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CFPB CFPB Source document ↗
CFPB United States Conduct & Consumer ✓ 13 claims 14 Oct 2026

CFPB opens debanking probe of nine largest US banks after OCC report

The CFPB has picked up an OCC report naming the nine largest national banks and turned it into an enforcement lane. This segment covers who is named, which statutes the bureau will test them against, and how a politically framed consumer-protection action reshapes supervisory exposure for institutions above the $10 billion threshold.

  • The CFPB will investigate the nine OCC-named banks and others for compliance with ECOA, FCRA adverse-action rules and UDAAP.
  • The OCC report cited debanking of sectors including firearms, oil and gas, and tobacco, with excerpts from bank emails.
  • The initiative implements Executive Order 14331; the CFPB supervises banks above $10 billion in assets.
FSB Financial Stability Board Source document ↗
Financial Stability Board Global Governance & Accountability ✓ 12 claims 14 Oct 2026

FSB review finds its own policy drafting contributes to uneven G20 reform implementation

The FSB's second Implementation Monitoring Review report turns the lens inward, asking whether the way it develops, drafts and presents post-crisis reforms affects how well they are implemented. It concludes national circumstances dominate but the policy process itself matters in a number of cases. For anyone who tracks FSB standards into national rulebooks, this signals where the body may recalibrate how it writes the next generation of reforms.

  • Second report under the G20 Implementation Monitoring Review, a strategic review led by Randal K. Quarles at the G20's request.
  • Finds national circumstances are the main driver of uneven implementation, but the FSB's own policy development process contributes in some cases.
  • Points to targeted, well-calibrated reform of the policy development process as one element in improving implementation.
FSB Financial Stability Board Source document ↗
Financial Stability Board Global Governance & Accountability ✓ 14 claims 14 Oct 2026

FSB consults on eight principles for modernising financial regulation and supervision

The Financial Stability Board has opened consultation on eight high-level principles meant to keep regulatory and supervisory frameworks forward-looking without eroding resilience. Alongside it sits the 2026 G20 Implementation Monitoring Review, which concedes that some of the uneven uptake of agreed standards stems from how the FSB drafts and presents policy. This segment covers what both documents say and the deadline that matters.

  • Eight high-level modernisation principles are open for comment until 8 January 2027, with a final report due in the first half of 2027.
  • Principles rest on four premises, including that they build on the commitment to implement internationally agreed standards and aim to preserve or enhance resilience.
  • The 2026 IMR traces part of uneven implementation to the FSB's own policy development process, following 2025 findings of a worrisome slowdown.
HMRC HM Revenue & Customs Source document ↗
HM Revenue & Customs United Kingdom Governance & Accountability ✓ 19 claims 14 Oct 2026

HMRC updates Air Passenger Duty payment guidance on wrong reference numbers

HMRC has refreshed its operational guidance on paying Air Passenger Duty. The headline change is a warning on payment reference discipline, alongside restated deadlines, payment channels and account details. It is administrative rather than a change to duty rates or liability, but it affects how airlines and occasional operators discharge their APD obligations and avoid penalties or interest.

  • Using an incorrect 15-character reference (starting with X) may delay a payment or apply it to another tax bill; payers can email APDHelpdesk@hmrc.gov.uk to move it.
  • Payment deadlines are extended by seven calendar days for Direct Debit, Faster Payments, CHAPS and Bacs; Occasional Operator Scheme users pay within seven days of the flight.
  • Payments over £20 million cannot be made by Direct Debit, and a return must be submitted even where there is nothing to pay.
  • Occasional Operator Scheme payers cannot use Direct Debit and must contact HMRC for a reference number.
FCA FCA Publications Source document ↗
FCA Publications United Kingdom Prudential & Capital ✓ 16 claims 14 Oct 2026

FCA and PRA lift 15% cap on individual lenders' high-LTI mortgage lending

The FCA and PRA have jointly recalibrated how the FPC's loan-to-income flow limit is enforced. Individual mortgage lenders may now push their share of high-LTI lending above 15%, provided the market-wide flow stays consistent with that limit. This item covers who the new guidance binds, how the aggregate flow will be measured and published quarterly, and where the supervisory attention now falls.

