As part of our ongoing commitment to keeping our clients and stakeholders informed, j. awan & partners has compiled the latest regulatory developments shaping financial markets across the GCC, APAC and key global jurisdictions for November 2025. This edition highlights critical updates impacting Financial Institutions, Fintechs, VASPs and other Regulated Entities, including new consultations, enforcement actions, rule changes, and supervisory priorities. We encourage market participants to review these developments closely to stay aligned with evolving regulatory expectations and global best practices.

Gulf Cooperation Council Regulatory Developments

United Arab Emirates

Abu Dhabi Global Market | Financial Services Regulatory Authority (FSRA)

• ADGM FSRA Consults on Enhancements to Insurance Regulation and Climate Risk Management

  • The ADGM FSRA has issued Consultation Paper No. 13 of 2025 proposing amendments to the Insurance Regulatory Framework. The proposals cover enhancements to risk management and market conduct standards, updates to reinsurance requirements, alignment with IFRS 17 and the introduction of clearer expectations for climate risk management within insurance firms. The consultation signals an increased regulatory focus on resilience, transparency and climate related financial risks in the insurance sector. Insurers and insurance related authorised persons are encouraged to assess the potential impact of the proposals and prepare for policy, governance and risk framework updates ahead of implementation.

Source: ADGM

• ADGM FSRA Consults on Enhancements to Funds and Fund Managers Framework

  • The ADGM FSRA has released Consultation Paper No. 12 of 2025 proposing amendments to its Funds and Fund Managers framework. The proposals include streamlined regulatory regimes, revisions to requirements applicable to foreign fund managers and measures to facilitate employee investment arrangements. The consultation aims to enhance market efficiency and competitiveness while maintaining appropriate investor protection. Fund managers and asset managers operating in or from ADGM are encouraged to assess the potential impact on fund structures, eligibility criteria and operational arrangements and to provide feedback ahead of the consultation deadline.

Source: ADGM

Dubai Financial Services Authority (DFSA)

• DFSA Publishes Thematic Review on Continuing Professional Development for MLROs

  • The DFSA has published a thematic review examining how authorised firms meet continuing professional development requirements for Money Laundering Reporting Officers. The review sets out observed good practices alongside common deficiencies and clarifies supervisory expectations around MLRO competency, governance and ongoing professional development. The findings emphasise the importance of structured CPD frameworks, formal tracking of training hours and alignment between MLRO development plans and firms’ compliance management programmes. The DFSA expects firms to ensure that MLROs maintain skills and knowledge commensurate with the complexity, size and risk profile of their businesses.

Source: DFSA

• DFSA Issues Alert on Misleading Use of DIFC Address by Unauthorised Firm

  • The DFSA has issued an alert clarifying that Berkshire Consulting Co is not authorised by the regulator and has been misleadingly using a DIFC address associated with a legitimately authorised firm. The notice serves as a warning to the public and market participants regarding misrepresentation of regulatory status. The DFSA reiterates the importance of conducting appropriate regulatory checks when engaging with firms claiming DIFC or DFSA authorisation and highlights ongoing risks associated with unauthorised or impersonating entities operating in the market.

Source: DFSA

• DFSA Warns of Impersonation of Authorised Firm in Scam Activity

  • The DFSA has issued an alert warning that scammers have impersonated DFSA authorised Dalma Capital. An unauthorised entity, operating under the name D Finance Capital Management Ltd, falsely used Dalma Capital’s details to solicit and offer loans to the public. The alert highlights ongoing risks of firm impersonation and fraudulent activity targeting clients and market participants. The DFSA reiterates the need for vigilance when verifying the regulatory status and identity of firms claiming authorisation within the DIFC.

Source: DFSA

Virtual Assets Regulatory Authority (VARA)

• VARA Issues Circular on AML/CFT Risk Assessment Requirements for VASPs

  • VARA has issued a circular to all licensed Virtual Asset Service Providers outlining mandatory requirements for conducting AML, CFT Business Risk Assessments. The guidance follows deficiencies observed during 2024 to 2025 inspections and mandates a data driven, board approved and quarterly reviewed risk assessment framework. The circular requires VASPs to identify money laundering, terrorist financing and proliferation financing risks across their business model, client base, products, distribution channels, jurisdictions and technology use. It reinforces the obligation to integrate findings from the UAE National and Sectoral Risk Assessments and to apply a transparent and well documented methodology. The first quarterly reassessment must be completed by 30 November 2025, with non compliance potentially triggering thematic supervisory reviews in 2026.

