Am I at Risk?

HIGH PRIORITY

FCA liquidity rules: implementation clock starts

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Why it matters?

UK UCITS, NURS, authorised fund managers, delegated managers and depositaries face strengthened expectations for liquidity assessments, stress testing and anti-dilution arrangements. The rules apply from 1 February 2027, so governance design and implementation should now move onto the 2026 planning agenda.

Red flags:

No named implementation owner; liquidity tools not linked to fund dealing profile;board reporting does not evidence challenge.

Key action:

‍Map impacted funds and delegates, confirm ownership, and establish a documented readiness plan covering stress testing, liquidity governance and anti-dilution tools.

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FCA scrutiny of Annex 1 firms: group controls may not be enough

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Why it matters?

The FCA is placinggreater focus on financial crime controls in Annex 1 firms. Entity-level riskassessments, policies and oversight evidence need to reflect the risks of theindividual business, rather than relying solely on a group-wide framework.

Red flags:

Generic group risk assessment; unclear delegated responsibility; limitedevidence that the UK entity challenges its service providers.

Key action:

Re-test each UK entity’s AMLrisk assessment and control set, then close gaps in delegated oversightrecords, governance minutes and management information.

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MEDIUM PRIORITY

Ireland expands access to beneficial ownership information

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Why it matters? Ireland’s amendedbeneficial ownership framework widens access for designated authorities andcertain third parties with a legitimate interest. The practical exposure is nota new filing project, but greater reliance on the accuracy and consistency ofexisting RBO records.

Key action Reconcile RBO entriesagainst statutory registers, investor due diligence files and governancerecords, and ensure escalation routes cover access requests and vulnerablebeneficial owners.

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US ownership transparency reduces, but your AML duties donot

Why it matters? FinCEN’s final ruleremoves CTA beneficial ownership reporting for US domestic entities. ForEuropean regulated firms, fewer official data points may be available whenverifying ownership and control of US LLCs, LPs, SPVs and holding structures.

Key action Identify due diligence stepsthat relied on CTA filings and strengthen direct collection, corroboration andrisk-based escalation for relevant US legal entity investors andcounterparties.

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LOW PRIORITY

Luxembourg considers umbrella flexibility for unregulatedpartnerships

Why it matters? Bill of Law No. 8814proposes umbrella functionality for unregulated SCS and SCSp AIFs managed by anEU-authorised AIFM, including legally segregated compartments. It may expandproduct design options, but remains subject to parliamentary approval.

Key action: Monitor the legislativeprocess and consider how compartment structures could affect future launches,operating models and governance mandates. Do not treat the proposal as enactedlaw.

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MMF stress-testing adoption shows supervisory convergence

Why it matters? ESMA’s compliance tableconfirms broad implementation of the revised 2025 MMF stress-testingGuidelines, including CSSF compliance through Circular CSSF 26/911. It does notadd a new implementation layer.

Key action: Confirm existing governanceevidence aligns with Circular CSSF 26/911 and continue monitoring for changesto scenarios or parameters.