Weekly · Tightening of sanctions and the launch of crypto-asset regulation · September 27 – October 3, 2026

Key points

Sanctions pressure: US and EU

On 28 September, the Council of the EU adopted Decision (CFSP) 2026/2185 and Implementing Regulation (EU) 2026/2184, which amended the legal basis for restrictive measures concerning Ukraine. These acts replaced previous provisions, requiring immediate updates to screening procedures for counterparties falling under Regulation (EU) No 269/2014.

During the same period, OFAC significantly expanded the sanctions perimeter. On 30 September, the US Office of Foreign Assets Control amended the Cuban Assets Control Regulations in accordance with NSPM-5, adding a prohibition on indirect financial transactions with entities on the Cuba Restricted List and revoking authorizations for U-Turn and group travel. The Iran Transactions Regulations were also updated, new names were published on the SDN List, and general licenses were issued, including the revocation of GL X and its replacement by GL X1, which subsequently expired. On 2 October, OFAC published another notice regarding the designation of individuals on the SDN List.

Crypto-regulation: UK and EU

On 30 September, the FCA opened the acceptance of applications for crypto-firm authorization under the new regulatory regime. The standards cover consumer protection, asset custody, market integrity, and financial resilience. Companies planning to continue operating in the UK must submit their applications by 28 February 2027 to meet the requirements before the regime comes into full force on 25 October 2027.

In parallel, ESMA presented its response to the European Commission’s consultation on the review of MiCA on 30 September. The regulator recommended simplifying the framework structure but simultaneously tightening rules on the marketing of crypto-assets, particularly for influencers, and introducing new safeguards for risks associated with DeFi, staking, and lending. This signals a move by the EU toward stricter oversight of retail promotion of crypto products.

SEC: access to private markets and crypto custody

On 30 September, the SEC voted in favor of a proposal to amend rules aimed at expanding choices for retail investors and facilitating capital formation in public and private markets. On 1 October, the regulator proposed a new regime for the custody of crypto-assets by registered investment advisers and regulated funds, including registered investment companies and business development companies.

These proposals are at the stage of public consultation. They could change the compliance architecture for funds wishing to deal with crypto-assets and open new distribution channels for private assets to retail clients if adopted in their current form.

Oversight in Switzerland and fraud prosecution

On 29 September, FINMA concluded its proceedings against Julius Bär, marking the fifth such case in the last ten years. The regulator identified serious breaches of supervisory norms related to private debts to a European group and relationships with two Russian politically exposed persons (PEPs). Some immediate measures were lifted, but the bank is required to ensure sustainable improvement in its risk and compliance culture.

In the enforcement sphere, the SEC brought charges against several entities on 29 September for defrauding retail investors via WhatsApp and other platforms, with losses of at least $15 million. On 30 September, charges were filed against Christopher Kenji Dinelli and Jacob David 'Kobe' Frankel for a scheme that attracted over $8.7 million from 35 investors, including veterans. In the UK, the FCA obtained confiscation orders on 28 September against Raymondip Bedi (£603,404.28) and Patrick Mavanga (£247,997.99) for fraud involving fictitious crypto-assets, which defrauded 65 investors of £1,541,799.

What this means

The sanctions landscape is becoming more complex and less predictable. If you have exposure to Cuba or Iran, the risk of secondary sanctions is increasing due to the prohibition on indirect transactions and frequent updates to OFAC lists. If you are working with the EU’s Ukraine sanctions package, it is necessary to urgently synchronize internal lists with the new acts from 28 September. Monitor the publication of additional Cuban regulations by OFAC: if they appear, this will confirm the trend toward expanding indirect control.

For the crypto sector, the UK and the EU are moving toward strict authorization and marketing controls. If you are planning to launch crypto products in the UK, the 28 February 2027 deadline is a critical path for obtaining a license. If you are promoting crypto-assets in the EU, the tightening of rules for influencers proposed by ESMA may require a review of marketing strategies. Watch whether the European Commission includes ESMA’s recommendations in the legislative proposal: this will be a signal for immediate adaptation of advertising materials.

In Switzerland and the US, oversight is focused on specific AML breaches and the protection of retail clients. If you manage private capital, attention to Russian PEPs and the structure of debt instruments remains a priority following the Julius Bär case. If you provide services to retail investors, the intensified prosecution of fraud via messengers requires stricter monitoring of communication channels. Watch court rulings in SEC and FCA cases: the issuance of confiscation orders or large fines will be an indicator of tightening enforcement.

Under the radar: technical changes

Despite the high-profile news, several technical but significant changes have occurred. ESMA and EBA published their 2027 work programs, shifting the focus from preparation to the implementation of initiatives under the Savings and Investments Union (SIU) and the Markets in Financial Instruments Package (MISP). This means that a wave of specific guidelines and RTS/ITS is expected next year.

Additionally, several US options exchanges (NYSE Arca, NYSE American, MX2, IEX) submitted changes to their fee schedules, which took effect immediately. Although these are routine procedures, they affect the economics of order routing and transaction costs for trading desks. The SEC confirmed the immediate effectiveness of the changes for NYSE Arca and NYSE American on 2 October.

Our read

The period is characterized by a clear tightening of the regulatory environment in both sanctions and digital asset regulation. On the 'tightening vs loosening' axis, tightening dominates: OFAC expanded the perimeter of indirect sanctions, the FCA introduced strict authorization deadlines, and ESMA proposed additional safeguards. The only counter-argument is the SEC’s proposal to expand retail investor access to private markets; however, this is more of a liberalization of access while maintaining strict requirements for custody and compliance. On the 'convergence vs fragmentation' axis, a mixed picture is observed: the EU and the UK are moving in similar directions regarding crypto-regulation, but the US maintains its own trajectory, focusing on custody and access rather than a unified licensing regime. On the 'intensity of enforcement' axis, the trend is clearly upward: FINMA concluded proceedings against a major bank, the SEC and FCA are actively prosecuting fraudsters, and OFAC regularly updates its lists. An indicator of a trend reversal could be the suspension or revocation of new OFAC sanctions packages or the easing of FCA deadlines, but no such signals are present. Overall signal: a clear tightening of requirements for compliance and sanctions screening.

This digest was produced automatically by a large-language-model system from the regulator publications and official sources listed below; it is AI-generated content and may contain inaccuracies. It is not legal advice — verify wording and deadlines against the original documents.

Sources