152、ecurities and Exchange Commissions Division of Examinations.Jamila worked with FINRA,the Federal Reserve,CTFC,NFA,US Attorneys Office,FBI and other regulators to improve compliance and monitor risk as a regulator.EY Global Regulatory Network executive team26Shane ONShane has 20 years of experience i

153、n banking,capital markets,asset finance and prudential regulation in a variety of CFO,COO,strategy and planning,and regulatory roles.Following the financial crisis,Shane was Head of Banking Supervision at a Eurozone Central Bank for four years,during which he influenced significant restructuring,rec

154、apitalization and change in the banking sector and in credit institutions,and executed numerous stress tests and asset quality reviews.Keith PKeith has been based in Asia for over 25 years and has more than 30 years of professional experience.He has held a number of leadership roles,both regionally

155、and globally within EY.He is the Chairman of the Listing Committee of the HKEX and a member of the policy subcommittees of the exchange,as well as the chair of the Standing Committee on ESG and Corporate Governance(CG).Keith is also the EY representative and Co-Chair of the Bank Working Group of the

156、 Global Public Policy Committee.Alex RAlex spent 25 years working in public and regulatory roles.He was at the Financial Conduct Authority for eight years,during which he was responsible for developing regulatory policy across consumer and retail businesses.Alex has regulatory experience leading pol

157、icy development across retail investments,disclosure,banking,payments,crypto assets,general insurance,mortgages,funeral plans,asset management and claims management companies.As part of and later as Head of Strategy,Alex led the team responsible for the development of the FCA Mission,laying out thei

158、r strategic approach to regulating financial services.Prior to his career in regulatory policy,Alex worked as an economist.Marc SMarc was Senior Vice President and Director of Supervisory Policy at Federal Reserve Bank of New York;Basel Committee Member and Liquidity Working Group Co-chair;and invol

159、ved in the development of supervisory expectations for capital planning,liquidity risk management and resolution planning.Ed SEd spent 14 years in financial regulation and supervision in Ireland and the UK.He was Deputy Governor at the Central Bank of Ireland for five years,with responsibility for p

160、rudential regulation and supervision of financial services operating in and out of Ireland,including retail and investment banks,insurance firms,investment firms and asset managers,and payment and e-money institutions.Ed was on the Supervisory Board of the Banking Supervision arm of the European Cen

161、tral Bank(the SSM).He also served on the Board of Supervisors at the European Banking Authority,the European Insurance and Occupational Insurance Authority(EIOPA),and various domestic and European high-level groups and networks.Ajay SAjay was a Product Manager at Reveleus for Basel II,ICAAP and Econ

162、omic Capital solutions.Ajay has extensive experience in banking regulatory frameworks,such as Basel II/III,IFRS9,CCAR,BCBS 239 governing the areas of credit risk management(quantitative modeling,processes and technology),enterprise risk management,stress testing and capital management.Recently,Ajay

163、has been spearheading climate risk modeling capabilities and in improving access to finance for SME borrowers and bottom-of-pyramid customers.Ajay is a certified FRM,PRM and SCR.Christopher Woolard CBEChristopher had a 25-year career in public service before joining EY.He joined the Financial Conduc

164、t Authority in 2013 and served as Executive Director of Strategy and Competition,a member of the FCAs Board and last as interim Chief Executive in 2020.He founded Project Innovate and the FCA regulatory sandbox.He has served as a member of the Bank of Englands Financial Policy Committee,the IOSCO Bo

165、ard and the FSBs Strategic Risk Committee.271.“EBA publishes the results of its 2023 EU-wide stress test,”European Banking Authority(EBA),https:/www.eba.europa.eu/eba-publishes-results-its-2023-eu-wide-stress-test#:text=This%20year%27s%20stress%20test%20includes,analysis%20on%20banks%27%20sectoral%2

166、0exposures.,July 28,2023.2.“Bank of England praises UK financial resilience as it announces shift in stress testing for 2024,”FStech,https:/www.fstech.co.uk/fst/Bank_Of_England_Shift_Stress_Test.php,October 11,2023.3.“Financial Policy Summary and Record-October 2023,”Bank of England,https:/www.banko

167、fengland.co.uk/financial-policy-summary-and-record/2023/october-2023,October 10,2023.4.“EBA workprogramme 2024,”European Banking Authority(EBA),https:/www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Reports/2023/1062275/EBA%20Work%20programme%202024.pdf,September 2023.5

