Egypt – Update 2026

out of Credit Institution’s Country of Establishment (Def, BT & Def)

Regulatory Template, Behaviour Template and Definitions and Concepts

Material changes

The Country Manual has been reviewed to ensure that the content of all documents remains accurate and up to date. We can confirm that there have been no major material changes or modifications of the relevant Egyptian cross-border legislation since the last publication of this Country Manual. Further to clarifications obtained from local counsel, please note however that mortgage credits for residential immovable property located both in Egypt and in the credit institution’s country are not considered as consumer credit.

Non-material changes

There have been certain, non-material changes to the wording in the RT to improve clarity and comprehensions.

 For more information, please contact us: info@brpsa.com

Geneva, January 13^th 2026

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Isle of Man

out of Company’s Country of Establishment (RS, BT & Def)

Regulatory Summary and Behaviour Template

Material changes

There are no significant material changes to be reported since the last update, but we have added an extra comment to the Behaviour Template for Providing Marketing Brochures on the Company’s initiative that there should be no information on specific services.

We have also added the comment “on a one-to-one basis” for custodian account opening on the Client’s initiative.

Non-material changes

Some comments have been reworded and further non-material changes have been made throughout the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the EAM Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM EAM BT SHORT COMP” and “ISLE OF MAN” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in colour). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, January 12^th 2026

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Qatar

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

There have been no significant changes or material legal changes. We have however added an extra comment for recommendation lists and advice where the answer is Grey zone/YES to emphasise that there should be no advice on locally listed securities. This is to reflect that tolerated practice allowing limited, discreet Crossborder activity will not likely apply to advice relating to securities listed on the Qatar Stock Exchange.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “QATAR” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in colour). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, January 12^th 2026

The post Qatar – CM PB appeared first on BRP.

Hong Kong

BRP has published its latest Country Manual Trustee for

Hong Kong

Regulatory Summary and Definitions and Concepts

Material changes

The content has been reviewed to ensure that all documents remain accurate and in line with the interpretation of the current legal framework.

With regard to Trustee activities, we can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, January 9^th, 2026

The post Hong Kong – CM T appeared first on BRP.

Belgium

BRP has published its latest Country Manual Trustee for

Belgium

Regulatory Summary and Definitions and Concepts

Material changes

The content has been reviewed to ensure that all documents remain accurate and in line with the interpretation of the current legal framework. The following should be noted:

Collecting relevant supporting documents and information may not be performed onsite by the Trustee;

Some nuances and conditions have been added to the answers concerning the general prospection activities of the Bank (i.e. presenting the Bank in general terms, providing the Bank’s annual report and press reviews, and providing marketing brochures on the Bank) to remind that there are no formal rules or clear position of the authorities for reverse solicitation.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, January 9^th, 2026

The post Belgium – CM T appeared first on BRP.

Saint Barthélemy out of Monaco

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

To reflect the strict approach of the authorities with regard to reverse solicitation, in particular for contacts taking place on Saint Barthélemy’s territory, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in Saint Barthélemy, to remind foreign banks that any kind of activity taking place on Saint Barthélemy’s territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence Saint Barthélemy.

Further non-material developments and amendments have been made throughout all the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “SAINT BARTHÉLEMY” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, January 9^th 2026

The post Saint Barthélemy out of Monaco – CM PB appeared first on BRP.

New Caledonia out of Monaco

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

To reflect the strict approach of the authorities with regard to reverse solicitation, in particular for contacts taking place on the New Caledonian territory, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in New Caledonia, to remind foreign banks that any kind of activity taking place on the New Caledonian territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence New Caledonia.

Further non-material developments and amendments have been made throughout all the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “NEW CALEDONIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, January 8^th 2026

The post New Caledonia out of Monaco – CM PB appeared first on BRP.

Wallis and Futuna

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

To reflect the strict approach of the authorities with regard to reverse solicitation, in particular for contacts taking place on the Wallisian Futunan territory, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in Wallis and Futuna, to bear in mind that any kind of activity taking place on the Wallisian Futunan territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence Wallis and Futuna.

Further non-material developments and amendments have been made throughout all the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “WALLIS AND FUTUNA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, January 7^th 2026

The post Wallis and Futuna – CM PB appeared first on BRP.

