
Life Sciences Law Update
Key developments of interest over the last month include: the UK government's communications in connection with the Chancellor's annual Mansion House speech, and the launch of its Financial Services Growth and Competitiveness Strategy, signaling the government's intention to position the UK as a leader in financial services innovation; President Trump signing the GENIUS Act into law, establishing the first federal stablecoin framework in the United States; and the Hong Kong government consulting on new licensing regimes for digital asset dealing and custody services.
In this Newsletter:
For previous editions of the Payments Newsletters, please visit our Financial Services practice page.
The UK government’s latest communications on 15 July 2025 in connection with the Chancellor’s annual Mansion House speech, and the launch of its Financial Services Growth and Competitiveness Strategy (the FS Strategy) (following publication of its Modern Industrial Strategy on 23 June 2025), signal the government’s intention to position the UK as a leader in financial services innovation.
Some key points from a payments and digital assets perspective include:
Also in accordance with the NPV, a “Payments Forward Plan” is expected from the PVDC by the end of this year which will set out a sequenced plan of initiatives, including in retail and wholesale payments, and the role of digital assets.
HM Treasury also published an update on the UK’s Digital Gilt Instrument (DIGIT), announcing a further set of features that it proposes to test as part of the pilot:
For more on the payments and digital assets aspects of the Mansion House 2025 publications, take a look at our articles here (a detailed summary of key initiatives outlined in the various publications, including in relation to payments and digital assets) and here (focusing on digital assets and tokenisation). For further resources, visit our Hogan Lovells Digital Assets and Blockchain Hub.
On 26 June 2025, the FCA published the findings of its multi-firm review into risk management and wind-down planning at firms authorised under the Electronic Money Regulations 2011 and the Payment Services Regulations 2017.
The FCA assessed 14 firms with a variety of business models and found that none fully met existing expectations under its related guidance FG20/1. Risk frameworks were often not aligned with firms’ activities or scale, and many failed to define risk appetite or carry out sufficient stress testing. The FCA noted that liquidity risk management was underdeveloped, with an overreliance on cash buffers and limited contingency planning. Firms also lacked adequate consideration of group risk, including dependencies on intra-group services and unclear governance in times of stress.
Wind-down plans were generally high-level, lacked detailed financial modelling and were not integrated with firms’ broader risk frameworks. The FCA expects firms to set credible wind-down triggers, assess operational dependencies, and plan realistically for safeguarding obligations and customer communications during an exit.
The findings do not create new obligations but serve as sector-specific examples of how existing expectations should be applied. Firms are encouraged to review their arrangements and address any gaps to support resilience, sustainable growth and orderly market exit if required.
See this Our Thinking article for more detail.
On 15 July 2025, the FCA and the PRA published the letters they have sent to Rachel Reeves, Chancellor of the Exchequer, setting out their newly agreed stretch targets for processing certain regulatory applications ahead of the statutory deadlines. The letters complement the government's consultation on proposals to shorten the statutory deadlines for determining applications for new firm authorisations, variations of permission and senior manager applications, which was also published on 15 July 2025.
The FCA’s letter states that for senior manager regime applications, it will target completing at least 50% of cases within 35 days and, for variations of permission, it will target completing cases within three months for complete applications and six months for incomplete applications for adjacent business models. It will also adjust its reporting for payments and e-money firms to align with the relevant statutory targets for firms authorised under the Financial Services and Markets Act 2000 (FSMA). This means that authorisations and registrations would, therefore, target deadlines of 3 months for complete applications and 10 months for incomplete applications, for both new firm and variation applications.
In its letter, among other things the PRA states that, for senior manager regime applications, it will target completing at least 50% of cases within 45 days.
Both the PRA and the FCA commit to enhancing their quarterly reporting from the start of 2026 to start showing performance against these targets and against the shorter targets being proposed in legislation, ahead of these coming into force. They anticipate that, when they start reporting, some new targets may not be met immediately, as it will take them time to make the necessary changes.
On 26 June 2025, the Payment Systems Regulator (PSR) published consultation paper CP25/2 proposing to revoke Specific Direction 4 and its amendment, Specific Direction 4a. These directions currently require the operator of the LINK payment system to run a competitive procurement process for its central infrastructure services every ten years.
The requirement was introduced following the PSR’s 2016 Infrastructure Market Review to address concerns about competition and ensure better outcomes for service users. However, the PSR now considers that the mandatory tender obligation may no longer be effective in the current market, particularly given the decline in cash usage and reduced LINK transaction volumes.
Instead, the PSR proposes that enhanced regulatory oversight of LINK and its infrastructure provider could more appropriately manage risks associated with a concentrated supply arrangement. The consultation invites views on the potential effects of removing the tender requirement and on the proposed supervisory approach.
Responses to the consultation were due by 17 July 2025.
On 24 June 2025, the Bank of England, PRA, FCA and Payment Systems Regulator (PSR) published a revised version of their Memorandum of Understanding on the regulation of UK payment systems, together with a joint press release.