  • Individual lenders may now exceed a 15% share of high-LTI lending, with the 15% limit instead applied to aggregate market flow.
  • FG26/11 replaces FG14/8 (2014), revised by FG17/2 (2017) and FG25/4 (July 2025); PRA amended its Rulebook and issued a new supervisory statement.
  • PRA and FCA will calculate aggregate high-LTI flow quarterly; PRA publishes the figure with completed mortgage volumes and share.
CSSF CSSF Luxembourg Source document ↗
CSSF Luxembourg Financial Crime ✓ 16 claims 14 Oct 2026

CSSF warns of fraud scheme misusing former name of investment firm CORIENT S.A.

The CSSF has issued a short warning flagging a fraudulent website impersonating a legitimate Luxembourg investment firm by reviving its former name. The item matters for compliance teams tracking impersonation risk and for anyone handling client queries about entities purporting to operate from a Kirchberg address. It is brief and investor-protection focused.

  • CSSF flags fraudulent website www.arche-associes-lu.com reusing the former name "Arche Associés S.A." of investment firm CORIENT S.A.
  • The scheme claims a registered office at 37 b A, Avenue JF Kennedy, L-1855 Luxembourg, and is classified as identity theft and illicit activities.
  • CORIENT S.A., an authorised investment firm, is stated to have no connection to the fraudulent website.
FSB Financial Stability Board Source document ↗
Financial Stability Board Global Governance & Accountability ✓ 13 claims 14 Oct 2026

FSB consults on eight principles for modernising regulatory and supervisory frameworks

The Financial Stability Board has opened consultation on eight high-level principles to guide how financial authorities modernise their regulatory and supervisory frameworks. Addressed to authorities rather than firms, the principles respond to a US G20 Presidency request and carry four framing understandings about resilience and existing standards. This segment covers what is proposed, what remains open, and why the framing matters for regulated institutions.

  • FSB proposes eight high-level modernisation principles addressed to financial authorities, subject to four framing understandings.
  • Work responds to a request from the US G20 Presidency, informed by a member stocktake and a June 2026 symposium.
  • Consultation responses are due by 8 January 2027 and will be published unless respondents request otherwise.
ECB European Central Bank Source document ↗
European Central Bank European Union AI, Technology & Data ✓ 20 claims 13 Oct 2026

ECB's Lane ties US-led AI boom to tighter euro area financial conditions

Philip Lane uses dinner remarks at an AI summit to set out five reasons the ECB is tracking AI, and the one that matters for policy is not productivity. He argues a global AI investment boom Europe does not share is pushing up long-term rates and importing a tightening of euro area financial conditions, while equity and debt valuations pose stability risks.

  • Firms are set to devote around 10% of total investment to AI this year, with AI-related lending accounting for roughly a quarter of recent credit growth to firms.
  • 64% of firms report experimental or moderate AI use and 7% significant use; worker usage reached 52% in 2026 versus 26% in 2024.
  • Lane said the global AI boom is lifting long-term rates, a material tightening of euro area financial conditions relevant to the ECB's policy stance.
BIS BIS Press Releases Source document ↗
BIS Press Releases European Union Digital Assets ✓ 21 claims 13 Oct 2026

ECB's Cipollone sets digital euro course: trilogue by year-end, pilot in 2027, issuance 2029

ECB Executive Board member Piero Cipollone lays out where the digital euro legislation stands, the financial-stability modelling behind holding limits, and how the wholesale Pontes and Appia initiatives fit. For compliance and treasury leads at euro-area banks, this is the clearest consolidated statement of timelines, distribution roles and deposit-outflow assumptions ahead of a potential 2029 first issuance.

  • Trilogue negotiations under way; European Council wants them concluded by end of year, with potential first digital euro issuance in 2029.
  • 12-month pilot begins H2 2027 with 36 payment service providers selected from more than 50 applications; merchant call opened 15 September.
  • Pontes launched 21 September to settle tokenised transactions in central bank money, full implementation expected mid-2028; Appia blueprint due 2028.
DOJ DOJ Criminal Division Source document ↗
DOJ Criminal Division United States Financial Crime ✓ 20 claims 13 Oct 2026

DOJ, NCA and tech firms remove 3.7 million scam accounts in West Africa disruption week

The Justice Department reported the results of a week-long international operation targeting scam centres in West Africa. For compliance leads at payments firms, exchanges and platforms, the notable feature is the roster of private-sector participants that voluntarily acted on their own networks, and the explicit call for more proactive industry disruption. This segment covers who took part, what was seized, and the obligations the model implies.