French Polynesia out of Monaco

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

To reflect the strict approach of the authorities with regard to reverse solicitation, in particular for contacts taking place on the French Polynesian territory, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in French Polynesia, to remind foreign banks that any kind of activity taking place on the French Polynesian territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence in French Polynesia.

Further non-material developments and amendments have been made throughout all the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “FRENCH POLYNESIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, January 6^th 2026

The post French Polynesia out of Monaco – CM PB appeared first on BRP.

French Polynesia out of France

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

Some non-material developments and amendments have been made throughout the Regulatory Summary for clarity purposes.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “FRENCH POLYNESIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, January 5^th 2026

The post French Polynesia out of France – CM PB appeared first on BRP.

French Polynesia

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

To reflect the strict approach of the authorities with regard to reverse solicitation, in particular for contacts taking place on the French Polynesian territory, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in French Polynesia, to bear in mind that any kind of activity taking place on the French Polynesian territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence in French Polynesia.

Further non-material developments and amendments have been made throughout all the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “FRENCH POLYNESIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, December 23^rd 2025

The post French Polynesia – CM PB appeared first on BRP.

New Caledonia

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

To reflect the strict approach of the authorities with regard to reverse solicitation, in particular for contacts taking place on the New Caledonian territory, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in New Caledonia, to bear in mind that any kind of activity taking place on the New Caledonian territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence New Caledonia.

Further non-material developments and amendments have been made throughout all the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “NEW CALEDONIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, December 22^nd 2025

The post New Caledonia – CM PB appeared first on BRP.

Several Jurisdictions – Update December I 2025

We would like to inform you that BRP has updated various country manuals external asset managers during this month:

Material changes

Norway

No Material changes

Armenia

Bermuda

Georgia

Sweden

Alerts

The full & detailed description of the Country Manuals updates is available on the BRP Platform (www.mybrponline.com). To access the relevant Alert, please connect to the BRP Platform and follow the below instructions.

For more information, please contact us: info@brpsa.com

Best regards,

The post Updates Several Jurisdictions – CM EAM appeared first on BRP.

Italy

BRP has updated its Country Manuals Retail Banking for

Italy

out of Bank’s Country of establishment (DEF, RS, BT & RT)

Definitions & Concepts, Regulatory Summary and Behaviour Template

Material changes

The Country Manual has been reviewed to ensure that the content of all documents remains accurate and in line with the evolving interpretation of the current legal and regulatory framework.

Two elements relating to credits should be highlighted:

Update on Disbursement in Italy for Credit Types Structured as Mutui

Following a detailed review of Italian civil law, recent case law (Corte di Cassazione, decision no. 19047 of 11 July 2025), and the distinction between mutui and apertura di credito, we have updated the guidance on the possibility of disbursing certain credit types in Italy. For credit types legally structured as mutui — including consumer credit or mortgage credit — disbursement in Italy could, in principle, trigger the application of Italian law and local licensing requirements for the foreign Credit Institution. Based on this clarification, the answer in the Manual regarding the permissibility of disbursement in Italy has been modified from Grey zone (for consumer credits and mortgage credits) to Grey zone/NO, reflecting that such disbursement is not generally permitted without considering potential licensing obligations.

Increased accuracy in highlighting the risk of consumer protection rules being applied

For mortgage credits secured by immovable property located in Italy, the answers in case both RM and the non-qualified prospect (i.e. consumer) are in Credit Institution’s country were modified from YES to Grey zone/YES to highlight the risk of local consumer protection rules being applied. This potential risk was also added to remote interactions on prospect’s initiative when related to consumer credits and mortgage consumer credits.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes), and additional references to applicable law/regulation have been made in order to provide more clarity and to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

Implications for business relations with third parties

Clarification has been added regarding finders and business introducers. Specifically, with respect to banking services, finders or business introducers acting on behalf of banks to offer loans to clients are considered credit brokers (‘mediatori creditizi’), with all the implications that this entails, particularly with regard to licensing requirements and the impact of cooperating with such intermediaries for a foreign bank.

Regulatory Summary

This document has now a more user-friendly layout and reflects the changes contained in the RT.

For more information, please contact us: info@brpsa.com

Geneva, December 19^th 2025

The post Italy – CM RT appeared first on BRP.

