THE GRC NAVIGATOR

Your Bi-Weekly GRC Intelligence Briefing

Issue 3 | 5 June 2025

Executive Summary

The FCA unveiled comprehensive proposals for cryptoasset regulation, including new sourcebooks for stablecoin issuance and custody requirements. The regulator also announced it will amend 11,000 requirements across 9,000 firms following a data accuracy review. Meanwhile, the UK Government published its final Pensions Investment Review, setting the stage for a £50bn shift into private markets. The ECB’s eighth consecutive rate cut continues to widen monetary policy divergence, while the EU’s 17th sanctions package against Russia adds 189 vessels to the shadow fleet ban. In enforcement, the FCA’s new disclosure policy for investigations takes immediate effect, marking a significant shift in regulatory transparency.

Top Story: FCA Launches Comprehensive Cryptoasset Regulatory Framework

DIGITAL ASSETS, BANKING, ASSET MANAGEMENT

The Financial Conduct Authority published two major consultation papers on May 28, 2025, proposing comprehensive rules for cryptoasset activities, marking the UK’s most significant step toward digital asset regulation.

KEY ELEMENTS INCLUDE:

◆ CP25/14 introduces bespoke CASS-based requirements for safeguarding qualifying cryptoassets

◆ New Cryptoasset sourcebook (CRYPTO) to consolidate sector-specific rules

◆ CP25/15 establishes prudential requirements through new COREPRU and CRYPTOPRU sourcebooks

◆ Firms must ensure cryptoassets are “effectively secured and easily accessed at any time”

◆ Consultation closes July 31, 2025, with final rules expected in 2026

The proposals follow HM Treasury’s April 2025 draft statutory instrument and represent a fundamental shift in UK crypto regulation. The FCA’s approach uses existing frameworks as a foundation while creating bespoke requirements for the unique risks of digital assets.

“These proposals would require firms providing cryptoasset custody services to ensure they are effectively secured and can be easily accessed at any time,” the FCA stated, emphasizing consumer protection alongside market integrity.

Regulatory Updates

FCA to Amend 11,000 Requirements Across 9,000 Firms

ALL FINANCIAL SERVICES

The FCA announced on May 29, 2025, a comprehensive review and amendment of approximately 11,000 requirements, directions and limitations affecting over 9,000 firms, following discovery of outdated or erroneous data.

◆ Immaterial updates will be made automatically without firm intervention

◆ Substantive changes require direct FCA contact with affected firms

◆ Review addresses data accuracy and superseded content

◆ Firms need not take action unless contacted directly

◆ Process expected to complete over several months

PRA Updates International Firm Supervision Framework

BANKING, CROSS-BORDER

The PRA’s PS6/15 (May 20, 2025) introduces significant changes to international banking supervision:

◆ Branch deposit thresholds raised to £130m (standard) / £650m (enhanced)

◆ Subsidiary requirements triggered above £300m UK liabilities

◆ Enhanced proportionality for systemic importance assessment

◆ Streamlined authorization for qualifying jurisdictions

◆ Implementation begins March 1, 2026

EU Adopts 17th Russia Sanctions Package

ALL

The EU’s latest sanctions package, adopted May 20, 2025, significantly expands maritime restrictions:

◆ 189 vessels added to shadow fleet ban (total now 342)

◆ Enhanced due diligence for firms using third-country intermediaries

◆ New “No Re-Export to Russia” contractual requirements

◆ Expanded technology transfer restrictions

◆ UK firms face growing UK-EU sanctions divergence challenges

PRA Developments

PS7/25: SME Lending Capital Adjustments

Published May 22, 2025, the PRA’s policy statement recalibrates SME lending requirements:

◆ Removal of Pillar 1 support factors for SME exposures

◆ Offsetting adjustments through Pillar 2A capital buffers

◆ Net neutral impact on overall capital requirements
– Simplified reporting for smaller institutions

Pillar 3 Data Hub Implementation

The EBA published onboarding plans on May 22, 2025:

◆ Centralised platform for CRR disclosures under CRR III

◆ Public access from December 2025

◆ Institutions must complete onboarding process

◆ FAQs published to assist implementation

Securities Financing Transaction Permanence

EU Parliament and Council published text May 23-29, 2025:

◆ Current transitional SFT treatment under NSFR made permanent

◆ Applies to transactions under six months maturity

◆ Implementation from June 29, 2025

◆ Addresses industry concerns about funding stability

Fund Launches & Capital Raises

Inflexion Raises Record £2.3 Billion Continuation Fund

Thoma Bravo Raises Record $34.4bn Across Software Funds

INFO
SECTORS: PRIVATE EQUITY, TECHNOLOGY

Thoma Bravo completed one of the largest software-focused fundraising efforts on June 4, 2025, securing more than $34.4bn across three private equity funds, surpassing all targets and underscoring sustained LP appetite for the firm’s high-conviction buyout strategy.

◆ Largest software-focused PE fundraise in recent years

◆ Demonstrates continued institutional confidence in tech buyouts

◆ GPIF separately committed $500m to Thoma Bravo vehicle (May 21)

◆ Signals resilience in PE fundraising despite broader market challenges

Goldman Sachs Targets Record Secondary Fund

INFO
SECTORS: PRIVATE EQUITY, SECONDARIES

Goldman Sachs Asset Management is preparing to launch its largest-ever PE secondaries fund on June 3, 2025, seeking to surpass the $14.2bn raised for its predecessor, capitalizing on the booming secondary market.

