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Articles by Mike Ringer
FCA strengthens safeguarding regime for payments and e-money firms
On 7 August 2025, the Financial Conduct Authority published a policy statement (PS25/12) setting out changes to the safeguarding regime for payments and e-money firms. These changes aim to minimise shortfalls in safeguarded relevant funds, ensure prompt and cost-effective return of funds if a payments firm fails, and enhance the FCA’s ability to identify deficiencies in safeguarding standards. The FCA consulted on the proposed reforms in September 2024.
The DFSA publishes explainer on the regulation of Crypto Tokens in the DIFC
The Dubai Financial Services Authority (“DFSA”) has published a comprehensive explainer (the “Explainer”) on its approach to regulating financial services in respect of “Crypto Tokens” carried on in or from the Dubai International Financial Centre (“DIFC”). We have set out some key takeaways from the Explainer below. 1.
UAE: VARA issues further regulations and guidance on marketing virtual assets and related activities in Dubai
UAE: VARA issues further regulations and guidance on marketing virtual assets and related activities in Dubai 30/09/2024 The Dubai Virtual Assets Regulatory Authority (“VARA”) has published new regulations (the “Regulations”)[1] and accompanying guidance (the “Guidance”)[2] on the marketing of virtual assets (“VAs”) and related activities (“VA Activities”) in... Read more Authors Mike Ringer Partner London Yasmin Johal Associate London
UAE: VARA issues further regulations and guidance on marketing virtual assets and related activities in Dubai
The Dubai Virtual Assets Regulatory Authority (“VARA”) has published new regulations (the “Regulations”)[1] and accompanying guidance (the “Guidance”)[2] on the marketing of virtual assets (“VAs”) and related activities (“VA Activities”) in Dubai (together the “Marketing Regulations”).
New safeguarding regime for payments and e-money firms (FCA CP24/20)
26/09/2024 On 25 September 2024, the FCA published CP24/20 setting out its proposed changes to the safeguarding regime for payments and e-money firms. The consultation closes to comments on 17 December.The changes are likely to present a high compliance burden for many... Read more
UAE: FSRA consults on proposed stablecoin regulatory framework for ADGM
On 20 August 2024, the Financial Services Regulatory Authority (“FSRA”) of the Abu Dhabi Global Market (“ADGM”) published a consultation paper No. 7 of 2024 (“CP”) on its proposed regulatory framework for the issuance of “fiat-referenced tokens” (“FRTs”) from the ADGM. These proposals mark a significant development in the regulation of FRT issuance, which has never been specifically addressed in FSRA legislation until now. We have set out the key proposals below. 1.
UAE: SCA Issues New Guidelines on the Regulation of Virtual Assets and VASPs
UAE: SCA Issues New Guidelines on the Regulation of Virtual Assets and VASPs 12/09/2024 IntroductionThe Securities and Commodities Authority (“SCA”) has published the long awaited guidelines (the “Guidelines”) that supplement its existing legislative framework for virtual assets in the UAE, in particular Cabinet Resolution No. 111 of 2022... Read more Authors Yasmin Johal Associate London
The DFSA publishes explainer on the regulation of Crypto Tokens in the DIFC
The DFSA publishes explainer on the regulation of Crypto Tokens in the DIFC 09/10/2024 The Dubai Financial Services Authority (“DFSA”) has published a comprehensive explainer (the “Explainer”) on its approach to regulating financial services in respect of “Crypto Tokens” carried on in or from the Dubai International Financial Centre... Read more Authors Mike Ringer Partner London Yasmin Johal Associate London
UAE: FSRA consults on proposed stablecoin regulatory framework for ADGM
UAE: FSRA consults on proposed stablecoin regulatory framework for ADGM 13/09/2024 On 20 August 2024, the Financial Services Regulatory Authority (“FSRA”) of the Abu Dhabi Global Market (“ADGM”) published a consultation paper No. 7 of 2024 (“CP”) on its proposed regulatory framework for the issuance of “fiat-referenced tokens”... Read more Authors Mike Ringer Partner London Yasmin Johal Associate London
The new CBUAE Payment Token Services Regulation: 10 things you need to know
08/08/2024 In June 2024, the Central Bank of the UAE (“CBUAE”), the supervisory and regulatory authority of the banking and insurance sector within the United Arab Emirates (“UAE”), published the long awaited Payment Token Services Regulation in Circular No.2 /2024... Read more
The new CBUAE Payment Token Services Regulation: 10 things you need to know
In June 2024, the Central Bank of the UAE (“CBUAE”), the supervisory and regulatory authority of the banking and insurance sector within the United Arab Emirates (“UAE”), published the long awaited Payment Token Services Regulation in Circular No.2 /2024 (the “PTSR”). The publication of the PTSR marks a significant development in the UAE’s regulatory framework for virtual assets. We have highlighted ten key issues below. 1. What activities are within scope of the PTSR?