  • Industry partners reported removing more than 3.7 million accounts, Pages and Groups and sharing leads on over 30 suspected scam centres.
  • Authorities made 28 arrests — 19 in Ghana's Sasaabi suburb and nine in Nigeria — and identified at least $11 million in potentially freezable funds.
  • Ghana operation identified 117 trafficking victims pending repatriation to Nigeria and 89 scam victims with approximately $8.3 million in losses.
ESMA ESMA Source document ↗
ESMA European Union Governance & Accountability ✓ 15 claims 13 Oct 2026

ESAs name DORA oversight, AI and private credit among 2027 joint priorities

The three European Supervisory Authorities have published their Joint Committee work programme for 2027. It signals where cross-sectoral supervisory attention will fall next year: critical ICT third-party oversight under DORA, the implications of AI, consumer protection, sustainable finance and securitisation. This is the forward map of coordinated EU supervision, and the point at which firms can see which shared files the three authorities intend to push together.

  • The Joint Committee of the EBA, EIOPA and ESMA published its Annual Work Programme for 2027 on 13 October 2026.
  • Priorities include digital operational resilience under DORA, AI and technological innovation, consumer protection, sustainable finance and securitisation.
  • The programme aligns with the Commission's Savings and Investment Union objectives and a simplification agenda to reduce regulatory burden.
FMA FMA Austria Source document ↗
FMA Austria Digital Assets ✓ 13 claims 09 Oct 2026

FMA to enforce ESMA's three-month deadline on CASP services tied to non-MiCAR stablecoins

ESMA issued an Opinion on 8 October 2026 telling MiCAR-authorised CASPs to stop offering services linked to stablecoins that do not comply with MiCAR. Austria's FMA has confirmed it will apply those expectations in supervision and police a remediation deadline. This segment covers who is bound, what services are caught, and the clock that is now running.

  • ESMA published its Opinion on non-MiCAR-compliant ARTs and EMTs on 8 October 2026; the FMA will apply it in supervision.
  • MiCAR-authorised CASPs should not provide any covered service linked to non-compliant stablecoins to EU clients, standalone or combined.
  • Existing positions must be remediated as quickly as possible, no later than three months from the Opinion's publication date.
FSB Financial Stability Board Source document ↗
Financial Stability Board Global Digital Assets ✓ 11 claims 12 Oct 2026

FSB maps cross-border stablecoin vulnerabilities, flags gaps in monitoring data

The Financial Stability Board has published a note summarising its monitoring work on global stablecoin arrangements. It sets out how these arrangements are structured, how vulnerabilities could propagate across borders, which metrics could support financial stability monitoring, and what data is actually available today. For compliance and policy teams tracking the FSB crypto framework, it signals where supervisory attention and data demands are heading.

  • FSB argues a single jurisdiction cannot fully assess or address cross-border vulnerabilities in global stablecoin arrangements that span multiple entities and authorities.
  • The note analyses arrangement structure, vulnerability propagation, and metrics for financial stability monitoring, plus the benefits and limitations of available data sources.
  • Delivered by FSB Chair Andrew Bailey on 12 October 2026 alongside finalised sound practices on AI adoption.
FSB Financial Stability Board Source document ↗
Financial Stability Board Global AI, Technology & Data ✓ 15 claims 12 Oct 2026

FSB submits AI, stablecoin and resolution reports to G20 ahead of Bangkok meeting

The Financial Stability Board has delivered a package of reports to G20 Finance Ministers and Central Bank Governors ahead of their 15 October meeting in Bangkok. This segment unpacks what the bundle contains, including finalised AI sound practices, a stablecoin monitoring note and a peer review finding gaps in public sector backstop funding, and what each signals for the FSB's 2027 agenda.

  • FSB transmitted finalised AI sound practices, a modernisation consultation, an implementation monitoring review and a backstop funding peer review to the G20.
  • A note on global stablecoin arrangements proposes enhanced cross-border monitoring and support for implementing the 2023 recommendations.
  • The backstop funding peer review finds further work needed to complete implementation of Key Attribute 6 for resolving large systemic banks.
FCA FCA Source document ↗
FCA United Kingdom Financial Crime ✓ 18 claims 13 Oct 2026

Two from Nexus advice firms plead guilty to fraud after clients lose £2m

A short item on an FCA criminal prosecution reaching guilty pleas. Two senior figures at two authorised advice firms have admitted defrauding four clients of £2m over four years, using false documents. The segment covers what was admitted, the firms' permissions, the FCA's intervention timeline and the confiscation action now coming.

