The GRC Navigator
Your Bi-Weekly GRC Intelligence Briefing
Executive Summary
The FCA published 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.
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 rules for cryptoasset activities and setting out the UK’s approach to digital asset regulation.
- 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. The FCA builds on existing frameworks while writing bespoke requirements for the risks specific to 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.
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of approximately 11,000 requirements, directions and limitations affecting over 9,000 firms, following discovery of outdated or erroneous data.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- Review addresses data accuracy and superseded content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) revises 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, 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 for the firm’s buyout funds.
- 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, in a growing 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, as LPs increasingly seek fee-efficient co-investment 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, opens the way for a large 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
Specialised 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, 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
- 3 June: PS25/5 enforcement disclosure policy takes effect
- 29 June: EU SFT transitional treatment permanence deadline
- 30 June: BNPL temporary permissions open; FCA Derivatives Trading Obligation changes
July 2025
- 31 July: FCA cryptoasset consultation closes; Portfolio manager enhanced reporting deadline
August 2025
- Summer 2025: FCA insurance market study interim report expected
March 2026
- 1 March: PRA international branch reporting rules take effect
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?
Insight
The FCA’s move to disclose certain enforcement investigations immediately changes how the regulator handles confidentiality. Alongside the new cryptoasset framework and the amendment of 11,000 firm requirements, the FCA is widening its perimeter and demanding more transparency at the same time. For firms, this means that as crypto rules and tougher international supervision add complexity, the cost of a compliance failure becomes public the moment an investigation opens. Compliance systems alone are no longer enough; firms also need real-time crisis management. Quiet remediation is no longer an option.