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Every regulatory change, banking update, and market development across 16 jurisdictions. Date-stamped, source-verified, and updated daily.

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🌎 All 16 Jurisdictions ๐Ÿ‡ธ๐Ÿ‡ฌ Singapore 2 changes today ๐Ÿ‡ฐ๐Ÿ‡พ Cayman Islands 3 changes today ๐Ÿ‡จ๐Ÿ‡ญ Switzerland 2 changes today ๐Ÿ‡ฆ๐Ÿ‡ช UAE 2 changes today ๐Ÿ‡ง๐Ÿ‡ฟ Belize Monitoring ๐Ÿ‡ญ๐Ÿ‡ฐ Hong Kong 3 changes today ๐Ÿ‡ต๐Ÿ‡ฆ Panama 2 changes today ๐Ÿ‡ป๐Ÿ‡ฌ British Virgin Islands 2 changes today ๐Ÿ‡ฐ๐Ÿ‡ณ Nevis 2 changes today ๐Ÿ‡จ๐Ÿ‡ฐ Cook Islands Monitoring ๐Ÿ‡ต๐Ÿ‡ท Puerto Rico 2 changes today ๐Ÿ‡ฒ๐Ÿ‡บ Mauritius 2 changes today ๐Ÿ‡ฌ๐Ÿ‡ฎ Gibraltar 2 changes today ๐Ÿ‡ฎ๐Ÿ‡ฒ Isle of Man 2 changes today ๐Ÿ‡ฏ๐Ÿ‡ช Jersey 2 changes today ๐Ÿ‡ง๐Ÿ‡ธ Bahamas 2 changes today

๐Ÿ‡ฌ๐Ÿ‡ฎ Gibraltar Intelligence

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⚖️ Regulatory Medium Confidence

Gibraltar's AML/CFT supervisory unit confirmed that enhanced due diligence thresholds for virtual asset service providers have been aligned with the latest FATF Recommendation 15 updates, following a post-mutual evaluation action plan review completed in August 2026. Affected DLT licence holders are expected to update their risk appetite statements and transaction monitoring rules by Q4 2026. The GFSC indicated informal guidance letters will be dispatched to impacted firms this week.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying expectations for DLT providers operating under the 10th Principle framework, specifically addressing adequate financial crime controls in tokenised asset custody arrangements. Firms are reminded that the 10th Principle requires demonstrable customer protection mechanisms proportionate to the risk profile of digital asset services offered. Compliance submissions for Q3 2026 self-assessments are due by 30 September 2026.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying expectations under its DLT Provider framework, specifically addressing custody arrangements for tokenised assets held by licensed DLT firms. The guidance reinforces that DLT businesses must maintain segregated client asset records consistent with the 10th Principle of the DLT regulatory framework, with GFSC examiners indicating enhanced focus on this area during upcoming scheduled inspections. Firms are expected to confirm compliance posture in writing to the GFSC by 31 October 2026.

⚖️ Regulatory Medium Confidence

Gibraltar's AML/CFT supervisory unit has circulated an internal industry notice reminding regulated entities of updated beneficial ownership verification thresholds following alignment with the EU's revised Anti-Money Laundering Regulation, which continues to influence Gibraltar's post-Brexit regulatory convergence strategy. The notice specifically flags higher-risk correspondent banking relationships and virtual asset service providers as priority review categories for Q4 2026 supervisory examinations. Institutions are advised to review and update their risk appetite statements accordingly before year-end.

⚖️ Regulatory High Confidence

The GFSC has issued updated guidance clarifying enforcement expectations under the 10th Principle of its DLT Provider framework, specifically addressing obligations around adequate resourcing and cyber resilience for licensed DLT firms. The guidance follows a series of supervisory visits conducted through Q3 2026 and signals heightened scrutiny of operational risk controls. Firms are expected to demonstrate compliance with the updated expectations by Q1 2027.