168、.“EU-wide EBA stress tests and SREP stress tests,”European Central Bank(ECB),https:/www.bankingsupervision.europa.eu/banking/tasks/stresstests/html/index.en.html,accessed October 23,2023.6.“Bank of England launches first system-wide exploratory scenario exercise,”Bank of England,https:/www.bankofeng

169、land.co.uk/news/2023/june/boe-launches-first-system-wide-exploratory-scenario-exercise,June 19,2023.7.“APRA-2023-24 Corporate Plan,”Australian Prudential Regulatory Authority(APRA),https:/www.apra.gov.au/apra-corporate-plan-2023-24#strategic-priorities-and-key-activities,accessed October 23,2023.8.“

170、Holistic capital review,“Federal Reserve,https:/www.federalreserve.gov/newsevents/speech/barr20230710a.htm,July 10,2023.9.“FSB Work Programme for 2023,”Financial Stability Board(FSB),https:/www.fsb.org/wp-content/uploads/P300323.pdf,March 30,2023.10.“Agencies propose guidance to enhance resolution p

171、lanning at large banks,”Federal Reserve,https:/www.federalreserve.gov/newsevents/pressreleases/bcreg20230829b.htm,August 29,2023 and“FDIC Board of Directors Issues Proposed Rule to Strengthen Resolution Planning for Large Banks,”FDIC,https:/www.fdic.gov/news/press-releases/2023/pr23066.html,August 2

172、9,2023.11.“Operational guidance for banks on the measurement and reporting of the liquidity situation in resolution,”Single Resolution Board(SRB),https:/www.srb.europa.eu/system/files/media/document/2023-06-16_Operational-Guidance-on-Liquidity-in-Resolution.pdf,June 2023.12.“FSB review of 2023 bank

173、failures assesses implications for the operation of the international resolution framework,”Financial Stability Board(FSB),https:/www.fsb.org/2023/10/fsb-review-of-2023-bank-failures-assesses-implications-for-the-operation-of-the-international-resolution-framework/,October 10,2023.13.“Agencies reque

174、st comment on proposed rule to require large banks to maintain long-term debt to improve financial stability and resolution,”https:/www.federalreserve.gov/newsevents/pressreleases/bcreg20230829a.htm,August 29,2023.14.“Core principles for effective banking supervision,”Basel Committee on Banking Supe

175、rvision(BCBS),https:/www.bis.org/bcbs/publ/d551.pdf,July 6,2023.15.“EBA workprogramme 2024,”European Banking Authority(EBA),https:/www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Reports/2023/1062275/EBA%20Work%20programme%202024.pdf,September 2023 and“OSFI 2023-2024 De

176、partmental Plan,”OSFI,https:/www.osfi-bsif.gc.ca/Eng/osfi-bsif/rep-rap/rpp/dp2324/Pages/default.aspx,March 14,2023.16.“Consumer protection code review,”Central Bank of Ireland,https:/www.centralbank.ie/regulation/consumer-protection/consumer-protection-codes-regulations/consumer-protection-code-revi

177、ew,July 2023.17.“Consultation Paper on Revisions to Guidelines on Fair Dealing”,Monetary Authority of Singapore(MAS),https:/www.mas.gov.sg/publications/consultations/2022/consultation-paper-on-revisions-to-guidelines-on-fair-dealing,December 14,2022.18.“Regulation of buy-now pay-later consultation o

178、n draft legislation,”HM Treasury,https:/assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1136257/BNPL_consultation_on_draft_legislation.pdf,February 2023.19.“Public consultation on Insurance Capital Standard as a prescribed capital requirement,”IAIS,https:/www.

179、iaisweb.org/2023/06/public-consultation-on-insurance-capital-standard-as-a-prescribed-capital-requirement/,June 23,2023.20.“Public consultation on ICP 14(Valuation)and ICP 17(Capital Adequacy),”IAIS,https:/www.iaisweb.org/2023/06/public-consultation-on-icps-14-and-17/,June 23,2023.21.“On 1 June 2023

180、,the European Parliament agreed on its position on the Directive on corporate sustainability due diligence(the CSDDD),”European Parliament,https:/www.europarl.europa.eu/doceo/document/TA-9-2023-0209_EN.html,June 1,2023.22.“Planning for net-zero transition”,Hong Kong Monetary Authority(HKMA),https:/w