Germany

BRP has updated its Country Manuals Retail Banking for

Germany

out of Bank’s Country of establishment (DEF, RS, BT & RT)

Definitions & Concepts, Regulatory Summary and Behaviour Template

Material changes

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. We can confirm that generally, there have not been any relevant legal or regulatory changes in Germany since the last update.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. In addition, the section on consumer protection rules have further been thoroughly reviewed and, where appropriated amended.

Regulatory Summary

This document has now a more user-friendly layout and reflects the changes contained in the RT.

For more information, please contact us: info@brpsa.com

Geneva, December 19^th 2025

The post Germany – CM RT appeared first on BRP.

Dubai IFC

BRP has updated its Country Manuals Cryptos Overview for

Dubai IFC

out of Crypto-Asset service provider’s country of establishment (DEF, RS & RT)

Definitions & Concepts, Regulatory Summary and Behaviour Template

Regulatory changes

The Cryptos Overview has been reviewed to ensure that the content of all the documents remain accurate and up to date.

On 15 December 2025, the Dubai Financial Services Authority (DFSA) published amendments to its policy statement on FiatCrypto Tokens and its Supervisory Guidelines on the assessment of Crypto Tokens. The amendments enter into force on 12 January 2026.

Under the previous regime, firms could provide financial services within or from the DIFC only in connection with Recognised Crypto Tokens (i.e. tokens formally approved by the DFSA and listed on its website), subject to limited exceptions such as certain custody services.

Under the revised framework, the DFSA has removed the general recognition requirement for Crypto Tokens. Firms engaging in activities involving a Crypto Token (other than a Fiat Crypto Token) must now conduct and document their own suitability assessment for the relevant token in relation to the specific activity. A transitional period applies whereby previously recognised Crypto Tokens (other than Fiat Crypto Tokens) will continue to be deemed suitable for three months following the entry into force of the new rules.

Fiat Crypto Tokens remain subject to a centralised DFSA suitability assessment. The DFSA has published both the assessment criteria and a list of Fiat Crypto Tokens currently considered suitable for use in the DIFC, namely Circle Euro Coin (EURC), Circle USD Coin (USDC) and Ripple USD (RLUSD).

Material changes

There are no material changes that affect the answers in the Cryptos Overview Behaviour Template.

Non-material changes

Some comments and content have been reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, December 18^th 2025

The post Dubai IFC – CM CO appeared first on BRP.

Argentina – Update 2025

out of Credit Institution’s Country of Establishment (Def, BT & Def)

Regulatory Template, Behaviour Template and Definitions and Concepts

Material changes

We have reviewed the documents following consultations with our local counsel in order to update the section on Foreign Exchange Controls. This update reflects the recent significant overhaul of the country’s foreign exchange (FX) framework, which introduces a more flexible FX regime, as outlined in the Alert Argentina 1/2025 published on May 13, 2025.

Concisely, currency restrictions on individuals residing in Argentina have been lifted. Our manual highlights the relevant changes also for legal entities and unfolds the implications for FX activities such as buying securities and receiving loans abroad.

In addition, the Central Bank has resolved to exempt individuals from the obligation to report external assets under the framework of the External Assets and Liabilities Survey (as established by Communiqué “A” 6401). This means that individuals will no longer be required to report their foreign assets to the BCRA, and will only have to report them to the Argentine Tax Authority (ARCA).

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

Moreover, in addition to more comprehensive information on consumer protection rules, the manual includes information on the validity of the credit agreement in cases of breach of licensing requirements and breach of borrower-protection laws, without any material changes to the content of the respective sections.

 For more information, please contact us: info@brpsa.com

Geneva, December 18^th 2025

The post Argentina – CM C appeared first on BRP.

Sri Lanka

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “SRI LANKA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, December 12^th, 2025

The post Sri Lanka – CM PB appeared first on BRP.

Belgium out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Definitions and Concepts, Regulatory Overview and Behaviour Template

Material changes

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. The changes/modifications are as follows:

Activities carried out solely on the basis of documented, specific reverse solicitation — i.e., where the Retail Investor contacts the service provider without any prior marketing — fall into a “Grey zone”, and must be interpreted strictly and conservatively (see below).