⚖️ Regulatory Medium Confidence

The GFSC has circulated an internal supervisory bulletin reminding regulated entities of enhanced customer due diligence obligations in line with evolving FATF Recommendation 15 guidance on virtual assets and DLT-based financial services. The bulletin emphasises that AML/CFT risk assessments must explicitly address exposure to decentralised finance protocols and cross-border crypto asset flows. Gibraltar-licensed banks and DLT providers are advised to review and update their AML frameworks ahead of scheduled supervisory reviews in Q4 2026.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated guidance notes clarifying enforcement expectations under the 10th Principle of its DLT Provider Regulations, specifically addressing custodial arrangements and client asset segregation for firms holding distributed ledger-based assets. The clarification follows a series of supervisory reviews conducted during Q2-Q3 2026 and is effective immediately for all licensed DLT providers operating under the Financial Services (Distributed Ledger Technology Providers) Regulations 2020. Firms have been advised to review internal compliance frameworks and submit updated attestations to the GFSC by 30 November 2026.

⚖️ Regulatory Medium Confidence

The GFSC published a revised AML/CFT supervisory bulletin reinforcing enhanced due diligence requirements for correspondent banking relationships and virtual asset service providers, aligning Gibraltar's framework more closely with revised FATF Recommendation 16 travel rule technical standards adopted in early 2026. Gibraltar-licensed banks and payment firms are expected to demonstrate full travel rule compliance tooling by Q1 2027. The bulletin also highlights increased scrutiny of beneficial ownership verification for non-resident corporate account holders.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission issued updated supervisory guidance clarifying expectations for DLT providers operating under the 10th Principle framework, specifically addressing algorithmic transparency and client asset segregation requirements. Firms holding existing DLT Provider licences are expected to submit compliance attestations confirming alignment with the revised guidance by 30 September 2026. This follows a pattern of incremental enforcement refinements the GFSC has pursued throughout 2026 as the DLT ecosystem in Gibraltar has matured.

⚖️ Regulatory Medium Confidence

Gibraltar's competent authorities published a reminder bulletin reinforcing enhanced due diligence obligations for correspondent banking relationships in light of updated FATF guidance on virtual asset service providers intersecting with traditional banking channels. The bulletin urges licensed banks and DLT firms operating hybrid models to review their transaction monitoring calibration before the Q3 2026 supervisory review cycle concludes at end of September. No new legislative changes were enacted, but the bulletin signals heightened supervisory scrutiny in the near term.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying expectations for DLT Providers operating under the 2018 DLT regulatory framework, with particular emphasis on custody arrangements and segregation of client assets. The guidance follows a thematic review conducted across licensed DLT firms during Q2-Q3 2026 and takes effect immediately. Firms have been directed to submit confirmatory compliance attestations to the GFSC by 31 October 2026.

⚖️ Regulatory Medium Confidence

The GFSC has published a supplementary AML/CFT bulletin reinforcing enforcement of the 10th Principle โ€” requiring DLT businesses to maintain honest and fair conduct โ€” in the context of cross-border virtual asset transfers subject to the FATF Travel Rule. The bulletin highlights deficiencies identified in recent on-site inspections, specifically around counterparty due diligence for unhosted wallet transactions. Firms are advised to review and update their risk-based policies ahead of anticipated Q4 2026 follow-up inspections.

⚖️ Regulatory Medium Confidence

Gibraltar's GFSC released a supplementary AML/CFT supervisory bulletin on 11 September 2026 addressing enhanced due diligence requirements for politically exposed persons transacting through virtual asset service providers registered in the jurisdiction. The bulletin reflects recommendations arising from Gibraltar's most recent MONEYVAL follow-up assessment and instructs VASPs to implement updated PEP screening protocols no later than 1 December 2026. Non-compliant entities risk licence suspension under the Proceeds of Crime Act 2015 as amended.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated guidance clarifying expanded reporting obligations under the 10th Principle of its DLT Provider framework, specifically addressing algorithmic staking products and tokenised asset custody arrangements. Firms operating under DLT Provider licences are required to demonstrate alignment with the revised Consumer Outcomes principle by 31 October 2026. The GFSC has indicated that supervisory visits scheduled for Q4 2026 will prioritise assessment of these updated disclosures.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying expectations under the DLT Provider framework, specifically addressing custodial arrangements for tokenised assets held by licensed DLT firms. The guidance reinforces that firms must maintain segregated client asset records auditable in real time and submit quarterly attestations beginning Q4 2026. This follows a thematic review conducted across several licensed DLT providers earlier in Q3 2026.