The updated MoU introduces five core principles for regulatory cooperation, covering policy development, supervision, authorisations and strategy. It aims to clarify each authority’s role in the payments ecosystem and improve coordination on matters of shared regulatory interest. The changes follow the authorities’ statutory annual review and reflect feedback from firms, trade associations and consumer groups.
Examples of the enhanced approach include joint horizon scanning, coordinated policy initiatives and collaborative supervisory work. The revisions are also intended to support the government’s planned consolidation of the PSR’s functions into the FCA, while maintaining the PSR’s current responsibilities in the interim.
To support transparency, the FCA has published a dedicated webpage outlining how the regulators’ remits fit together, along with a diagram illustrating areas of overlap and cooperation across key workstreams. The authorities have committed to reviewing the MoU each year to ensure that coordination continues to evolve.
On 18 June 2025, the Financial Action Task Force (FATF) published updates to Recommendation 16 and an accompanying explanatory note, aimed at improving the transparency and security of cross-border payments.
The revised rules will standardise the information that must accompany wire transfers, with financial institutions required to include consistent sender and recipient details for peer-to-peer transfers above USD/EUR 1,000. Required information includes full name, address and date of birth. The updated standards also clarify that responsibility for data accuracy begins with the institution that receives the customer’s payment instruction.
To help mitigate fraud and misdirected payments, the FATF is now requiring the use of tools such as payee verification systems. While card transactions for goods and services remain exempt, the FATF has narrowed the definition of such exemptions to close potential gaps.
The changes are designed to reflect evolving risks in the payments ecosystem and support global efforts to strengthen cross-border payment systems, including the G20 roadmap. The accompanying explanatory note confirms that countries will have until the end of 2030 to implement the changes. The FATF will issue further guidance to assist with consistent adoption, expected by late 2026, and will engage with industry through its Payment Advisory Group to monitor progress and address implementation challenges.
On 16 July 2025, the Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025 (the Order) was made. It comes into force on 31 July 2025.
The Order increases the threshold amount (value of criminal property below which a regulated firm can carry out a transaction in operating an account for a customer, without committing an offence under sections 327 to 329 of the Proceeds of Crime Act 2002 (POCA)) specified in section 339A(2) and (6A) of POCA from £1,000 to £3,000.
This is the second change to the threshold amount since the Proceeds of Crime (Money Laundering) (Threshold Amount) Order 2022 raised the amount from £250 to £1,000.
On 7 July 2025, the FCA published final guidance (FG25/3) (the Final Guidance) on the treatment of PEPs for anti-money laundering purposes, which updates its Guidance issued in 2017 (the 2017 Guidance). An amended version of the Final Guidance was subsequently published on 15 July 2025. A PEP is someone who is entrusted with prominent public functions either in the UK or elsewhere in the world.
Publication of the Final Guidance follows a multi-firm review undertaken by the FCA on how effectively firms were following its 2017 Guidance, and a consultation in July 2024 in which the FCA proposed some changes to the 2017 Guidance.
The Final Guidance assists firms with complying with their obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) which require them to undertake enhanced due diligence on PEPs, their families and close associates. This is to address the increased risk that PEPs, and those connected to them, may be targeted for bribery and corruption and the financial system used to launder the proceeds.
The MLRs 2017 and the Final Guidance clarify that a case-by-case approach is required with the risk assessment of individual PEPs. The Final Guidance sets out indicators which might suggest whether a PEP poses a higher or lower risk, and due diligence measures in each scenario. The FCA clarifies that firms should only take additional measures beyond those set out in the Final Guidance where this is justified on the basis of their risk assessment or the customer has risk factors unrelated to their position or connection to a PEP.
The FCA says that the Final Guidance should be read in conjunction with the findings from its multi-firm review published in July 2024 which provides examples of good and poor practice by firms (see this previous Our Thinking article).
On 20 June 2025, the EBA published a report confirming that the existing list of standardised terms for common payment account services remains fit for purpose and does not require amendment at this time.
The review, required under the EU Payment Accounts Directive, assessed developments in EU payments legislation and gathered input from national regulators and stakeholders. While the EBA considered adding a term for instant credit transfers, it concluded that the benefits would not outweigh the costs of updating disclosure documents across the industry.
The current regulatory technical standards will remain unchanged, but the EBA plans to revisit the issue in four years or earlier if significant market or legislative changes arise.
On 25 June 2025, the Council of the EU published a press release announcing that it has reached provisional political agreement with the European Parliament on the legislative proposals for amendments to the Bank Recovery and Resolution Directive (2014/59/EU) (BRRD), the Single Resolution Mechanism (SRM) Regulation (806/2014) and the Deposit Guarantee Schemes Directive (2014/49/EU) (DGSD). The Parliament has also published a press release on the agreement.