Under the “gold-plating” rules, EU Member States may extend certain requirements beyond the harmonised framework of EU directives when transposing them into national law. However, “local distribution rules” generally do not need to be taken into account where an investor approaches or visits the foreign (unlicensed) service provider on the investor’s own initiative and outside the target country (at source). In such cases, the country-specific restrictions mentioned above are no longer reflected in the Country Manuals Products Behaviour Template (CM P BT) for offshore scenarios (at source).

On this occasion, we would like to remind you of the FSMA rules governing the distribution of certain derivatives — specifically Contracts for Difference (CFDs), Binary Options, and Rolling Spot FX contracts — to Retail Investors in Belgium. The FSMA has imposed a permanent ban on the marketing, distribution, or sale of these products to Retail Investors in or into Belgium, subject only to very limited exceptions.

To ensure that the CM P Regulatory Overview (CM P RO) accurately reflects the applicable Belgian framework:

Active marketing or distribution of Binary Options, CFDs (including OTC CFDs), and Rolling Spot FX contracts to Retail Investors in or into Belgium — whether onshore (at target) or via remote means of communication into Belgium (remote) — is answered with “NO”.

Non-material changes

Some comments and content have been slightly reworded in the CM P, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

It has further been highlighted that the FSMA interprets the concept of reverse solicitation very restrictively, a cautious approach is recommended.

For more information, please contact us: info@brpsa.com

Geneva, December 11^th, 2025

The post Belgium out of EEA – CM P appeared first on BRP.

United Arab Emirates

BRP has updated its Country Manuals Cryptos Overview for

United Arab Emirates

out of Crypto-Asset service provider’s country of establishment (DEF, RS & RT)

Definitions & Concepts, Regulatory Summary and Behaviour Template

The Country Manual Cryptos Overview has been reviewed to ensure that the content of all the documents remain accurate and up to date.

A new law regulating banking activities in the UAE was issued on 8 September 2025. Federal Decree-Law No. (6) of 2025 regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business (the “New Banking Law”) became effective on 16 September 2025. The said law repeals and replaces the old Banking Law, Decretal Federal Law No. 14 of 2018 regarding the Central Bank and Organization of Financial Institutions and Activities (the “Law of 2018”). 

The New Banking Law consolidates prudential and conduct supervision of banks and other financial institutions under the CBUAE and expands the CBUAE’s regulatory perimeter to capture technology service providers that facilitate financial services. The inclusion of providing payment services using virtual assets as a licensable activity follows the adoption of the Payment Token Services Regulation in June 2024 (the PTS Regulation), which sets out the revised regulatory framework for the provision of ‘payment token services’ in the UAE. 

Existing regulations, decisions, standards, guidelines and circulars issued under the Central Bank Law remain in force until expressly replaced.

Material changes

In line with the regulatory changes outlined above, the Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, December 11^th 2025

The post United Arab Emirates – CM CO appeared first on BRP.

Réunion

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

With regard to reverse solicitation, the Regulatory Summary now states that the French authorities (also overseeing Réunion) comply with ESMA’s reverse solicitation guidelines in connection with MiCA regulation. The aim is to bear in mind that, also with regard to reverse solicitation in relation to investment services, the AMF may take into consideration ESMA’s MiCA guidelines, which provide for a narrow interpretation of the concept of reverse solicitation.

To reflect the strict approach of the French authorities with regard to reverse solicitation, in particular for contacts taking place on the French territory, including Réunion, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in Réunion, to remind that any kind of activity taking place on the Reunionese territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence in Réunion.

Further non-material developments and amendments have been made throughout all the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “RÉUNION” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, December 10^th, 2025

The post Réunion – CM PB appeared first on BRP.

Mayotte

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

With regard to reverse solicitation, the Regulatory Summary now states that the French authorities (also overseeing Mayotte) comply with ESMA’s reverse solicitation guidelines in connection with MiCA regulation. The aim is to bear in mind that, also with regard to reverse solicitation in relation to investment services, the AMF may take into consideration ESMA’s MiCA guidelines, which provide for a narrow interpretation of the concept of reverse solicitation.