⚖️ Regulatory Medium Confidence

The GFSC has signalled an upcoming consultation paper on enhanced Customer Due Diligence obligations aligned with FATF Recommendation 16 updates, targeting virtual asset service providers and correspondent banking relationships operating through Gibraltar. The paper is expected to be published before end of October 2026 and will address travel rule implementation gaps identified during 2026 examinations. Firms are advised to begin preliminary gap analyses ahead of the formal consultation window.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying expectations for DLT providers operating under the 2018 DLT Regulatory Framework, with particular emphasis on enhanced cybersecurity resilience requirements and incident reporting timelines. Firms holding DLT Provider licences are expected to align internal policies with the new guidance by Q4 2026. The GFSC confirmed this forms part of its ongoing post-Brexit regulatory alignment programme to maintain equivalence with evolving EU MiCA standards.

⚖️ Regulatory Medium Confidence

The GFSC's Enforcement Division signalled a renewed focus on the application of the 10th Principle โ€” requiring DLT businesses to have adequate resources, conduct affairs in an orderly manner, and maintain appropriate systems of control โ€” following two informal guidance requests received from licensees in August 2026. Supervisors have indicated that upcoming thematic reviews scheduled for October 2026 will assess compliance with Principle 10 alongside updated AML/CFT transaction monitoring obligations. Firms are advised to review their risk appetite statements and customer due diligence frameworks ahead of the review cycle.

⚖️ Regulatory Medium Confidence

Gibraltar's AML/CFT Unit published a sector-specific risk advisory for virtual asset service providers and DLT firms, highlighting elevated typologies related to cross-chain bridge transactions and privacy-enhancing technologies identified in recent supervisory assessments. The advisory aligns with FATF's updated guidance on virtual assets issued in mid-2026 and calls on obliged entities to refresh their business-wide risk assessments before year-end. Firms failing to document updated risk assessments may face enhanced scrutiny during forthcoming GFSC thematic reviews.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated guidance notes clarifying the application of the 10th principle under the DLT Provider Regulations, specifically addressing custody arrangements for tokenised assets and the segregation of client funds held in digital form. Firms operating under DLT provider licences are expected to demonstrate compliance with the revised custody standards by Q4 2026. The GFSC has indicated that supervisory review visits scheduled for October and November 2026 will specifically assess firms against these updated expectations.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission published updated guidance clarifying enforcement expectations under the 10th Principle of its DLT Provider framework, specifically addressing obligations around adequate disclosure of conflicts of interest by token issuers and DLT businesses. The guidance reinforces that licensees must maintain documented board-level oversight of conflict management policies reviewed at minimum on a semi-annual basis. Firms have been given until 31 October 2026 to demonstrate full alignment or face supervisory review.

⚖️ Regulatory Medium Confidence

The GFSC issued an internal advisory to regulated firms referencing FATF's September 2026 plenary outcomes, directing Gibraltar-licensed institutions to review customer risk appetite statements in light of updated red flag indicators for virtual asset service providers operating cross-border. While no formal rule change has been enacted, firms are expected to update their AML/CFT policies to reflect the new typologies ahead of the Q4 supervisory cycle. This is consistent with Gibraltar's proactive approach to aligning domestic AML frameworks with evolving FATF standards.