The Council and the Parliament highlight that agreement was reached on issues including: use of deposit guarantee scheme funds in resolutions; public interest assessment; and hierarchy of claims.
The provisional political agreement is subject to approval by the Council and the Parliament before going through the formal adoption procedure.
On 14 July 2025, Regulation (EU) 2025/1355 of the European Central Bank of 2 July 2025 on oversight requirements for systemically important payment systems (ECB/2025/22) (recast SIPS Regulation) was published in the Official Journal of the European Union (OJ). It amends and replaces the ECB Regulation on oversight requirements for systemically important payment systems (765/2014) (ECB/2014/28) (SIPS Regulation) and applies to payment systems operated both by central banks and by private operators.
Among other things, the recast SIPS Regulation includes:
The recast SIPS Regulation will come into force on 3 August 2025 (that is, 20 days after publication in the OJ).
On 18 July 2025, the Bank of England (BoE) published a policy statement setting out its Fundamental Rules for financial market infrastructures (FMIs). The BoE consulted on the rules in November 2024 (see this Our Thinking article).
The aim of the rules is to set out the outcomes that the BoE expects from FMIs, including in relation to their financial resources, operational resilience and the actions that they should take to understand and manage the risk they may pose to the stability of the financial system.
Key changes from the consultation proposals are:
The BoE's final policy is reflected in the Fundamental Rules Part of the BoE FMI Rulebook for Central Counterparties and for Central Securities Depositories Instrument 2025, the Bank of England Recognised Payment Systems Fundamental Rules Code of Practice and a Supervisory Statement on the Fundamental Rules for FMIs.
The Fundamental Rules will apply to UK recognised central counterparties (CCPs), UK recognised central securities depositories (CSDs), UK recognised payment system operators and specified service providers. Third-country CSDs and systemic overseas CCPs are not in scope, but this may change in the future.
Also on 18 July 2025, the BoE published a document setting out its supervisory approach to onboarding new FMIs that fall within its regulatory remit. The document complements the BoE's overall approach to supervising FMIs, which it updated in November 2024. It covers matters including:
The BoE may revise and reissue the document in response to significant legislative and other developments that result in changes to its approach.
On 18 July 2025, the Bank of England (BoE) published its response (dated 15 July 2025) to a letter from HM Treasury (HMT) setting out the government's remit, recommendations and priorities for the Financial Market Infrastructure (FMI) Committee.
The letter explains how the BoE, as regulator of FMIs, is supporting sustainable economic growth in the UK and facilitating innovation in support of that goal. In an annex to the letter, the BoE sets out in detail how its actions support the recommendations detailed in HMT's letter. Some points of interest include:
On 19 June 2025, the Data (Use and Access) Bill received Royal Assent to become the Data (Use and Access) Act 2025. It has subsequently been published. Among other things, the Act enables the transition of regulatory oversight for Open Banking to the FCA and the development of Open Finance.
Most of the provisions in the Act do not come into force immediately, with most provisions effective as and when the Secretary of State makes specific regulations.
On 16 June 2025, HM Treasury published a webpage on the wholesale cash oversight orders that it has issued for the purposes of the new Bank of England wholesale cash oversight regime. The orders were made on 5 June 2025 and came into force on 12 June 2025.
On 2 July 2025, the All-Party Parliamentary Group on Fair Banking (APPG) published a follow-up report on authorised push payment fraud, assessing the early impact of the mandatory reimbursement requirement introduced by the Payment Systems Regulator (PSR).
The report finds that reimbursements are increasing, but victims are recovering on average only 86 percent of their losses. It calls on the PSR to assess whether the £85,000 compensation cap is appropriate, clarify how the consumer standard of caution is being applied, and evaluate the scheme’s operational burden on smaller firms.
The APPG also recommends expanding protection to cover crypto and cross-border fraud, and proposes a levy on social media and telecoms firms to fund victim reimbursements. It stresses that a joined-up approach is needed and that banks cannot bear sole responsibility for tackling scams.
See the April 2025 edition of the Newsletter for information on the previous APPG report on APP fraud.
On 30 June 2025, the Council of the EU published working documents from its General Secretariat containing comparison tables for the proposed Payment Services Directive (PSD3) and Payment Services Regulation (PSR). These documents are intended to support upcoming trilogue negotiations.
The working documents include:
The tables highlight areas of alignment and difference across key topics such as third-party access, customer protection, authentication standards and operational resilience. They aim to provide a useful reference point for stakeholders tracking the progress of the legislative package.
Take a look at the June 2025 edition of the Newsletter for an overview of the Council’s recently published compromise proposals for PSD3 and the PSR. Watch this space for an updated edition of our previously published PSD3 Impacts Report, which will highlight key elements of the Council’s compromise proposals alongside those of the Parliament.