To reflect the strict approach of the French authorities with regard to reverse solicitation, in particular for contacts taking place on the French territory, including Mayotte, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in Mayotte, to remind that any kind of activity taking place on Mayotte’s territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended to avoid a too regular presence in Mayotte. Further non

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “MAYOTTE” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, December 9^th, 2025

The post Mayotte – CM PB appeared first on BRP.

Dubai IFC

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The DIFC Regulatory Law No.1 of 2004 was amended during 2005 to enhance the powers and efficiency of the Dubai Financial Services Authority (DFSA), in particular with respect to financial crime and recovery/resolution of failing firms. The changes do not materially affect the PB Manual.

There have been some changes to DIFC rules since the last update of this manual. The DFSA routinely amends its Rulebook.

Operating a Representative Office – With regard to occasional promotional visits to the DIFC, note that over-reliance on promotional exemptions by a foreign bank on a prolonged basis during such visits may be deemed by the DFSA to be operating a representative office which would itself require a DFSA licence. The DFSA now considers that in the context of financial promotions made onsite, “a regular basis” would be anything more than occasional and “a prolonged period” would usually be anything more than five consecutive days. Previously it was three days. This provides more flexibility than before in avoiding the requirement to have a local representative office.

Changes To Answers And Comments

With regard to various changes introduced as a result of changes in interpretation:

There is a new comment included for promotion and negotiation activities – “In compliance with financial promotion rules”. This is to emphasise that where a foreign bank is relying on an exemption to the DFIC Financial Promotions Prohibition it must take reasonable care to ensure that any financial promotion it makes in the DIFC:

is clear, fair and not misleading;

includes the credit institution’s name, address and regulatory status;

if it is intended only for deemed Professional Clients, it is not sent or directed to any person who appears on reasonable grounds not to be such a Professional Client, and contains a clear statement that only a person meeting the criteria for deemed Professional Clients should act upon it; and

follows certain guidelines in the event it is targeted at non-qualified clients or contains any information or representation relating to past performance.

Changes in detail by activity type:

Prospecting and Negotiation Activity on Bank’s initiative

For active and passive onsite socialising the comment on an occasional basis has been added.

The answers for Presenting the Bank in General Terms by remote means are now Grey zone/YES as opposed to YES – there should be no promotion of services or products for non-qualified clients and promotion to deemed professional clients is permitted in compliance with financial promotion rules.

The answers for Providing the Bank’s Annual Report and Press Reviews by remote means is now Grey zone/YES there should be no promotion of services or products for non-qualified clients (previous answer was NO) and promotion to deemed professional clients is permitted in compliance with financial promotion rules.

For Providing Marketing Brochures, Presenting Banking Services, Providing Documentation on Banking Services, Presenting Investment Services and Providing Documentation on Investment Services in respect of Qualified Clients the additional comment “In compliance with financial promotion rules” has been added.

For active negotiation activities with Qualified Clients the additional comment “In compliance with financial promotion rules” has been added.

Prospecting and Negotiation Activity on Client’s initiative

For Presenting the Bank in General Terms, Providing the Bank’s Annual Report and Press Reviews, Providing Marketing Brochures, Presenting Banking Services, Providing Documentation on Banking Services, Presenting Investment Services and Providing Documentation on Investment Services in respect of both Non-qualified and Qualified Clients the comment “In compliance with financial promotion rules” has been added. This is to reflect the use of financial promotion exemptions for reverse solicitation or deemed professional clients as appropriate. Use of an exemption requires compliance with DFSA rules as discussed above. Answers that were previously YES for such activities by remote means are now Grey zone/YES.

For passive negotiation activities with Non-qualified and Qualified Clients the additional comment “In compliance with financial promotion rules” has been added.

For passive collection of relevant supporting documentation onsite the answers are now Grey zone/Yes – on an occasional basis – rather than YES.

Activity related to Cards

For activity on the Bank’s initiative relating to offering a debit or credit card and collecting or receiving a signed debit or credit card agreement the comment “In compliance with financial promotion rules” has been added where the answer is Grey zone/YES.

For actively providing a debit card the comment no promotion of financial services has been added for qualified clients.

For passively offering a debit card or a credit card the answers for Qualified and Non-qualified clients are now Grey zone/YES with the comment “In compliance with financial promotion rules”. The same comment has been added for passive collection/receipt of a signed debit card agreement.