⚖️ Regulatory Medium Confidence

The GFSC has circulated a supplementary AML/CFT advisory note encouraging all regulated entities, including banks and DLT providers, to review customer due diligence procedures in light of the EU's updated Transfer of Funds Regulation now being mirrored in Gibraltar's domestic rulebook post-Brexit alignment. The advisory specifically flags transaction monitoring thresholds for crypto-asset transfers and urges firms to update their internal policies before Q4 2026 audits commence. This forms part of Gibraltar's broader effort to maintain its FATF-compliant status and preserve correspondent banking relationships.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance reinforcing the application of the 10th Principle under the DLT Provider Regulations, placing heightened obligations on licensed DLT firms to demonstrate ongoing financial crime risk assessments aligned with FATF Recommendation 15. Firms have been reminded that annual attestations of compliance must be submitted no later than 30 September 2026. Non-compliant firms risk suspension of their DLT licence pending a formal supervisory review.

⚖️ Regulatory Medium Confidence

The GFSC has circulated a supervisory bulletin reiterating updated AML/CFT transaction monitoring thresholds effective as of 1 September 2026, aligned with revisions to Gibraltar's Proceeds of Crime Act 2015 secondary legislation. Regulated entities including banks and DLT providers are now required to apply enhanced due diligence on cross-border transactions exceeding revised risk-tiered thresholds, with particular focus on counterparties in jurisdictions flagged in FATF's June 2026 grey list update. Non-compliance during the current supervisory cycle may result in formal enforcement action.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated guidance clarifying enforcement expectations under the 10th Principle of its DLT Provider Regulations, specifically addressing obligations around market integrity and the prevention of financial crime in token issuance activities. Firms holding DLT Provider licences are reminded that compliance reviews scheduled for Q4 2026 will include enhanced scrutiny of how the 10th Principle is operationalised within internal governance frameworks. Firms are advised to conduct internal gap analyses before the October 2026 review window opens.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has published updated guidance notes clarifying enforcement expectations under the 10th Principle of its DLT Provider Regulations, reinforcing that licensed firms must maintain adequate financial crime controls specifically tailored to blockchain-based transaction monitoring. The guidance follows a supervisory review cycle initiated in Q2 2026 and takes effect immediately for all current DLT licence holders. Firms have been advised to conduct gap analyses against the updated expectations within 60 days.

⚖️ Regulatory Medium Confidence

The GFSC issued a supplementary AML/CFT circular directing Gibraltar-licensed deposit-taking institutions and payment firms to align their customer risk assessment frameworks with revised FATF guidance on virtual asset exposure by 31 October 2026. The circular specifically flags correspondent banking relationships involving jurisdictions with elevated crypto-asset activity as requiring enhanced due diligence. This follows Gibraltar's ongoing effort to maintain its MONEYVAL-compliant status ahead of the next scheduled mutual evaluation cycle.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying enforcement expectations under the 10th Principle of the DLT Provider Regulations, specifically addressing the obligation for DLT firms to maintain adequate financial and non-financial resources as token market volatility has increased across Q3 2026. Firms are expected to demonstrate stress-tested capital adequacy buffers aligned with current market conditions by the next scheduled supervisory review cycle. Non-compliant entities risk licence conditions being varied or suspended without further notice.

⚖️ Regulatory Medium Confidence

The GFSC has circulated a revised AML/CFT sector-specific risk assessment addendum applicable to both traditional offshore banking licensees and DLT providers operating under Gibraltar's framework, reflecting updated FATF typologies published in late August 2026. The addendum places heightened scrutiny on virtual asset-to-fiat conversion corridors and correspondent banking relationships involving jurisdictions newly flagged on FATF's grey list. Regulated entities are expected to integrate the updated risk factors into their enterprise-wide risk assessments within 60 days of the bulletin date.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying enforcement expectations under the 10th Principle of its DLT regulatory framework, specifically addressing governance obligations for DLT providers handling client assets above threshold limits. Firms are reminded that enhanced due diligence documentation must be retained for a minimum of seven years and made available to the GFSC within 48 hours upon request. This reinforces ongoing supervisory pressure following a series of thematic reviews conducted in Q2 2026.