Source: VARA

• VARA Issues Notice on UAE Federal AML/CFT/CPF Decree Law Requiring Mandatory Gap Assessments for VASPs

  • VARA has published a regulatory notice confirming the issuance of the UAE Federal Decree Law on AML, CFT and CPF (2025). The Decree Law requires all Virtual Asset Service Providers regulated by VARA to conduct a mandatory gap assessment against the new legislative requirements. The notice signals heightened supervisory expectations for VASPs to formally assess existing AML, CFT and CPF frameworks, identify deficiencies and implement remediation measures. Firms are expected to update policies, procedures and controls to ensure full alignment with the new federal regime.

Source: VARA

• VARA Issues Updated Guidance on Targeted Financial Sanctions Compliance

  • VARA, via the Executive Office for Control and Non Proliferation, has issued updated guidance reinforcing compliance obligations relating to targeted financial sanctions. The guidance sets out enhanced expectations for sanctions screening, due diligence measures and ongoing monitoring across virtual asset activities. The update underscores the need for robust sanctions frameworks aligned with federal requirements and reflects increased supervisory focus on proliferation financing and sanctions risk within the virtual asset sector.

Source: VARA

• VARA Issues Guidance on Rule III D Risk Assessment Requirements

  • VARA has issued guidance under Rule III D of the Compliance and Risk Management Rulebook, requiring all VARA licensed Virtual Asset Service Providers to update and formalise their risk assessment frameworks. The guidance reinforces expectations around documented methodologies, board oversight and alignment with AML, CFT and CTF requirements. The update reflects VARA’s continued supervisory focus on risk based governance and requires firms to ensure that risk assessments remain current, proportionate and responsive to changes in business models, products and regulatory obligations.

Source: VARA

Kuwait

Capital Market Authority (CMA)

• CMA Kuwait Issues Amendments to Market Infrastructure Regulations

  • CMA Kuwait has issued Resolution No. 193 of 2025 introducing amendments to provisions governing market infrastructure. The changes form part of ongoing efforts to support the development and resilience of Kuwait’s capital markets and affect regulatory requirements applicable to exchanges, clearing houses, market operators and brokers. Market participants are expected to review the amended rules and assess implications for compliance, risk management and clearing arrangements to ensure continued alignment with the updated regulatory framework.

Source: CMA

Kingdom Of Saudi Arabia

Capital Market Authority (CMA)

• CMA Introduces Governance and Procedural Reforms for Special Purpose Entities

  • The CMA has approved regulatory amendments to strengthen governance and streamline operational procedures for Special Purpose Entities. The reforms introduce enhanced requirements for securitisation activities, exempt debt offerings, board independence, trustee duties and dissolution processes. Licensed SPEs are required to update their by laws within 180 days. The announcement also highlights rapid market expansion, with 1,239 SPEs established by mid 2025, representing year on year growth of approximately 87 percent.

Source: CMA

Saudi Central Bank (SAMA)

• SAMA Approves the Use of Visitor ID for Opening Bank Accounts

  • SAMA has approved the use of the Ministry of Interior’s Visitor ID as an accepted form of identification for opening bank accounts in Saudi Arabia. This decision broadens access to financial services for short term residents and visitors, supports financial inclusion initiatives and aligns with the Kingdom’s digital transformation agenda. The update enables financial institutions to onboard non resident individuals using a verified national level digital identity, subject to standard due diligence and AML requirements.

Source: SAMA

Asia-Pacific Regulatory Develpments

Australia

Australian Securities and Investments Commission (ASIC)

• ASIC Issues Reporting and Audit Update – Issue 2

  • ASIC has released Issue 2 of its Reporting and Audit Update, covering developments in financial and sustainability reporting, auditor independence, enforcement findings and updates to regulatory guides. The publication includes the reissued Regulatory Guide 34, which consolidates and simplifies existing guidance on auditor breach notification and contravention reporting obligations and replaces the version issued in March 2020. The updated guidance clarifies auditor obligations to report suspected contraventions related to sustainability reporting, audits of superannuation entities, corporate collective investment vehicles and compliance plans for retail CCIVs. It also addresses reporting obligations involving attempts to influence or mislead auditors, conflict of interest scenarios linked to independence rules and auditors’ own suspected contraventions. ASIC also sets out expectations for lodging notifications, the operation of qualified privilege and consequences for non compliance.

Source: ASIC

• ASIC Issues New Regulatory Guide for Exchange Traded Product Issuers

  • ASIC has issued Regulatory Guide 282, Exchange Traded Products, consolidating and clarifying expectations for issuers of exchange traded products, including exchange traded funds. The guide outlines issuer obligations under the Corporations Act and associated regulatory regimes, covering disclosure, governance, product design, liquidity management and ongoing compliance responsibilities. RG 282 is effective immediately and forms part of ASIC’s broader work to strengthen oversight across Australia’s investment product ecosystem.