181、ww.hkma.gov.hk/media/eng/doc/key-information/guidelines-and-circular/2023/20230829e1.pdf,August 29,2023.23.“Transition Plan Taskforce(TPT)disclosure framework,”TPT,https:/ 2023.24.“FR 08/23 Compliance Carbon Markets,”IOSCO,https:/www.iosco.org/library/pubdocs/pdf/IOSCOPD740.pdf,July 2023.25.“Recomme

182、ndations of the Taskforce on Nature-related Financial Disclosures,”TNFD,https:/tnfd.global/wp-content/uploads/2023/08/Recommendations_of_the_Taskforce_on_Nature-related_Financial_Disclosures_September_2023.pdf,September 2023.26.“IFRS S1 General Requirements for Disclosure of Sustainability-related F

183、inancial Information and IFRS S2 Climate-related Disclosures,”International Sustainability Standards Board(ISSB),https:/www.ifrs.org/projects/completed-projects/2023/general-sustainability-related-disclosures/,June 2023.27.“Investment Company Names Act,”Securities and Exchange Commission(SEC),https:

184、/www.sec.gov/files/rules/final/2023/33-11238.pdf,September 20,2023.28.“FCA proposes new rules to tackle greenwashing,”Financial Conduct Authority(FCA),https:/www.fca.org.uk/news/press-releases/fca-proposes-new-rules-tackle-greenwashing,October 25,2022.29.“ESAs put forward common understanding of gre

185、enwashing and warn on risks,”European Supervisory Authorities(ESAs),https:/www.esma.europa.eu/press-news/esma-news/esas-put-forward-common-understanding-greenwashing-and-warn-risks,June 1,2023.30.“Due diligence processes for green and sustainable products”,Hong Kong Monetary Authority(HKMA),https:/w

186、ww.hkma.gov.hk/media/eng/doc/key-information/guidelines-and-circular/2022/20221209e3.pdf,December 9,2022.31.“CP23/20:Diversity and inclusion in the financial sector,”Financial Conduct Authority(FCA),https:/www.fca.org.uk/publications/consultation-papers/cp23-20-diversity-inclusion-financial-sector-w

187、orking-together-drive-change,September 25,2023.32.“Draft Guidelines on the benchmarking of diversity practices,”European Banking Authority(EBA),https:/www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Consultations/2023/Consultation%20on%20draft%20Guidelines%20on%20the%20

188、benchmarking%20of%20diversity%20practices%20including%20diversity%20policies%20and%20gender%20pay%20gap/1054882/CP%20on%20draft%20Guidelines%20on%20the%20diversity%20benchmarking%20exercise.pdf,April 24,2023.33.“SEC Diversity,Equity,Inclusion,and Accessibility Strategic Plan Fiscal Years 2023-2026,S

189、ecurities and Exchange Commission(SEC),https:/www.sec.gov/files/sec-deia-strategic-plan-2023-2026.pdf,September 14,2023.34.“High-level Recommendations for the Regulation,Supervision and Oversight of Global Stablecoin Arrangements,”Financial Stability Board(FSB),https:/www.fsb.org/2023/07/high-level-

190、recommendations-for-the-regulation-supervision-and-oversight-of-global-stablecoin-arrangements-final-report/,July 17,2023.35.“MAS Finalises Stablecoin Regulatory Framework,”Monetary Authority of Singapore(MAS),mas-stablecoin-regulatory-framework-infographic.pdf,August 15,2023.36.“FSB Global Regulato

191、ry Framework for Crypto-asset Activities,”Financial Stability Board(FSB),https:/www.fsb.org/2023/07/fsb-global-regulatory-framework-for-crypto-asset-activities/,July 17,2023.37.“Proposed regulations on sales and exchanges of digital assets by brokers,U.S.Department of the Treasury,IRS,https:/www.fed

192、eralregister.gov/documents/2023/08/29/2023-17565/gross-proceeds-and-basis-reporting-by-brokers-and-determination-of-amount-realized-and-basis-for August 25,2023.38.“FCA sets expectations ahead of incoming crypto marketing rules,”Financial Conduct Authority(FCA),https:/www.fca.org.uk/news/press-relea

193、ses/fca-sets-expectations-ahead-incoming-crypto-marketing-rules,September 7,2023.39.“CR01/2023:Policy Recommendations for Crypto and Digital Asset Markets(iosco.org),”IOSCO,https:/www.iosco.org/library/pubdocs/pdf/IOSCOPD734.pdf,May 2023.40.“The New EU Markets in Crypto-Assets Regulation(MiCAR),”EY.