◆ Would be among the largest secondary funds ever raised

◆ Reflects institutional need for liquidity solutions

◆ Builds on Yale’s $2.5bn secondary sale momentum

◆ Secondary market providing critical exit routes for LPs

Carlyle’s AlpInvest Closes $4.1bn Co-Investment Fund

INFO
SECTORS: PRIVATE EQUITY, CO-INVESTMENTS

AlpInvest Partners secured $4.1bn for its ninth dedicated co-investment vehicle (ACF IX) on June 4, 2025, marking significant uptick in co-investment appetite as LPs seek fee-efficient exposure.

◆ AlpInvest also tapping structured finance with separate $1bn CFO (May 21)

◆ Co-investment strategies gaining favor for lower fees

◆ Direct deal participation increasingly important for LPs

◆ Reflects evolution in LP-GP partnership models

UK Pensions Target £50bn Private Markets Shift

INFO
SECTORS: PENSIONS, ALTERNATIVES

The UK Government’s final Pensions Investment Review, published May 29, 2025, paves the way for massive reallocation to alternatives:

◆ DC consolidation measures to enable illiquid investments

◆ New long-term asset funds (LTAF) gaining traction

◆ Minimum scale requirements with 2035 transition pathway

◆ Market fragmentation review scheduled for 2029

Asia Healthcare and Infrastructure Attract Capital

INFO
SECTORS: HEALTHCARE, INFRASTRUCTURE

Despite global fundraising challenges, specialized strategies continue to attract capital:

◆ Quadria Capital closed oversubscribed $1.07bn Asia healthcare fund (May 27)

◆ Exceeded $800m target with additional $300m co-invest capacity

◆ Apollo secured $1bn private credit for PowerGrid acquisition (May 20)

◆ Sinopec launched $690m hydrogen-focused VC fund (June 2)

Enforcement Watch

FCA Implements New Investigation Disclosure Policy

ALL FINANCIAL SERVICES

PS25/5, effective June 3, 2025, fundamentally changes enforcement transparency:

◆ Immediate disclosure of enforcement investigations in certain cases

◆ Significant departure from historical confidentiality approach

◆ Firms must prepare crisis communications strategies

◆ Market abuse and consumer harm cases prioritized

◆ Enhanced reputational risk management required

Former Credit Suisse VP Banned for Mozambique Corruption

BANKING

The FCA banned Detelina Subeva on May 23, 2025:

◆ Third former Credit Suisse employee banned over Mozambique loans

◆ US conviction for money laundering conspiracy

◆ $200,000 in unlawful kickbacks accepted

◆ Part of $475m global settlement from 2021
◆ Reinforces individual accountability focus

Basset & Gold Complaints Decision Published

CONSUMER CREDIT

FCA published decision letter May 29, 2025:

◆ Upholds complaints about BGF authorization and supervision failures

◆ No redress as FCA not direct cause of losses

◆ £200 ex-gratia payment for response delays

◆ Mini-bond sector scrutiny continues

Market Developments

ESMA Targets Social Media Financial Promotions

INFO
SECTORS: ALL FINANCIAL SERVICES

ESMA wrote to major platforms on May 28, 2025:

◆ Letters sent to X, Meta, TikTok, Alphabet, Telegram, others

◆ Collaboration sought on unauthorized promotion prevention

◆ Links to IOSCO’s May 21 global initiative

◆ Platforms encouraged to verify MiFID II authorization

◆ UK firms should monitor cross-border implications

Insurance Market Study Progress

INFO
SECTORS: INSURANCE

FCA responds to Which? petition May 29, 2025:

◆ Interim report on monthly payment fairness due summer 2025

◆ Home and travel claims handling review planned

◆ Motor premium increases under investigation

◆ Consumer Duty enforcement focus confirmed

BNPL Regulation Timeline Clarified

HIGH RISK
SECTORS: CONSUMER CREDIT, FINTECH

Implementation schedule following May 19 legislation:

◆ June 30, 2025: Temporary permissions applications open

◆ December 31, 2025: Affordability check systems operational

◆ Mid-2026: Full regulatory regime in force

◆ Section 75 protections to apply to BNPL transactions

Regulatory Calendar

June 2025

July 2025

August 2025

March 2026

Question of the Week

With the FCA’s new enforcement investigation disclosure policy taking immediate effect and comprehensive cryptoasset regulations on the horizon, how should firms balance transparency obligations with reputational risk management while preparing for fundamental changes to their regulatory perimeter?

Share your insights on navigating these converging challenges.

Insight: The Regulatory Transparency Revolution

The FCA’s decision to implement immediate disclosure of certain enforcement investigations represents more than a policy shift—it signals a fundamental change in the UK’s regulatory philosophy. Combined with the comprehensive cryptoasset framework and the data-driven amendment of 11,000 firm requirements, we’re witnessing a regulator simultaneously expanding its perimeter while demanding unprecedented transparency. This creates a paradox for firms: just as regulatory complexity increases with new crypto rules and enhanced international supervision frameworks, the cost of compliance failures becomes immediately public. The message is clear: in this new era, firms must invest not just in compliance systems but in real-time crisis management capabilities. The days of quiet remediation are ending.

Artizan Governance

Artizan Governance