Source: ASIC

South Korea

Financial Services Commission (FSC)

• FSC Strengthens Oversight of Payment Gateway Providers to Protect Users’ Unsettled Funds

  • The FSC has approved legislative amendments to the Act on Electronic Financial Transactions, introducing enhanced safeguards for users’ unsettled funds held by payment gateway providers. The revised rules require payment gateway firms to maintain 100 percent of unsettled funds in external accounts, such as deposits, trusts or guarantee insurance, ensuring full protection in the event of operational or financial issues. The amendments also increase supervisory and enforcement powers. Misuse of unsettled funds can lead to penalties of up to ten years’ imprisonment or fines of up to KRW 100 million. Additional measures include administrative fines, potential business suspension for non compliance with external fund management requirements and prohibitions on using unsettled funds as collateral or for transfers or set offs by third parties.

Source: FSC

United Kingdom Regulatory Developments

Financial Conduct Authority (FCA)

• FCA Consults on Reforms to the UK EMIR Intragroup Exemption Regime

  • The FCA has issued Consultation Paper CP25/30 outlining proposed revisions to the UK EMIR intragroup exemption framework. The current regime is governed by the Temporary Intragroup Exemption Regime, known as TIGER, which is scheduled to expire on 31 December 2026. The consultation examines options for establishing a streamlined, permanent exemption process and seeks feedback on the proposed reforms. The paper highlights potential changes to eligibility criteria, notification and application procedures and documentation requirements for intragroup counterparties, particularly those involved in OTC derivatives. The proposals may also affect how firms apply margin and clearing exemptions across non-UK group entities, given the potential removal of certain jurisdictional equivalence conditions.

Source: FCA

• FCA Recognises Revised FX Global Code and UK Money Markets Code

  • The FCA has reapproved the 2024 editions of the FX Global Code and the UK Money Markets Code under its Code Recognition Scheme. Both codes set out standards of good practice for participants in wholesale foreign exchange and UK money markets and are reviewed periodically to reflect evolving market practices. Although adherence is voluntary, the FCA considers the codes important benchmarks for expected conduct standards in unregulated markets. Firms and individuals active in wholesale FX and money market activities are encouraged to align internal policies, controls and behaviours with the updated codes to demonstrate sound market conduct.

Source: FCA

United States of America

Office of the Comptroller of the Currency (OCC)

• OCC Confirms Bank Authority to Hold Certain Crypto Assets as Principal for Network Fee Payments

  • The OCC has issued Interpretive Letter 1186 confirming that national banks may pay blockchain network fees to facilitate otherwise permissible activities and may hold the necessary crypto assets on balance sheet as principal where there is a reasonably foreseeable need. The letter also confirms that banks may hold limited amounts of crypto assets as principal for the purpose of testing otherwise permissible crypto asset platforms, whether developed internally or provided by third parties. The OCC emphasises that these activities must be conducted in a safe and sound manner and in compliance with applicable law and regulatory requirements.

Source: OCC

• OCC Discontinues Annual Money Laundering Risk System Data Collection for Community Banks

  • The OCC has confirmed it will no longer annually collect information from community banks through the Money Laundering Risk System, with immediate effect. The change reduces supervisory reporting requirements under the BSA and AML framework. Community banks are still expected to maintain robust BSA and AML risk assessment processes, with examinations continuing to draw on alternative information sources.

Source: OCC

• Agencies Finalise Amendments to Regulatory Capital Standards

  • The OCC, alongside other US banking agencies, has issued a final rule amending certain regulatory capital standards to reduce disincentives for lower risk activities, including Treasury market intermediation. The changes adjust aspects of leverage and capital requirements applicable to large and systemically important banking organisations and their relevant subsidiaries.

Source: OCC

• OCC Publishes Final Rule Modifying Enhanced Supplementary Leverage Ratio Standards

  • The OCC has issued a bulletin summarising a final rule that modifies the enhanced supplementary leverage ratio standards applicable to covered US global systemically important bank holding companies and their subsidiary depository institutions. The rule confirms the effective date and provides an option for early adoption.

Source: OCC

Financial Industry Regulatory Authority (FINRA)

• FINRA Highlights SEC Amendments on Electronic Filing and FOCUS Report Changes

  • FINRA has issued guidance highlighting SEC amendments that modernise filing and recordkeeping requirements for broker dealers. The amendments require electronic submission of annual reports to the SEC, eliminate paper filings, introduce changes affecting FOCUS reporting, permit electronic signatures and update record retention obligations, including removing notarisation for the Oath or Affirmation while imposing specific retention requirements.

Source: FINRA

For further insights and tailored regulatory guidance, reach out to j. awan & partners.

Email: info@jawanpartners.com