For passively providing a debit or credit card the comment no promotion of financial services has been added for non-qualified and qualified clients.

Lombard Credit

For activity on the Bank’s initiative relating to offering Lombard credit and collecting or receiving a signed Lombard credit agreement the comment “In compliance with financial promotion rules” has been added where the answer is Grey zone/YES for qualified clients. The comment “Provided the account was opened in compliance with cross-border rules has been deleted.

For passively offering Lombard credit onsite and by remote means the answers are  Grey zone/YES with the comment “In compliance with financial promotion rules”. The same comment has been added for passive collection/receipt of a signed Lombard credit agreement.

Advisory Activity

For active and passive remote provision of Generic Recommendation Lists, Personalised Recommendation Lists and Ongoing Advice based on an Investment Advisory Agreement the comment “only toward a limited number of prospects/clients” has been added. This reflects the view that the DFSA would not be concerned by isolated and sporadic cases of financial services provided via remote means of communication into the DIFC, but rather by the mass, systematic provision of financial services to a large number of DIFC clients into the DIFC.

Sanctions

There is now wording in the Sanctions Section to that emphasise Article 65 of the DIFC Regulatory Law addresses the unenforceability of agreements made in breach of the financial services prohibition. If a person enters into an agreement while conducting a financial service in violation of the Financial Services Prohibition or as a result of a prohibited financial promotion, the agreement is unenforceable.

Non-material changes

Some content has been amended and/or slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “DIFC” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in colour). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, December 8^th, 2025

The post Dubai IFC – CM PB appeared first on BRP.

Germany – Update 2025

out of Credit Institution’s Country of Establishment (Def, BT & Def)

Regulatory Template, Behaviour Template and Definitions and Concepts

Material changes

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. We can confirm that generally, there have not been any relevant legal or regulatory changes in Hungary since the last update.

Given the inherent threats for the Credit Institution of a leverage effect of Lombard credit (margin financing) agreement where the client’s/prospect’s portfolio serves as collateral, the answer for solicitation and negotiation of Lombard credit services have been changed to Grey zone for all activites onsite and on a remote basis to Germany. This is to reflect the increased risk level for the Credit Institution that local consumer protection rules may apply to a Lombard credit agreement with a prospect or client in Germany, even when the Credit Institution acts upon the client’s or prospect’s request. The potential legal risks for the Credit Institution under German consumer protection law manifest in particular in the case that the mandatory information requirements are not fully complied with.

The section on consumer protection rules have further been thoroughly reviewed and, where appropriated amended.

Non-material changes

The section on consumer protection rules have further been thoroughly reviewed and, where appropriated amended.

 For more information, please contact us: info@brpsa.com

Geneva, December 5^th 2025

The post Germany – CM C appeared first on BRP.

Bermuda

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “BERMUDA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, December 4^th, 2025

The post Bermuda – CM PB appeared first on BRP.

Switzerland

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Definitions and Concepts, Regulatory Overview and Behaviour Template

Material changes

There are no material changes that affect the answers in the Country Manual Products Behaviour Template (CM P BT).

Non-material changes

Some comments and content have been reworded in the CM to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, December 3^rd, 2025

The post Switzerland – CM P appeared first on BRP.

Kuwait

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Definitions and Concepts, Regulatory Overview and Behaviour Template

Material changes

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. The changes/modifications are as follows:

In alignment with the Country Manual Private Banking (CM PB), it is highlighted that any provision of execution-only services by foreign (unlicensed) service providers on a cross-border basis into Kuwait (remote) may be accepted without triggering licensing requirements. As the account is opened abroad and the assets held abroad, the acceptance and execution of brokerage orders should not, in principle, constitute a financial activity performed within Kuwait. The Country Manual Products Behaviour Template (CM P BT) therefore now provides the answer “Grey zone/YES – No formal rules. Unofficial tolerated practice”.

Non-material changes

Some comments and content have been slightly reworded in the CM P, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, December 2^nd, 2025

The post Kuwait – CM P appeared first on BRP.

Austria

BRP has published its latest Country Manual Trustee for

Austria

Regulatory Summary and Behaviour Template

Material changes

We have reviewed the documents and can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual. Nevertheless, some interpretations give room for a more liberal approach (see details below).

Non-material changes

We took advantage of this update to revise the wording of certain sentences.