194、com,https:/ June 2023.41.“ASIC proposes to extend design and distribution obligations instrument,”Australian Securities&Investment Commission(ASIC),https:/asic.gov.au/about-asic/news-centre/find-a-media-release/2023-releases/23-220mr-asic-proposes-to-extend-design-and-distribution-obligations-instru

195、ment/,August 15,2023.42.“Bank of China:Platforms must provide digital yuan retail payment option,”Cointelegraph,https:/ 4,2023.43.“Digital rupee gets big usability boost through Yes Bank integration with UPI,”Cointelegraph,https:/ 1,2023.44.“Australian CBDC Pilot for Digital Finance Innovation,”Rese

196、rve Bank of Australia(RBA),https:/www.rba.gov.au/payments-and-infrastructure/central-bank-digital-currency/pdf/australian-cbdc-pilot-for-digital-finance-innovation-project-report.pdf,August 2023.45.“Eurosystem proceeds to next phase of digital euro project,”,46.“How bank CROs are responding to volat

197、ility and shifting risk profiles”,EY.com,Jan Bellens,Bill Hobbs and Christopher Woolard,https:/ 10,2023.References47.“Payment Services,“European Commission(EC),https:/finance.ec.europa.eu/consumer-finance-and-payments/payment-services/payment-services_en,accessed October 24,2023.48.“Artificial Intel

198、ligence and Data Act,”Government of Canada,https:/ised-isde.canada.ca/site/innovation-better-canada/en/artificial-intelligence-and-data-act,September 2023.49.“A pro-innovation approach to AI regulation,”UK Government,https:/www.gov.uk/government/publications/ai-regulation-a-pro-innovation-approach/w

199、hite-paper,March 20,2023.50.“Report on the proposal for a regulation of the European Parliament and of the Council on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing”,European Parliament(EP),https:/www.europarl.europa.eu/doceo/document/A-

200、9-2023-0151_EN.html,April 14,2023.51.“Report on the proposal for a directive of the European Parliament and of the Council on the mechanisms to be put in place by the Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing and r

201、epealing Directive(EU)2015/849”,European Parliament(EP),https:/www.europarl.europa.eu/doceo/document/A-9-2023-0150_EN.html,April 14,2023.52.“Report on the proposal for a regulation of the European Parliament and of the Council establishing the Authority for Anti-Money Laundering and Countering the F

202、inancing of Terrorism and amending Regulations(EU)No 1093/2010,(EU)1094/2010,(EU)1095/2010,”European Parliament(EP),https:/www.europarl.europa.eu/doceo/document/A-9-2023-0128_EN.html,April 5,2023.53.“COM(2021)422:Proposal for a regulation on information accompanying transfers of funds and certain cr

203、ypto-assets,”European Union(EU),https:/eur-lex.europa.eu/legal-content/EN/HIS/?uri=CELEX:52021PC0422,accessed 23 October 2023.54.“Resilience by Design:Leading vs.Reacting|EY Canada,”EY.com,https:/ 12,2023.55.“APRA finalises reforms aimed at strengthening recovery and resolution planning,”Australian

204、Prudential Regulatory Authority(APRA),https:/www.apra.gov.au/news-and-publications/apra-finalises-reforms-aimed-at-strengthening-recovery-and-resolution,May 18,2023.56.“Draft guideline:operational resilience and operational risk management,”Office of the Superintendent of Financial Institutions(OSFI

205、),October 2023.EY|Building a better working worldEY exists to build a better working world,helping to create long-term value for clients,people and society and build trust in the capital markets.Enabled by data and technology,diverse EY teams in over 150 countries provide trust through assurance and

206、 help clients grow,transform and operate.Working across assurance,consulting,law,strategy,tax and transactions,EY teams ask better questions to find new answers for the complex issues facing our world today.EY refers to the global organization,and may refer to one or more,of the member firms of Erns

207、t&Young Global Limited,each of which is a separate legal entity.Ernst&Young Global Limited,a UK company limited by guarantee,does not provide services to clients.Information about how EY collects and uses personal data and a description of the rights individuals have under data protection legislatio

208、n are available via member firms do not practice law where prohibited by local laws.For more information about our organization,please visit .2023 EYGM Limited.All Rights Reserved.CSG No.2310-4366442EYG no.011278-23Gbl ED NoneThis material has been prepared for general informational purposes only and is not intended to be relied upon as accounting,tax,legal or other professional advice.Please refer to your advisors for specific

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