Payments, E-Money And Crypto-Assets:- Quarterly Legal And Regulatory Update

The European Commission has published an Action Plan addressing the dual-edged nature of frontier artificial intelligence models in cybersecurity, outlining how the EU will harness AI's defensive capabilities while protecting against AI-powered cyber threats. Through nine key actions spanning 2026-2027, the plan establishes frameworks for safe AI evaluation, structured access to advanced AI capabilities, and the scaling of European sovereign AI cybersecurity solutions across critical infrastructure sectors.

The European Commission has published comprehensive guidelines on AI transparency obligations under Article 50 of the EU AI Act, with enforcement beginning August 2, 2026. These guidelines establish how organizations must disclose AI systems, mark synthetic content, label deepfakes, and demonstrate compliance, with significant penalties for non-compliance reaching up to €15 million or 3% of global turnover.

Ireland has established the AI Office as its central coordinating authority under the EU AI Act, introducing a comprehensive regulatory framework that includes sector-based supervision, enforcement powers, and administrative fines reaching up to €35 million. The new legislation empowers market surveillance authorities like the Central Bank and Data Protection Commission to oversee AI compliance while creating a regulatory sandbox to foster innovation within legal boundaries.

The Cyber Resilience Act (Regulation (EU) 2024/2847)1 (“CRA”) establishes horizontal cybersecurity requirements for products with digital elements (“PDEs”) placed on the European Union (“EU”) market. Reporting obligations took effect on 11 September 2026, with full application of the CRA from 11 December 2027.

The European Union has reached a political agreement to amend the AI Act, introducing targeted changes aimed at simplifying compliance requirements for businesses while maintaining protective standards.

The Irish Government has published the Regulation of Artificial Intelligence Bill 2026, establishing Ireland's framework for implementing the EU AI Act. This landmark legislation creates the AI Office of Ireland as an independent statutory entity and designates existing sectoral authorities to oversee AI regulation within their domains. The Bill introduces a comprehensive administrative sanctions regime and enforcement toolkit while reflecting Ireland's National Digital and AI Strategy.

The Court of Justice of the European Union has delivered landmark judgments that fundamentally reshape how online platforms can claim immunity from liability for user-generated content. These decisions establish that algorithmic content distribution and commercial partnerships with creators may strip platforms of their safe harbour protections, forcing a reassessment of how social media companies, video-sharing services, and digital marketplaces structure their operations and revenue models.

The text remains subject to formal endorsement by both institutions and to legal-linguistic revision before adoption, with publication in the Official Journal expected ahead of the original...

On 19 November 2025, the European Commission published its proposed Digital Omnibus Package, a reform aimed at overhauling significant parts of the European Union's digital regulatory framework.

The EU Cyber Resilience Act introduces mandatory reporting obligations for manufacturers of digital products, requiring them to notify authorities within 24 hours of discovering actively exploited vulnerabilities or severe security incidents. This regulation establishes strict timelines for early warnings, detailed vulnerability notifications, and final reports, fundamentally changing how manufacturers must respond to cybersecurity threats.

The Supreme Court, in Delaney v The Personal Injuries Assessment Board, the Judicial Council, Ireland and the Attorney General [2024] IESC10, has upheld the legality...

The Cayman Islands Monetary Authority has introduced sweeping changes to anti-money laundering audit requirements for investment funds, mandating independent audits of entire compliance programmes by September 2026. This marks a fundamental departure from previous practice where internal AML officers could conduct their own testing, raising critical questions about implementation timelines, qualified auditor availability, and compliance costs for funds operating in the jurisdiction.

Ireland's Budget 2027 introduces a lower exit tax rate for fund investors, clearer rules for Irish ETFs, and a new Retail Investment Account, while leaving the controversial eight-year deemed disposal rule unchanged. The package also includes Pillar Two updates, interest relief reforms, and a capital gains tax reduction, offering targeted refinements for the financial services sector rather than the fundamental reform many had anticipated.

The EU Retail Investment Strategy is a legislative package which introduces significant changes to the UCITS Directive and AIFMD, as well as MiFID II, the Insurance Distribution Directive and the Solvency II Directive via an omnibus directive (Omnibus Directive).

The European Union has reached a political agreement to amend the AI Act, introducing targeted changes aimed at simplifying compliance requirements for businesses while maintaining protective standards.

Ireland has introduced significant amendments to its beneficial ownership registers in 2026, implementing the Sixth Anti-Money Laundering Directive (AMLD6) framework. These reforms fundamentally restructure access rights to the Central Register of Beneficial Ownership of Trusts and Corporate Entities, moving away from unrestricted public access toward a tiered system that balances transparency with privacy rights while maintaining accessibility for legitimate anti-money laundering purposes.

The Listing Act Directive introduces significant reforms to the MiFID II research regime, allowing investment firms greater flexibility in paying for research and execution services. This briefing examines how the removal of market capitalisation thresholds restores bundling as a commercial option and establishes a new EU framework for issuer-sponsored research.

The European Commission's proposed overhaul of the SFDR regime is entering crucial trialogue negotiations, with the Irish Presidency aiming to reach agreement by year-end. While the Council and Parliament have aligned on key issues like professional investor opt-outs, significant divergences remain on exclusion criteria for Transition funds, PAI reporting requirements, and engagement strategy disclosures that will shape the future of sustainable finance regulation.

Following President Trump's recent confirmation that U.S economic sanctions on Iran will be reinstated, Muireann Reedy looks at the penalties ...

As widely anticipated on 10 September 2019, mainland China's foreign exchange regulator, the State Administration of Foreign Exchange, confirmed that existing restrictions on both QFII and RQFII schemes have been abolished.