There have been a number of recent developments in relation to the government’s and the FCA’s work to bring Buy Now, Pay Later (BNPL) credit within the regulatory perimeter. In outline, these are as follows:
On 4 July 2025, the People’s Bank of China (PBOC) published its first-batch licence renewal bulletin for July on its official website, together with an accompanying Excel spreadsheet. The notice confirms that 13 non-bank payment institutions have been granted licences of long term validity.
Under the new supervisory framework introduced in 2024, long term validity replaces the previous five-year renewal cycle for payment business licences. PBOC officials have said this model will provide greater regulatory certainty, ease the burden of periodic renewals and support sustained compliance and strategic planning by approved firms.
The bulletin also records that six other institutions either had their renewal applications suspended, were not accepted for review, or voluntarily withdrew.
Since the launch of China’s non-bank payments licensing regime in 2011, 271 licences have been issued. A freeze on new approvals in 2016 and more rigorous reviews have reduced the number of active licences to 169 as of 10 June 2025.
On 17 June 2025, the Illinois Governor signed an amendment delaying the implementation of the state’s Interchange Fee Prohibition Act by one year. The Act was originally due to take effect on 1 July 2025 but will now apply from 1 July 2026.
The Act was passed in 2023 and prohibits payment card networks from charging merchants interchange fees on the portion of a card transaction that covers state or local taxes and certain fees, such as restaurant tips. Retail and hospitality groups have supported the law, while major banks and card networks have opposed it and launched a legal challenge.
In December 2024, a federal judge granted a preliminary injunction preventing enforcement of the law against federally chartered and out-of-state banks. As a result, most card transactions in the state remain unaffected for now.
The one-year delay provides time for ongoing litigation to proceed and avoids creating a competitive imbalance between Illinois-chartered and national banks. Industry groups have welcomed the deferral and continue to push for a full repeal.
On 2 July 2025, the Australian Banking Association (ABA) published a webpage announcing the launch of Confirmation of Payee (CoP), a name-checking system developed by Australian Payments Plus and designed to help reduce fraud and mistaken payments. The service is being rolled out across the banking sector and applies to both large and small institutions.
CoP will be introduced progressively during 2025 as banks complete the necessary system upgrades. The programme forms part of the Scam-Safe Accord and has attracted AUD 100 million in sector-wide investment.
The ABA’s announcement highlights the CoP launch as a key milestone in the fight against scams and has been welcomed by government and consumer representatives.
It was announced on 4 July 2025 that Cambodia and Japan have launched the first phase of a cross-border QR code payment system, enabling Cambodian travellers in Japan to make real-time payments by scanning Japanese standard QR codes (JPQR) using the Bakong e-wallet or participating mobile banking apps. The system connects Cambodia’s Bakong infrastructure with Japan’s domestic banking network, allowing seamless settlement in local currency.
The announcement was made at the Osaka Expo 2025, following a memorandum of cooperation signed in December 2023 and a further memorandum of understanding in April 2025 between the National Bank of Cambodia and the Payments Japan Association, which oversees the project.
This marks the first instance of Cambodia’s KHQR system linking with another country’s national QR code network for cross-border transactions. Phase 2 will enable Japanese travellers to use their domestic apps to scan KHQR codes for payments in Cambodia. The initiative supports regional payment connectivity, improves consumer convenience, and promotes financial inclusion by facilitating efficient, low-cost cross-border transactions.
On 2 July 2025, the Australian Competition and Consumer Commission (ACCC) issued a final determination allowing AusPayNet and its members to coordinate the phase out of the national cheque system.
The authorisation permits banks and payment providers to collaborate and share information to support the government’s Cheques Transition Plan. No new cheques will be issued after 30 June 2028, and cheque acceptance will end by 30 September 2029.
While such coordination would usually raise competition concerns, the ACCC found that the public benefits, including cost savings, greater efficiency and a shift to digital payments, outweigh any potential detriment. The authorisation runs until 31 December 2030 and includes a requirement for regular progress updates.
Support measures will be put in place to help vulnerable groups move to electronic alternatives.
On 2 July 2025, the Bank of England (BoE) published a speech by Victoria Cleland, BoE Executive Director for Payments, delivered at City Week 2025. The speech focused on how the BoE is facilitating the next phase of financial innovation. Key points include:
On 14 July 2025, the Financial Stability Board (FSB) published a letter sent to G20 finance leaders and central bank governors ahead of their July 2025 summit.
The letter, which is the first from Andrew Bailey, FSB Chair, sets out the FSB's work priorities which include addressing key risks to financial stability. Alongside giving more focus to existing initiatives such as the G20 cross-border payments roadmap, as part of this work priority the FSB will support robust implementation of agreed policies on non-bank financial intermediation and explore vulnerabilities from the growing role of private finance. It will also assess the increasing role of stablecoins for payment and settlement purposes.
On 18 July 2025, President Donald J. Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act into law, creating the first federal regulatory framework for fiat-referenced stablecoins in the United States. A White House fact sheet published alongside the legislation describes the Act as a landmark move intended to make America the leader in digital assets.
