Risk & Resilience

BaFin's Circular 11/2026 (BA), effective September 14, 2026, replaces the 2023 FAQs on trustee and deputy appointments under Sections 7 et seq. of the Pfandbrief Act (PfandBG). It sets out the eligibility criteria, the required documents and their validity periods, the fees, and the rules on remuneration and expenses. Mortgage banks should check their trustee renewal pipeline and internal processes against the new document and timing requirements.

The Norway Financial Supervisory Authority (Finanstilsynet) has posted a warning on gatrixcapital.com, a website that the French Autorité des Marchés Financiers (AMF) placed on its blacklist of crypto-asset derivatives offerings. Compliance teams should treat the domain as a high-risk, likely unauthorized entity and take screening and monitoring steps across onboarding, payments, and fraud controls.

The ACPR and AMF will host the 10th-anniversary Fintech Forum on October 2, 2026, at the Bank of France Conference Center in Paris, as part of the French FinTech Weeks. The agenda signals current supervisory priorities, including tokenization and DLT, MiCA, AML/CFT, digital operational resilience, crowdfunding, and payment services. It offers compliance teams direct access to French regulators.

The Bundesbank's September 11, 2026 press release shows domestic bond issuance surged in July 2026, driven by federal government and credit institution issuance and heavy foreign investor demand. This is a statistical release, not a rule change, so it creates no new obligations. It does provide useful market context for compliance, treasury, and risk teams assessing liquidity, concentration, and funding conditions.

The ECB's 2026 reverse stress test found that banks need stronger risk data aggregation, board-led scenario planning, and more realistic assumptions about crisis management actions. Supervisors identified weak links between capital, liquidity, and operational impacts, as well as overreliance on mitigating measures that may be unavailable when many banks act at once. Compliance teams should expect continued supervisory scrutiny of geopolitical risk and capital planning frameworks.

It's planning season for many risk management and internal audit functions. CROs and CAEs are deciding where to spend their limited resources, what work to prioritize and what they hope to accomplish in the coming year. I have a question for them. Do you see yourselves in the decision and performance support business?

The Hong Kong SFC has concluded its consultation on amendments to the Securities and Futures (Stock Market Listing) Rules, confirming it will proceed with proposals to introduce continuing conditions on listing applications, post-listing conditions, information requisition powers, and removal of automatic exemptions for certain share issuances. These changes, expected to take effect in Q1 2027, expand the SFC's regulatory toolkit for both IPO and post-IPO oversight, requiring compliance teams supporting listed issuers and sponsors to reassess disclosure, governance, and monitoring processes.