Digital Securities Sandbox applications now open: our summary of updates and clarifications from the regulators
07/10/2024 On 30 September 2024, the Bank of England (the “Bank”) and Financial Conduct Authority (the “FCA”) (together, the “Regulators”) issued a joint policy statement (the “Policy Statement”) addressing responses to the Digital Securities Sandbox (“DSS”)... Read more
DFSA boosts cryptoasset regime with a number of key amendments
20/06/2024 The Dubai Financial Services Authority (“DFSA”), the financial services regulator for the Dubai International Financial Centre (“DIFC”), has announced further developments to its agile cryptoasset regime following its January 2024 Consultation Paper (the... Read more
DFSA boosts cryptoasset regime with a number of key amendments
19/06/2024 The Dubai Financial Services Authority (“DFSA”), the financial services regulator for the Dubai International Financial Centre (“DIFC”), has announced further developments to its agile cryptoasset regime following its January 2024 Consultation Paper (the... Read more
DFSA boosts cryptoasset regime with a number of key amendments
The Dubai Financial Services Authority (“DFSA”), the financial services regulator for the Dubai International Financial Centre (“DIFC”), has announced further developments to its agile cryptoasset regime following its January 2024 Consultation Paper (the “CP”). The amendments relate to a number of changes to the DFSA rules on funds, custody, financial crime and the recognition of cryptoasset tokens.
Op-Ed: Why EU stablecoin rules threaten to upend crypto markets
Op-ed MiCA risks leaving the $155 billion stablecoin industry fragmented, warn Hugo Coelho and Mike Ringer. The warning comes ahead of new rules taking affect at the end of June. Hugo Coelho is the digital asset regulation lead at the Cambridge Centre for Alternative Finance, and Mike Ringer is a partner and co-lead of Crypto & Digital Assets Group at CMS. Opinions are their own.
A guide to the regulators’ joint consultation on implementing and operating the Digital Securities Sandbox
On 3 April 2024, the Financial Conduct Authority (“FCA”) and Bank of England (“BoE”) published CP24/5, a joint consultation paper (“Consultation Paper”) on a suggested approach to implementing and operating the Digital Securities Sandbox (“DSS”). The DSS offers firms the opportunity to test and innovate with new technologies like distributed ledger technology (“DLT”) in relation to certain financial services activities, such as issuing, trading, and settling securities.
A guide to the regulators’ joint consultation on implementing and operating the Digital Securities Sandbox
28/05/2024 On 3 April 2024, the Financial Conduct Authority (“FCA”) and Bank of England (“BoE”) published CP24/5, a joint consultation paper (“Consultation Paper”) on a suggested approach to implementing and operating the Digital Securities Sandbox (“DSS”).The... Read more
UK Cryptoasset Regulation - 2023 developments and what’s to come in 2024 (Part 1)
2023 will be remembered as the year the cogs of the UK legislative and regulatory machine finally began to crank meaningfully into gear in relation to cryptoassets, with a raft of legislation, consultations and discussion papers published. Through these initiatives, the UK is paving the way for a comprehensive regulatory regime to rival those in other jurisdictions with early-mover advantage, such as the European Union, Dubai, Singapore and Hong Kong.
Law Commission’s draft Digital Assets Bill - welcome news for the UK
27/02/2024 Following an extensive consultation and publication of its final report in June 2023, the Law Commission has now published its draft Digital Assets Bill (the “Bill”). The Bill is designed “to ensure that the law remains dynamic, highly competitive, and flexible... Read more
CMS | Law-Now | UK Fund Tokenisation
11/12/2023 The Investment Association (IA) has published a report with a blueprint for implementing the tokenisation of UK investment funds.The report recommends a phased approach to achieving the ultimate goal of the full investment value chain operating on distributed... Read more
UK Cryptoasset Regulation: Three Key Updates
02/11/2023 On 30 October 2023, HM Treasury (“HMT”) published 3 key updates on its proposed approach to regulating cryptoassets under the UK’s financial services regulatory framework, namely:Response to feedback received on its February 2023 consultation and call for... Read more
UK Cryptoasset Regulation: three key updates
03/11/2023 On 30 October 2023, HM Treasury (“HMT”) published 3 key updates on its proposed approach to regulating cryptoassets under the UK’s financial services regulatory framework, namely:Response to feedback received on its February 2023 consultation and call for... Read more
VARA issues further rules governing staking and stablecoin regulation in Dubai
Dubai’s Virtual Assets Regulatory Authority (“VARA”) has recently introduced two significant updates to its virtual assets regulatory framework, which is relevant for all entities providing services to or from Dubai, other than entities conducting business in the Dubai International Financial Centre ( “DIFC”). For an overview of VARA’s virtual assets framework, please refer to our previous articles here and here.
VARA issues further rules governing staking and stablecoin regulation in Dubai
03/10/2023 Dubai’s Virtual Assets Regulatory Authority (“VARA”) has recently introduced two significant updates to its virtual assets regulatory framework, which is relevant for all entities providing services to or from Dubai, other than entities conducting business... Read more
Banking portfolio transfers: Key commercial and legal issues | Lexology
Summary 1. No statutory transfer mechanism in Hong Kong – need contract-by-contract transfers 2. Early communication between IT teams is key – to plan and manage data mapping process and transfer process (including ensuring compliance with data privacy rules) 3. Early communication with HKMA is key – to settle what client consents are required 4.
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