The Act introduces issuer licensing requirements, 100 percent reserve backing with U.S. dollars or short-term Treasuries and monthly public disclosures of reserve composition. It imposes strict marketing restrictions, prohibiting misleading claims that stablecoins are backed by the U.S. government or are legal tender. Issuers must comply with anti-money laundering and sanctions obligations under the Bank Secrecy Act and maintain the technical ability to freeze or redeem tokens when legally required. The legislation also gives stablecoin holders priority in insolvency and seeks to bolster the U.S. dollar’s status as the global reserve currency by driving demand for U.S. Treasuries.
See the June 2025 edition of the Newsletter for more on the Senate’s earlier vote to advance the GENIUS Act.
Recent developments relating to the Markets in Crypto-Assets Regulation ((EU) 2023/1114) (MiCA) include:
Separately, the Commission is expected to adopt additional RTS under Article 36(4) of MiCA on the liquidity requirements for the reserves of assets held by ART and e-money token (EMT) issuers. These are based on the EBA’s draft RTS submitted in June 2024 and will include requirements for maintaining minimum deposits in each official currency referenced.
On 25 June 2025, ESMA published a report on the implementation of the Regulation on a pilot regime for market infrastructures based on distributed ledger technology (DLT) ((EU) 2022/858) (DLTR).
The report notes that, although uptake of the DLT Pilot Regime remains limited with only three authorised infrastructures and minimal live trading activity, the regime has stimulated experimentation with DLT-based models for trading, settlement and compliance (particularly for smaller issuers and innovative asset types). It highlights operational and legal frictions, such as lack of interoperability and access to central bank money, and concludes that current thresholds restrict wider participation.
The report sets out recommendations for making the DLT Pilot Regime:
The European Commission has consulted on the DLT Pilot Regime for market stakeholders as part of the wider consultation on the Savings and Investments Union and is expected to present its own report to the European Parliament and the Council of the EU within three months of receiving ESMA's report.
Depending on the Commission's recommendations, the DLT Pilot Regime may be extended, amended or converted into a permanent regulation. In an accompanying press release, ESMA states that if the regime is extended, it would be prepared to provide a follow-up report within the revised timeline and to continue technical engagement with all stakeholders.
On 3 July 2025, an independent bill to ease several tax burdens on digital assets was introduced to the U.S. Senate. The bill would establish a de minimis threshold of $300 (up to $5,000 annually) under which cryptocurrency transactions need not be reported for capital gains. It also seeks to eliminate double taxation of mining and staking rewards by taxing them only on sale (rather than at receipt) and provides clarity on other tax issues – including safe harbour for crypto lending, explicit wash-sale rules for crypto, favourable treatment for charitable donations of digital assets, and an option for brokers and traders to use mark-to-market accounting for crypto holdings.
On 1 July 2025, the Securities Commission Malaysia (SC) published a consultation paper and corresponding announcement proposing significant reforms to its regulatory framework for digital asset exchanges (DAXs), including a liberalised listing regime.
Under the proposal, certain digital assets could be listed on registered exchanges without prior approval from the SC, provided they meet specific criteria such as having undergone a comprehensive public security audit and having been traded for at least twelve months on a platform that complies with Financial Action Task Force (FATF) standards. The aim is to reduce time to market, broaden the range of products available to investors, and enhance accountability among exchange operators.
The SC is also seeking feedback on whether higher-risk digital assets should be permitted on licensed exchanges, including privacy coins, memecoins, and nascent utility tokens, due to their association with heightened market volatility, limited transparency, and money laundering concerns.
In parallel, the SC is proposing tighter standards for governance and custody, requiring DAXs to segregate client assets, hold at least 90 per cent of digital assets in cold storage, designate a senior manager resident in Malaysia to oversee wallet access, and either register as a digital asset custodian or appoint one that is licensed by the SC. These proposals are intended to promote responsible innovation, improve investor protection, and strengthen the integrity of Malaysia’s digital asset ecosystem.
On 1 July 2025, the Connecticut Governor signed House Bill 7082 into law, formally prohibiting the use of cryptocurrency by the state government.
The law, which passed with strong bipartisan support in both chambers of the state legislature, prevents state agencies and offices from accepting virtual currency as payment and from purchasing, holding or investing in digital assets. It also prohibits the establishment of any form of cryptocurrency reserve. These restrictions will take effect on 1 October 2025.
In addition, the legislation introduces stricter requirements for cryptocurrency-related money transmission licensees operating in the state, including enhanced licensing and compliance obligations.
On 12 June 2025, Brazil enacted Provisional Measure 1303, introducing a major overhaul of its tax treatment for cryptocurrency. See also this press release. The measure forms part of Brazil’s broader 2025 tax reform and is aimed at increasing government revenue, closing loopholes such as using foreign exchanges to avoid tax, and aligning the country’s approach with other jurisdictions like India and Japan that have recently tightened cryptocurrency taxation.