⚖️ Regulatory Medium Confidence

Gibraltar's GFSC has circulated a sector-wide AML/CFT advisory referencing FATF's Q3 2026 typologies update, directing licensed banks and DLT providers to reassess their transaction monitoring parameters for virtual asset-related flows. The advisory specifically highlights risks associated with cross-border layering through non-custodial wallet intermediaries. Firms are expected to document their risk reassessment outcomes and update their AML policies by 30 September 2026.

⚖️ Regulatory Medium Confidence

Gibraltar's AML/CFT supervisory framework has been updated to reflect revised FATF guidance on virtual asset service providers issued following the July 2026 FATF Plenary, with the GFSC circulating updated guidance to regulated firms effective 1 September 2026. The updated guidance places additional emphasis on travel rule compliance for cross-border crypto asset transfers and requires enhanced customer due diligence for politically exposed persons transacting through DLT-based products. Regulated entities are expected to conduct a gap analysis against the new guidance and report material deficiencies to the GFSC within 60 days.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has confirmed that its enhanced supervisory expectations for DLT providers under the DLT Provider Regulations 2018 entered a new review cycle as of 1 September 2026, with firms required to submit updated technology risk assessments to the GFSC by 30 September 2026. This follows the GFSC's Q2 2026 thematic review which identified gaps in incident reporting and key personnel notifications among a subset of registered DLT providers. Firms failing to demonstrate adequate controls risk suspension of their DLT provider authorisation under Principle 10 of the ten core principles framework.

⚖️ Regulatory High Confidence

The GFSC issued a supervisory circular reminder ahead of the Q3 2026 close, reaffirming that all DLT Provider licence holders must demonstrate ongoing compliance with the 10th Principle โ€” the requirement to protect and properly advance the interests of customers and the wider Gibraltar community. Firms that received conditional authorisation in H1 2026 have been reminded that enhanced monitoring obligations remain in force through the end of the calendar year. The circular signals continued active enforcement posture rather than any relaxation of standards entering Q4.

⚖️ Regulatory Medium Confidence

Gibraltar's AML/CFT coordination unit published an updated internal guidance note aligning local virtual asset supervision procedures with the most recent FATF guidance on travel rule implementation for DLT-based service providers, effective from today. Obliged entities with cross-border crypto settlement functions are expected to review counterparty data-sharing arrangements by 30 September 2026 or face enhanced supervisory scrutiny. This follows MONEYVAL's ongoing assessment cycle in which Gibraltar has sought to maintain its strong mutual evaluation standing.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance under its DLT Provider framework, clarifying enhanced due diligence requirements for DLT businesses handling stablecoin-related settlement operations. The guidance reinforces the 10th Principle obligations around consumer protection and financial crime prevention for licensed DLT entities. Firms have been given a 60-day compliance window to align internal policies with the revised supervisory expectations.

⚖️ Regulatory Medium Confidence

The GFSC published a supplementary AML/CFT circular addressing correspondent banking relationships, requiring Gibraltar-licensed banks and payment institutions to conduct enhanced periodic reviews of high-risk jurisdictional counterparties by Q4 2026. The circular aligns Gibraltar's supervisory posture with FATF's updated Recommendation 13 guidance issued earlier in 2026. This follows ongoing MONEYVAL follow-up scrutiny and signals a proactive regulatory stance ahead of the next mutual evaluation cycle.

⚖️ Regulatory Medium Confidence

Gibraltar's AML/CFT supervisory framework received an incremental update aligning local guidance with FATF's June 2026 revised Recommendation 15 standards on virtual assets, bringing DLT provider risk assessment templates into closer conformity with international expectations. The GFSC confirmed that updated risk-based supervision templates will be circulated to regulated firms by 15 September 2026. No immediate licence conditions are changing, but firms are advised to begin internal gap analyses ahead of the September deadline.

⚖️ Regulatory High Confidence

The GFSC issued updated guidance notes clarifying enforcement expectations under the 10th Principle of the DLT Provider Regulations, specifically addressing custody arrangements and client asset segregation for DLT businesses operating under Category 2 and Category 3 licences. Firms have been reminded that evidence of adequate custody controls must be submitted with upcoming annual compliance attestations due in Q4 2026. This follows a targeted review the GFSC conducted across several licensees during Q2 2026.

