UKThe FCA's consultation GC26/7, on non-Handbook guidance for firms providing financial services using decentralised finance (DeFi), closes on 18 November 2026. The draft covers operational resilience and financial crime, including SYSC 6 and the Money Laundering Regulations. The FCA plans to publish the final guidance in January 2027.
Why it matters:The draft says responsibility for financial crime controls may be fragmented across developers, governance participants, and infrastructure providers. It also lists high-risk factors, including exposure to wallets or protocols associated with illicit activity and the use of privacy-enhancing technologies.
Action:If your firm touches DeFi, check whether your systems can identify exposure linked to wallet addresses, smart contracts, or protocols, and decide before 18 November whether to respond.
EUOn 5 November 2026, the European Commission hosted the tenth meeting of the High-Level Group on sanctions. Its agenda included the use of crypto assets to circumvent sanctions. The EU Sanctions Envoy also convened a forum with partners including the UK, the US, Japan, and Canada on Russia's financing through payment networks in third countries.
Why it matters:The agenda suggests third-country payment routes and crypto are where EU enforcement attention sits, along with Russia's energy exports and the shadow fleet.
Action:Review payment corridors through third countries for Russia exposure, and confirm that crypto-related circumvention appears in your EU sanctions risk assessment.
USOn 6 November 2026, FinCEN and the Federal Reserve Board jointly withdrew a proposed rule that would have amended the Recordkeeping and Travel Rule regarding convertible virtual currencies. It would also have lowered the threshold for funds transfers that begin or end outside the United States.
Why it matters:A withdrawn proposal changes nothing in the current rule, so firms that were preparing for a lower cross-border threshold no longer have a proposal to build against.
Action:Check any project plan or budget line that assumed the proposal would take effect, and re-scope it against the rule as it stands.
GlobalTreasury's 6 November readout of the October FATF plenary says the planned targeted review of certain jurisdictions with longstanding virtual asset deficiencies will outline decision points for the next plenary. It also says the FATF reminded all jurisdictions to impose countermeasures on Iran.
Why it matters:Treasury describes the goal as accountability for jurisdictions with systemic weaknesses. That suggests the review could lead to consequences for those jurisdictions as early as the next plenary.
Action:Keep your list of virtual asset counterparties by jurisdiction current, so you can respond quickly if the plenary singles out specific markets.