Daily · US Market Infrastructure and Accredited Investor Rules · October 5, 2026

Key points

FinCEN Targets A7 Network Sanctions Evasion

FinCEN issued a finding and notice of proposed rulemaking pursuant to section 9714(a) of the Combating Russian Money Laundering Act (Public Law 116-283), as amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 (Public Law 117-81). The agency found transactions involving any company operating outside the United States that is controlled by the A7 Network to be a class of transactions of primary money laundering concern in connection with Russian illicit finance.

FinCEN proposed the imposition of a prohibition on certain transmittals of funds by any covered financial institution involving that class of transactions. The A7 Network is described as a sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies.

This proposal expands sanctions compliance obligations for covered financial institutions, which must prepare to screen and block transmittals involving A7 Network-controlled entities. The measure targets the specific mechanism of using sub-agents or controlled entities to obscure the origin of funds linked to Russian illicit finance.

SEC Explores New Accredited Investor Paths

The US Securities and Exchange Commission published a notice in the Federal Register on 5 October 2026 stating it is considering whether to issue an order designating holding a Certified Financial Planner (CFP) certification in the United States in good standing as qualifying natural persons for accredited investor status.

In related actions, the SEC is also considering designating the holding of a U.S. certified public accountant (CPA) license in good standing, the Investment Banking Representative license (Series 79), the Research Analyst licenses (Series 86 and Series 87), and the Chartered Financial Analyst (CFA) charter in good standing as independently qualifying natural persons for accredited investor status. Additionally, the SEC is considering whether to designate passage of an accredited investor exam to be developed by the Financial Industry Regulatory Authority (FINRA) as qualifying for this status.

If finalized, these designations would allow natural persons holding these specific professional credentials or passing the FINRA-developed exam to qualify as accredited investors without meeting the standard income or net worth thresholds.

23-Hour Trading Expansion and Risk Controls

MIAX PEARL LLC filed a proposed rule change with immediate effectiveness to amend risk controls for equity members. This change is in connection with the upcoming expansion by other national securities exchanges and applicable securities information processors of their trading hours to 23 hours per day, 5 days per week.

The Nasdaq Stock Market LLC also filed a proposed rule change with immediate effectiveness to amend Exchange Rule Equity 2, Section 9 regarding clearing and settlement in connection with 23-5 trading. These filings indicate that market infrastructure providers are adjusting their risk management and settlement procedures to accommodate the extended trading window.

SEC Proposes Interval Fund Modernization

The SEC proposed to amend the rule under the Investment Company Act of 1940 that allows registered closed-end management investment companies and business development companies (BDCs) to make repurchase offers to shareholders at net asset value (NAV) at periodic intervals pursuant to a fundamental policy, known as interval funds.

The proposed amendments would increase flexibility in the rule's repurchase offer framework and modify liquidity management requirements. The proposal is designed to allow interval funds to better match the liquidity profile of the assets in which they invest while continuing to provide the operational infrastructure and investor protection of the Investment Company Act of 1940.

Furthermore, the SEC proposed to permit regulated closed-end funds to issue multiple share classes, consistent with routine exemptive relief provided to these funds, and to require certain related disclosure in funds' prospectuses. The agency also proposed to require disclosures in all regulated closed-end fund shareholder reports, a legend in their prospectuses, and an increase in the dollar amount used for the prospectus expense example. As a result of these amendments, the SEC proposed to rescind existing related exemptive orders.

FCA Prioritizes Tokenization and AI

Jon Relleen, director of infrastructure and exchanges at the Financial Conduct Authority (FCA), stated at the Reform of the UK Public and Private Capital Markets Summit 2026 that tokenisation, AI, and markets for trading private company shares have become central to the FCA's capital markets policy programme. He noted that the FCA has completed major aspects of a multi-year programme of work to ensure capital markets work well for the economy and support growth.

Relleen said the FCA has been working with the Treasury, the Bank of England, and in close dialogue with the private sector on a raft of wholesale market reforms. He indicated that this work draws on formal reports like the Wholesale Markets Review, the process of reviewing inherited EU regulation, and issues raised by market contacts.

Routine Filings and Administrative Notices

The SEC issued a joint investor bulletin with U.S. and global financial regulators as part of World Investor Week, encouraging investors to be resilient in changing market conditions. The Depository Trust Company (DTC) filed a proposed rule change with the SEC to modernize the Direct Registration System.

Philip R. Lane, Chief Economist of the European Central Bank, delivered a speech titled 'Diagnostic Challenges for ECB Monetary Policy' on 5 October 2026. The Swiss National Bank published important monetary policy data via its data portal.

Nasdaq GEMX, LLC, The Nasdaq Stock Market LLC, Nasdaq PHLX LLC, Nasdaq ISE, LLC, and Nasdaq MRX, LLC filed conforming rule changes with immediate effectiveness to reflect the name change of Nasdaq BX, Inc. to Nasdaq Texas, LLC. Long-Term Stock Exchange, Inc. filed a proposed rule change with immediate effectiveness to amend LTSE Rule 15.120 to expand the permitted collection arrangements.

Our read

The expansion of trading hours to 23 days per week requires immediate attention from market participants regarding risk control and settlement infrastructure, as evidenced by the immediate effectiveness of MIAX PEARL and Nasdaq rule changes. For financial institutions, the FinCEN proposal targeting the A7 Network signals a tightening of sanctions compliance requirements, necessitating updated screening protocols for transmittals involving entities controlled by this network. The SEC's exploration of professional credentials as a path to accredited investor status could significantly broaden the pool of eligible investors for private placements and hedge funds, potentially altering marketing and onboarding strategies for asset managers.

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.

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