⚖️ Regulatory Medium Confidence

The GFSC has circulated an internal AML/CFT advisory to licensed firms highlighting elevated risk typologies associated with virtual asset service providers operating across EU and UK corridors post-Brexit, referencing updated FATF guidance published in July 2026. Gibraltar-regulated banks and DLT businesses are reminded to refresh their risk assessments and ensure Travel Rule compliance tooling is operational ahead of a planned GFSC thematic review scheduled for Q4 2026. Non-compliant firms identified during the review may face supervisory intervention under the Proceeds of Crime Act 2015 (Gibraltar).

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated supervisory guidance clarifying expectations under its DLT Provider framework, specifically addressing custody obligations and segregation of client assets for firms holding DLT licences. The guidance reinforces the 10th principle requirement that DLT businesses must be able to demonstrate that token holder assets are protected in the event of firm insolvency. Firms have been directed to review internal governance arrangements and submit compliance attestations to the GFSC by 30 September 2026.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission issued updated supervisory guidance on its Distributed Ledger Technology framework, clarifying token classification thresholds and expanded reporting obligations for DLT providers holding client assets above ยฃ500,000. The guidance reinforces the GFSC's 10th principle requirements, specifically around ongoing risk disclosure and adequate financial crime controls for crypto-asset businesses. Firms have been given until 30 September 2026 to attest compliance with the revised standards.

⚖️ Regulatory Medium Confidence

The GFSC published a follow-up AML/CFT circular reinforcing enhanced due diligence requirements for politically exposed persons and correspondent banking relationships, aligned with Moneyval's latest mutual evaluation follow-up recommendations for Gibraltar. Regulated firms are expected to update internal EDD procedures and submit revised risk appetite statements to their supervisory contact by Q4 2026. The circular signals increased enforcement scrutiny heading into Gibraltar's next Moneyval progress review cycle.

⚖️ Regulatory Medium Confidence

The GFSC published a supervisory communication referencing FATF's latest typologies report on virtual asset service providers, directing Gibraltar-licensed firms to review their transaction monitoring calibration in light of newly identified layering patterns involving cross-chain bridge transactions. The communication stops short of imposing new rules but signals that upcoming thematic reviews scheduled for Q4 2026 will scrutinise VASP screening controls with heightened intensity. Firms with high volumes of DeFi-adjacent activity are considered higher priority for inspection.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued an updated guidance note clarifying enforcement expectations under the 10th Principle of its DLT Provider Regulations, specifically addressing token issuers who offer staking and yield-generating products. Firms are reminded that any product featuring guaranteed or indicative returns must be classified under the appropriate investment business category and licensed accordingly. Existing DLT licensees have been advised to conduct a product review by 30 September 2026 to ensure ongoing compliance.

⚖️ Regulatory Medium Confidence

The GFSC circulated an internal industry advisory reminding Gibraltar-licensed institutions of enhanced due diligence obligations for correspondent banking relationships involving jurisdictions flagged in FATF's June 2026 grey-list revision. While no new primary legislation was enacted today, the advisory signals heightened supervisory scrutiny ahead of Gibraltar's scheduled MONEYVAL mutual evaluation preparation cycle beginning Q4 2026. Firms are encouraged to review and update their risk appetite statements and EDD procedures before the October 2026 deadline.

⚖️ Regulatory High Confidence

The Gibraltar Financial Services Commission has issued updated guidance clarifying enforcement expectations under the 10th Principle of its DLT Provider Regulations, specifically addressing custody arrangements and client asset segregation for firms holding DLT tokens on behalf of retail clients. The guidance takes effect immediately and requires affected licensees to submit a compliance attestation to the GFSC within 60 days. This follows a series of supervisory visits conducted during Q2 2026 that identified inconsistencies in how firms were interpreting custody obligations.