The new law replaces the previous tax regime, which exempted monthly crypto sales of up to R$35,000 and taxed higher gains at rates between 15 and 22.5 per cent, with a flat 17.5 per cent capital gains tax on all cryptocurrency profits, regardless of the amount. This reform removes long-standing relief that allowed small-scale investors to avoid tax entirely.
The 17.5 per cent rate applies uniformly across all forms of crypto-related income, including assets held offshore, in self-custody, or earned through decentralised finance (DeFi), staking, and non-fungible token (NFT) sales.
On 26 June 2025, the Hong Kong government issued its second policy statement on digital assets, outlining a new strategic framework known as “LEAP” – Legal clarity, Ecosystem expansion, Application in the real economy, and People development. See also this press release. The policy builds on Hong Kong’s 2022 digital asset roadmap and aims to position the jurisdiction as a global hub for responsible innovation in the sector.
As part of the introduction of a comprehensive, unified regulatory framework for digital asset service providers, a key feature is a mandatory licensing regime for stablecoin issuers, which will apply from 1 August 2025. The regime is intended to ensure that fiat-referenced stablecoins used in payments are fully backed by high-quality reserves and meet certain governance and risk management standards. The Securities and Futures Commission will oversee the licensing process.
The statement also confirms the government’s intention to regularise the issuance of tokenised government bonds and promote the development of tokenised exchange-traded funds (ETFs). The Financial Services and the Treasury Bureau (FSTB) and the de facto central bank, the Hong Kong Monetary Authority will conduct a legal review to support wider tokenisation of real-world assets, focusing on issues such as settlement, registration, and stamp duty treatment.
In parallel, the government will encourage the use of tokenisation across a broader range of assets and financial instruments across sectors including precious and non-ferrous metals and renewable energy, covering real world physical assets such as gold and solar panels, and launch a funding programme through Cyberport to support blockchain and digital asset innovation.
On 27 June 2025, the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) jointly launched a public consultation on legislative proposals to establish new licensing regimes for digital asset dealing and custody service providers. The consultation is open until 29 August 2025.
The proposals seek to extend Hong Kong’s regulatory framework beyond virtual asset exchanges (which became licensable with effect from June 2023) to cover a broader range of activities, reflecting market growth and the need for stronger investor protection. They build on the FSTB’s earlier consultation on over-the-counter (OTC) virtual asset services, which ran from February to April 2024.
Two distinct regimes are proposed:
Applicants under both regimes must meet fit and proper standards and comply with detailed obligations relating to conduct, risk controls, record keeping and investor safeguards as well as those relating to AML and CTF. There will be no transitional or deeming arrangements when the legislation comes into effect.
This consultation builds on the virtual asset exchange licensing regime introduced in June 2023 with an enforcement regime comprising both administrative and criminal sanctions and forms part of Hong Kong’s broader efforts to establish a robust, comprehensive and unified regulatory environment for digital assets.
See this Our Thinking article for further details on the consultation and proposed regulatory obligations.
On 4 July 2025, the Guardian Foreign Exchange Industry Group published their report on the 'Use of Tokenised Bank Liabilities for Transaction Banking'. This report was led by Ant International in collaboration with the International Swaps and Derivatives Association, and is one of the outcomes of the Monetary Authority of Singapore's (MAS) Project Guardian.
The report recommends design principles for tokenised bank liabilities, outlines key risks and mitigation actions, and outlines use cases in transaction banking.
Key findings include:
On 24 June 2025, Japan’s Financial Services Agency (FSA) released a proposal to reclassify cryptocurrencies as “financial products” under the Financial Instruments and Exchange Act. The proposal forms part of the government’s broader “New Capitalism” strategy to attract investment and modernise Japan’s capital markets.
The reclassification would mark a major legal and regulatory shift, bringing crypto assets into the same regime as securities and other investment products. This would enable the launch of domestic exchange traded funds (ETFs) based on digital assets, which are currently not permitted under Japanese law. The FSA highlighted the increasing institutional uptake of crypto globally, citing over 1,200 financial institutions now holding U.S.-listed Bitcoin ETFs, and noted that Japan’s crypto market has grown to more than 12 million active trading accounts.
Alongside regulatory reclassification, the FSA is also proposing a reform of the tax treatment of crypto gains. Under current law, individual profits from crypto trading are taxed as miscellaneous income at rates of up to 55 percent. The proposal would align crypto with the capital gains tax regime applicable to stocks, applying a flat 20 percent rate and allowing the use of annual loss offsets. The aim is to reduce the compliance burden and encourage greater retail and institutional participation in the domestic market.
The proposed reforms are subject to public consultation and legislative approval.
On 13 June 2025, Thailand approved a five-year exemption from capital gains tax on profits from cryptoasset sales made through licensed domestic platforms. The measure applies from 1 January 2025 to 31 December 2029 and covers cryptocurrencies and digital tokens such as Bitcoin and Ethereum.