  • Nelson and Stephens pleaded guilty on 12 October 2026 to defrauding four clients of £2m between January 2019 and January 2023 using false documents.
  • Nelson, the firms' director, also admitted a money laundering offence under the Proceeds of Crime Act; the FCA will seek confiscation.
  • The FCA restricted both Nexus firms from regulated activity on 25 January 2023; the High Court placed them into administration on 26 January 2023.
FCA FCA Source document ↗
FCA United Kingdom Financial Crime ✓ 14 claims 12 Oct 2026

FCA wins confiscation orders against two men convicted over £1.5m crypto fraud

The FCA has secured Proceeds of Crime Act confiscation orders against two men already jailed for a cold-calling cryptoasset investment scam. This item covers what each must repay, the enforcement timeline, and the mechanism by which victims recover losses — a reminder of how long the asset-recovery tail runs after conviction.

  • Southwark Crown Court ordered Bedi to pay £603,404.28 and Mavanga £247,997.99 on 28 September 2026.
  • At least 65 investors lost £1,541,799 in a scheme run via CCX Capital and Astaria Group LLP between February 2017 and June 2019.
  • Non-payment within three months exposes Bedi to up to five further years' imprisonment and Mavanga up to two.
OCC OCC Bulletins Source document ↗
OCC Bulletins United States Prudential & Capital ✓ 19 claims 12 Oct 2026

OCC issues version 3.0 of Concentrations of Credit examiner handbook

The OCC has replaced version 2.0 of its Concentrations of Credit booklet with a reorganised version 3.0, used by examiners across all OCC-supervised banks. The threshold definition is unchanged, but the handling of securitizations, correlations and aggregate risk assessment is expanded. This short segment covers what moved, what the definition still is, and what examiners will be working from.

  • Version 3.0 replaces version 2.0 and rescinds OCC Bulletin 2020-90, which had transmitted the earlier version.
  • The concentration definition is unchanged: obligations exceeding 25 percent of tier 1 capital plus allowance for credit losses.
  • New content covers securitizations, the correlation-concentration relationship, and determining aggregate risk.
FED Federal Reserve Source document ↗
Federal Reserve United States Prudential & Capital ✓ 11 claims 12 Oct 2026

Fed extends comment period on Regulation O insider-lending overhaul to November 4

The Federal Reserve has given interested parties an extra month to comment on its proposal to modernize Regulation O, the rule governing loans banks make to their executives, directors and principal shareholders. This segment covers the mechanics of the extension and what it signals about the proposal's contested substance, which remains open for input until November 4.

  • The Federal Reserve extended the Regulation O comment period to November 4, 2026, from an original deadline of October 5.
  • The proposal modernizes the rule governing extensions of credit by banks to insiders: executives, directors and principal shareholders.
  • The Board said it granted the extension to allow interested parties more time to analyze the issues and prepare comments.
FED Federal Reserve Source document ↗
Federal Reserve United States Digital Assets ✓ 14 claims 12 Oct 2026

Fed opens comment on two GENIUS Act rules for Board-supervised stablecoin issuers

The Federal Reserve has put out two proposals building the framework for payment stablecoin issuers it supervises under the GENIUS Act. One covers reserve backing, capital, risk management and custody of backing assets; the other sets a tailored application, appeals and hearing process for banks seeking to issue. Comment runs 60 days from Federal Register publication. This segment covers what each proposal binds and where the pressure points sit.

  • First proposal requires full reserve backing with permissible assets, standardized capital for credit and operational risk, and custody rules for backing assets.
  • Second proposal sets a tailored application process for Board-supervised banks to issue stablecoins, with appeals, hearings and final determinations.
  • Comment period closes 60 days after publication in the Federal Register; Governor Barr issued a separate statement.
ECB European Central Bank Source document ↗
European Central Bank European Union Prudential & Capital ✓ 13 claims 12 Oct 2026

ECB tightens collateral rules, moving to second-best ratings for private assets from November

The ECB has published amendments to its monetary policy implementation and haircut guidelines, consolidating four separately announced decisions into binding form effective 30 November 2026. The changes touch how private sector collateral is rated, how haircuts are calibrated, and which COVID-era instruments remain eligible. Treasury and collateral teams at euro area banks need to know what posts, at what haircut, from when.

