Reg Watch: Global policy moves and deadlines this week

Policy moves this week

• FCA sues HTX over unlawful promotions. The UK regulator filed a civil claim in London alleging that HTX, formerly Huobi, breached Britain’s financial promotions regime by marketing to UK consumers without authorization.
• SEC operations curtailed by funding lapse. The SEC states it is operating with very limited staff under its shutdown plan effective October 1, 2025, while keeping EDGAR running. See the SEC’s homepage notice and meeting calendars for status context.
• CFTC posts its own shutdown procedures. The Commission issued a notice on September 30, 2025 describing how it will continue, suspend, and resume operations during a lapse in appropriations, and published its plan in the Federal Register.
• ESMA MiCA market abuse guidelines now in force at the NCA level. ESMA’s July 2025 guidelines require national authorities to notify ESMA within two months of the official translations whether they comply. See ESMA’s guideline PDF and a regulator posting of the same text.
• EBA flags transitional risk behaviors under MiCA. A new EBA report highlights cases where firms rejected for MiCA authorization continue operating under national regimes while appeals are pending, increasing supervisory risk.
• MAS status check. Singapore’s Digital Token Service Providers regime under the Financial Services and Markets Act 2022 took effect on June 30, 2025 via subsidiary regulations. See the official legislation text and MAS notices.

Enforcement ledger

• FCA actions around promotions and influencers. This month the FCA confirmed court dates in a finfluencer case and reiterated its campaign against illegal promotions, following a multi-agency crackdown earlier this year.
• CFTC recent penalties and orders. In September, the CFTC announced six settled orders against 10 firms totaling $8.325 million in penalties, part of an enforcement “sprint” realignment.

MiCA implementation watch

• Supervision playbooks. ESMA’s market abuse guidelines under MiCA require data-driven surveillance across spot crypto markets and venues. Firms should map triggers, order-book patterns, and off-venue signaling that fall within the new scope.
• Forthcoming reports. ESMA and EBA must deliver the first Article 141 report on MiCA’s application by December 31, 2025. Trackers summarize the pipeline of Level 2 and 3 measures and statutory reports.

Deadlines coming due

• FCA CP25/25. The FCA’s consultation on applying the Handbook to regulated cryptoasset activities closed discussion chapters on October 15, 2025. The main consultation closes November 12, 2025.
• EBA consultations. Multiple EBA papers close October 29–31 and November 7, 2025 across reporting, branches, and governance, which can affect crypto-exposed banks and e-money groups. See the EBA consultations list for dates.
• US operational caveat. With the SEC operating under its shutdown plan since October 1, firms should expect delayed staff interactions, even though EDGAR filings continue.

What companies should do now

• UK marketing controls. If you market to UK users, audit crypto promotions against the FCA financial promotions rules and pause unapproved affiliate or influencer campaigns. Keep HTX litigation in mind as a risk marker.
• EU MiCA readiness. Update surveillance for ESMA’s market abuse framework and confirm whether your NCA has notified compliance. If issuing ARTs or EMTs, validate authorization status, reserve governance, and college arrangements per EBA materials.
• Singapore licensing. Map cross-border activity to FSM Act DTSP requirements. If in scope, align with MAS notices and subsidiary legislation that became effective June 30, 2025.
• US contingency. Build extra lead time for SEC interactions during the funding lapse and watch the CFTC site for any comment windows that reopen post-shutdown.