The exemption forms part of Thailand’s strategy to support fintech growth, attract investment, and promote use of regulated exchanges. The Ministry of Finance estimates that the policy could generate over 1 billion baht (approximately 30 million U.S. dollars) in indirect tax revenue.
The announcement follows recent steps to allow crypto payments for tourism and ongoing enforcement against unlicensed exchanges. Authorities intend the exemption to strike a balance between innovation and regulatory oversight in line with FATF standards.
On 2 July 2025, the Bank of England’s (BoE) Sasha Mills, Executive Director, Financial Market Infrastructure (FMI), delivered a speech at City Week 2025, setting out the BoE’s evolving approach to the digitalisation of wholesale markets. She highlighted the promise of technologies such as distributed ledgers and tokenisation to enhance post-trade processes and asset mobility, while emphasising the need for financial stability and interoperability with existing systems.
The BoE is reviewing the role of stablecoins in wholesale markets and within the Digital Securities Sandbox, and is expected to publish further detail later this year. Following industry feedback, the BoE is also considering permitting a portion of stablecoin reserves to be held in high quality liquid assets rather than entirely in central bank deposits.
Proposals for transitional holding limits on systemic stablecoins are likely to be in the region of £10,000 to £20,000 for individuals and £10 million for businesses, though formal consultation is expected. The BoE also confirmed plans to publish its onboarding approach for new financial market infrastructures and continues to develop its RTGS upgrade and programmable settlement capabilities.
See this Our Thinking article for further detail.
On 26 June 2025, the Financial Action Task Force (FATF) published a report on best practices on travel rule (ie FATF recommendation 16 on payment transparency) supervision alongside its update on the implementation of its standards on virtual assets (VAs) (also known as cryptoassets) and virtual asset service providers (VASPs) (also known as cryptoasset service providers (CASPs)) (see the separate item).
The report sets out good practices on the various elements of travel rule supervision that jurisdictions may consider when developing their approaches including:
The report also focuses on challenges in travel rule obligations, including uneven adoption of the travel rule across jurisdictions, unhosted wallets and lack of capacity.
On 26 June 2025, the Financial Action Task Force (FATF) published its sixth targeted update on the implementation of its standards on virtual assets (VAs) (also known as cryptoassets) and virtual asset service providers (VASPs) (also known as cryptoasset service providers (CASPs)).
The update sets out the findings from the FATF’s assessment of jurisdictions’ compliance with recommendation 15 on new technologies (R.15) and its interpretative note (INR.15), as well as recommendation 16 on payment transparency (R.16) (ie the “travel rule”) and the related interpretative note (INR.16).
The update provides key areas for improvement and recommendations for both public and private sectors to better address persistent and significant threats.
The FATF will continue to share findings, experiences and challenges on R.15 implementation (including relating to stablecoins, offshore VASPs, ecentralized finance (DeFi)) and market monitoring trends, some of which may necessitate further FATF work. The status of R.15 implementation by FATF members and jurisdictions with materially important VASP activity will next be updated and published in 2026.
On 22 June 2025, the Financial Action Task Force (FATF) published updated guidance on financial inclusion and anti-money laundering (AML) and counter-terrorist financing (CTF) measures. This forms part of the FATF's work to address the unintended consequences of its AML and CTF standards.
The updated guidance provides support in the design of AML and CTF measures that foster financial inclusion without compromising measures that focus on combating crime and safeguarding financial integrity. It aims to develop a common understanding of the FATF standards that are relevant when promoting financial inclusion and highlights the flexibility the standards offer (especially around a risk-based approach).
The guidance mainly focuses on facilitating access to and use of formal services by unserved and underserved persons. It is relevant to policymakers, supervisors and regulated entities, and includes best practice examples of the risk-based approach.
On 30 June 2025, it was announced that the continent's first Pan-African card scheme, the PAPSSCard, has launched. The card is a joint venture between Afreximbank, PAPSS, and Mercury Payment Services.
Afreximbank notes that most African card payments are routed through global systems, causing increased fees and loss of data control. PAPSSCard aims to address this problem by processing transactions within the continent, keeping value, data and economic benefit in Africa.
The President of Afreximbank highlighted the significance of PAPSSCard in reclaiming Africa's financial autonomy, describing it as a "transformative step towards strengthening intra-African trade and preserving value within the continent".
On 24 June 2025, it was reported that the People's Bank of China (PBOC) and the Hong Kong Monetary Authority (HKMA) have jointly developed Payment Connect. Payment Connect is being implemented by the China National Clearing Centre (CNCC) and Hong Kong Interbank Clearing Limited (HKICL).
The project will allow participating institutions in both regions to facilitate cross-boundary remittances in Renminbi and Hong Kong dollars. This system is expected to support various types of personal transfers, including salary payments, tuition fees, and medical expenses. The HKMA and PBOC have stated that the initiative has been designed to increase the efficiency and quality of cross-boundary payments.