  • Second-best external rating replaces first-best for private sector collateral from 30 November 2026; euro area public sector assets retain the first-best rule.
  • Haircut schedule updated, refining own-used or retained assets and adding granularity to individual credit claims by amortisation type.
  • COVID-19 guaranteed credit claims eligible only until end-2026; NFC financial subsidiaries reassigned to haircut category III.
BOE Bank of England Source document ↗
Bank of England United Kingdom Digital Assets ✓ 16 claims 12 Oct 2026

Bank of England board consults on design of next-generation UK retail payments infrastructure

The Retail Payments Infrastructure Board has opened a consultation that will shape the blueprint for Britain's next-generation retail payments system. It covers the payment journeys, design choices and functionality the new infrastructure should support, from account-to-account payments at the point of sale to enhanced cross-border flows. The output feeds a new industry-led Delivery Company. Responses close 11 September 2026.

  • RPIB consultation seeks views on payment journeys, design choices and priorities for the UK's next-generation retail payments infrastructure; responses close 11 September 2026.
  • Proposed functionality includes account-to-account payments at the point of sale as an additional option to cards, and enhanced cross-border payments.
  • A new industry-led Delivery Company will own and deliver the core infrastructure; Pay.UK continues running existing systems including Faster Payments, Bacs and the Image Clearing System.
BOE Bank of England Source document ↗
Bank of England United Kingdom Digital Assets ✓ 18 claims 12 Oct 2026

Bank of England sets £40bn issuance cap for systemic stablecoins, drops holding limits

The Bank of England has published its policy statement and draft Code of Practice for systemic sterling stablecoin issuers, revising two central proposals from its 2025 consultation. It swaps per-holder limits for a per-coin issuance guardrail and loosens backing-asset rules. This segment covers what changed, the timeline to finalisation, and how the regime splits from the FCA's.

  • Maximum backing held in interest-bearing short-term UK government debt rises from 60% to 70%, with the remainder in central bank deposits.
  • Consulted per-holder holding limits are dropped; a temporary per-coin issuance guardrail applies, initially set at £40 billion and reviewed regularly.
  • Feedback closes 22 September 2026; the Bank intends to finalise the Code by end-2026, allowing regulated stablecoins to operate from 2027.
CFTC CFTC — Commodity Futures Trading Commission Source document ↗
CFTC — Commodity Futures Trading Commission United States Digital Assets ✓ 13 claims 12 Oct 2026

CFTC opens comment on crypto asset market framework under existing commodity authority

The CFTC has published an Advanced Notice of Proposed Rulemaking on how it would regulate retail crypto asset transactions under section 2(c)(2)(D) of the Commodity Exchange Act. This segment covers what the agency is asking, the new registration category it is floating, and the 60-day clock now running for anyone who wants to shape the eventual rules.

  • CFTC issued an ANPRM on retail crypto asset transactions under CEA section 2(c)(2)(D), published 5 October 2026.
  • It floats codifying a "crypto asset market" as a subcategory of designated contract market registration purpose-built for crypto transactions.
  • Comments are due within 60 days of Federal Register publication; the notice informs potential future rulemaking rather than proposing rules.
FED Federal Reserve Source document ↗
Federal Reserve United States Prudential & Capital ✓ 12 claims 12 Oct 2026

US bank agencies propose replacing third-party risk guidance with principles-based framework

The Fed, FDIC, OCC and NCUA jointly proposed new third-party risk management guidance that would replace current standards when finalized. The package includes a companion guide for Federal Reserve-supervised community banks and a statement on supervisory treatment of core service provider relationships. This segment covers what the proposal changes, what stays non-binding, and the comment timeline firms need to track.

  • Four agencies propose principles-based, non-binding third-party risk management guidance intended to replace existing guidance once finalized.
  • Comments are due 60 days after Federal Register publication; the Fed added a companion guide for its supervised community banks.
  • A separate joint statement addresses factors the agencies will consider on community banks' core service provider relationships.
ECB European Central Bank Source document ↗
European Central Bank European Union Digital Assets ✓ 23 claims 12 Oct 2026

ECB's Cipollone sets 2029 digital euro target as trilogue nears deadline

Piero Cipollone laid out the ECB's full digital money strategy: a retail digital euro moving through trilogue, and the wholesale Pontes and Appia initiatives for tokenised settlement. The speech matters for the fresh financial-stability modelling on holding limits and for the concrete 2027 pilot and 2029 issuance timeline banks now need to plan against.

  • ECB aims for potential first digital euro issuance in 2029 if legislation concludes by end-2026; trilogue is under way with a Council push to finish this year.
  • Modelling of 2,025 banks shows holding limits up to €3,000 leave aggregate LCR at 163% and project a €127bn deposit inflow by 2034 under business-as-usual.
  • Pontes launched 21 September to settle tokenised transactions in central bank money, full implementation mid-2028; Appia blueprint targeted for 2028.
ESMA ESMA Source document ↗
ESMA European Union Digital Assets ✓ 11 claims 12 Oct 2026

ESMA tells MiCA-licensed crypto firms to stop serving non-compliant stablecoins

ESMA has issued an opinion drawing a hard line around stablecoins that do not meet MiCA. It tells authorised crypto-asset service providers to cease offering any MiCA service connected to non-compliant asset-referenced and e-money tokens, and directs national regulators to enforce controls and clear legacy exposures within three months. This segment covers what binds, the carve-outs, and the compliance clock.

  • Authorised CASPs must cease all MiCA services linked to non-MiCA-compliant ARTs and EMTs for EU clients.
  • NCAs must require remediation of pre-existing exposures within three months of the 8 October 2026 opinion.
  • Residual activity is confined to liquidation, conversion, withdrawal, transfer or safekeeping, time-limited and supervised.
CFPB CFPB Source document ↗
CFPB United States Governance & Accountability ✓ 11 claims 11 Oct 2026

Nine US financial regulators finalise joint data standards under 2022 transparency law

Nine federal financial regulators, from the SEC to the Fed and CFPB, have finalised the joint data standards mandated by the Financial Data Transparency Act of 2022. The rule fixes common identifiers and transmission formats so filings become interoperable across agencies. This segment covers what the rule binds and the practical reporting work it sets in motion for regulated firms.

  • Joint final rule adopts uniform technical standards for data reported to nine US financial regulators, as required by the Financial Data Transparency Act of 2022.
  • Standards establish common identifiers for entities, geographic locations, dates, and certain products and currencies.
  • A principles-based joint standard covers data transmission and schema and taxonomy formats to enable machine-readable submissions.
SRB Single Resolution Board Source document ↗
Single Resolution Board European Union Digital Assets ✓ 14 claims 11 Oct 2026

SRB flags resolution gaps for stablecoins in response to Commission's MiCA review

The Single Resolution Board has told the European Commission that the current MiCA framework leaves resolution authorities short of tools and information when stablecoin activity threatens credit institutions. This segment covers what the SRB is asking for, the four bank roles it has identified, and why the interaction between MiCA and the EU resolution rulebook is now on the table.

  • SRB says non-credit stablecoin issuers lack a dedicated resolution regime for systemic activity, beyond some supervisory and recovery measures.
  • It wants data-sharing, supervisor-resolution coordination and alignment of MiCA with BRRD and SRMR on reserves, segregation and depositor protection.
  • The response focuses on credit institutions as token issuers and as institutions funded by issuers and crypto-asset service providers.
SFC SFC Hong Kong Source document ↗
SFC Hong Kong Financial Crime ✓ 18 claims 11 Oct 2026

SFC fines Zheng Da $7 million over client-supplied trading systems and AML control gaps

The SFC fined a Hong Kong futures broker and suspended its responsible officer over anti-money-laundering failures tied to client-supplied trading systems connected via API. Worth a few minutes to see how CSS-through-API arrangements and the Manager-In-Charge regime are being enforced, and why carrying on despite peer enforcement aggravated the outcome.

  • Zheng Da reprimanded and fined $7 million for AML/CFT and other failures between 1 December 2021 and 30 September 2023.
  • Responsible officer Zhong Hao suspended for seven months, from 28 September 2026 to 27 April 2027.
  • SFC found no due diligence or testing on customer-supplied systems used by 160 clients, and 176 undetected same-second matched buy/sell orders.