On 17 July 2025, it was reported that the bank payment firm GoCardless has partnered with the Cashflows platform to power Cashflows Payouts, which allows businesses to send real-time payments using A2A payment technology.
On 1 July 2025, it was reported that Vietnam's Asia Commercial Bank (ACB) has launched Visa Flex Credential which will allow cardholders to switch between debit and credit payment modes using a single card. This new function is aimed at expanding consumer payment flexibility in Vietnam, where debit cards continue to dominate over credit. This feature aims to increase credit card adoption and encourage more frequent card usage. ACB expects this offering to improve activation rates, reduce dormant accounts, and generate data insights for future product development.
On 1 July 2025, it was reported that Klarna has rolled out an opt-out feature which, once activated, prevents users from accessing Klarna's BNPL products that involve credit. However, this option still allows immediate payment options that do not involve deferred settlement.
Klarna is now rolling out this feature in the Netherlands after an earlier implementation in the UK, where Klarna tested the feature as part of its responsible lending framework.
In the Netherlands, the opt-out option was discussed during a parliamentary roundtable with BNPL providers in January 2025. Klarna's new feature is seen as a commitment to developing the functionality locally, aligning with political calls for stronger consumer financial safeguards.
On 3 July 2025, Worldpay announced in a press release that they are adding domestic acquiring capabilities to Thailand. Worldpay will be able to provide domestic settlements in local currency to Thai merchants. In addition to card acquiring, Worldpay have also launched access to four alternative payment methods that are popular in the Thai market: LINE Pay, TruMoney, PromptPay and online banking.
Worldpay has also expanded into other regions over the last two years, including Columbia, Mexico and the UAE.
On 27 June 2025, it was reported that Kraken has become the first company to be awarded a MiCA licence from the Central Bank of Ireland. The MiCA licence will allow Kraken to expand its product offering to include spot trading, derivatives and payments to retail, professional and institutional clients across Europe.
On 25 June 2025, Barclays announced in a press release that from 27 June 2025, customers would no longer be able to make crypto-currency transactions using a Barclaycard.
Barclays have explained that their reasons for doing so are because a fall in the price of cryptoassets could lead to customers finding themselves in debt that they cannot afford to repay. Another reason is that there is no protection for cryptoassets if something goes wrong with a purchase as they're not covered by the Financial Ombudsman Service and the Financial Services Compensation Scheme.
On 2 July 2025, it was reported that Bitget, with Mastercard's support, are launching a zero-fee crypto card. The card will be available through the Bitget wallet app and will support real-time funding via on chain swaps and deposits. By leveraging Mastercard's Digital First technology, users can apply for the card digitally and add it to their mobile wallets within minutes.
The card will first be rolled out in the UK and EU, with plans to expand to Latin America, Australia, and New Zealand in the coming months.
On 2 July 2025, it was reported that Paxos has launched its Global Dollar (USDG) stablecoin in the EU. A portion of the stablecoin's reserve assets are with European banking partners. The stablecoin is available via a number of host distribution partners including Kraken, Gate, Coinmetro, SwissBorg, Zodia Custody, and Orbital.
On 2 July 2025, it was reported that AllUnity has been granted an e-money institution (EMI) licence by the German Federal Financial supervisory authority (BaFin). According to the report, this licence allows AllUnity to proceed with the release of a Euro stablecoin, named Eurau. The stablecoin will be 100% collateralised and can be used for 24/7 instant cross-border settlements, with seamless integration for regulated financial institutions, fintechs and enterprise clients internationally.
On 10 July 2025, it was reported that Ripple has selected Bank of New York Mellon (BNY) as primary custodian for its U.S. dollar-pegged stablecoin reserves. Ripple USD is issued under a New York Department of Financial Services Trust Company Charter, with a particular objective of improving the speed, cost and efficiency of cross-border payments.
According to the report, the aim for Ripple is that partnering with BNY as primary reserve custodian will lead to ‘adoption at institutional scale’ and ‘help bridge the gap between traditional finance and crypto’. BNY’s transaction banking services will also help in underpinning Ripple’s operations.
On 16 June 2025, the Payments Association its 'Merchant survey 2025: Navigating the payment innovation divide'. This survey was conducted in partnership with Opinium and collated information from 125 UK retail businesses across all regions and business sizes.
The findings from the survey offer key insights into topics such as payment challenges, payment method usage, cross-border transactions and future payment trends.
Key findings include:
On 15 July 2025, Volante Technologies published The Big Survey 2025: Modernising Payments, analysing responses from over 250 senior executives at banks across Europe, the Middle East and Africa (EMEA). The survey examines bank strategies for upgrading payments infrastructure in response to evolving technology demands, operational challenges and regulatory change.
The findings offer insight into how banks are prioritising investment in modern payments platforms, cloud adoption and real-time readiness.
Key findings include:
Authored by Charles Elliott, Virginia Montgomery, Sofie Gowran and Nurangis Sobirkhonova.