The behaviour rules have been made more precise.

The legal basis list has been updated.

Behaviour Template

The changes are as follows:

In order to maintain a consistent approach, responses relating to the referral of a Custodian Bank, Investment Advisor or Asset Manager have been aligned with our CM Private Banking.

Socialising activities, such as providing a business card, are permitted (“YES” instead of “Grey zone/YES”).

Since trustee services and activities are not expressly regulated in Austria, Trustees must ensure that they do not establish a permanent presence. They might act onsite under certain circumstances, but they should avoid onsite activities involving remuneration and they should act on a strict occasional basis. (“Grey zone” instead of “Grey zone/NO”).

For more information, please contact us: info@brpsa.com

Geneva, November 27^th, 2025

The post Austria – CM T appeared first on BRP.

Vatican City

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. We can confirm that there have not been any relevant legal or regulatory changes in Vatican City since the last update.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “VATICAN CITY” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, November 24^th, 2025

The post Vatican City – CM PB appeared first on BRP.

Isle of Man

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

There are no significant material changes to be reported since the last update, but we have added an extra comment to the Behaviour Template for Providing Marketing Brochures on the Bank’s initiative that there should be no information on specific services.

Non-material changes

Some answers, in particular in the chapter on collaboration with third parties and in the chapter “Miscellaneous”, have been amended to provide more detail. Also, some comments have been reworded and further non-material changes have been made throughout the documents.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “ISLE OF MAN” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, November 24^th, 2025

The post Isle of Man – CM PB appeared first on BRP.

Italy – Update 2025

out of Credit Institution’s Country of Establishment (Def, BT & Def)

Regulatory Template, Behaviour Template and Definitions and Concepts

Material changes

The Country Manual has been reviewed to ensure that the content of all documents remains accurate and in line with the evolving interpretation of the current legal and regulatory framework.

Update on Disbursement in Italy for Credit Types Structured as Mutui

Following a detailed review of Italian civil law, recent case law (Corte di Cassazione, decision no. 19047 of 11 July 2025), and the distinction between mutui and apertura di credito, we have updated the guidance on the possibility of disbursing certain credit types in Italy.

For credit types legally structured as mutui — including consumer credit, portfolio-backed lending (non-Lombard), mortgage credit, corporate lending, and transactional financing — disbursement in Italy could, in principle, trigger the application of Italian law and local licensing requirements for the foreign Credit Institution. Based on this clarification, the answer in the Manual regarding the permissibility of disbursement in Italy has been updated from YES (for portfolio-backed lending (non-Lombard), corporate lending, and transactional financing) respectively from Grey zone (for consumer credits and mortgage credits) to GREY zone/NO, reflecting that such disbursement is not generally permitted without considering potential licensing obligations.

Increased accuracy in highlighting the risk of consumer protection rules being applied

For mortgage credits secured by immovable property located in Italy, the answers in case both RM and the non-qualified prospect (i.e. consumer) are in Credit Institution’s country were modified from YES to Grey zone/YES to highlight the risk of local consumer protection rules being applied.

This potential risk was also added to remote interactions on prospect’s initiative when related to consumer credits and mortgage consumer credits.

The specific explanations were modified accordingly.

Non-material changes

There have been certain, non-material changes to the wording in the RT to improve clarity and comprehension.

In particular, the Tax section of the document has been updated to include clarifications on the scope of obligations, withholding tax, joint liability, filing deadlines, and interpretation of Italian resident debtors, while no material changes to the underlying principles have been made.

 For more information, please contact us: info@brpsa.com

Geneva, November 21^st 2025

The post Italy – CM C appeared first on BRP.

France out of Monaco

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The documents have been reviewed, and we can confirm that there have been no relevant regulatory developments implying material changes since the last update of this Country Manual.

Non-material changes

With regard to reverse solicitation, the Regulatory Summary now states that French authorities comply with ESMA’s reverse solicitation guidelines in connection with MiCA regulation. The aim is to remind us that, also with regard to reverse solicitation in relation to investment services, the AMF may take into consideration ESMA’s MiCA guidelines, which provide for a narrow interpretation of the concept of reverse solicitation.

To reflect the strict approach of the French authorities with regard to reverse solicitation, in particular for contacts taking place on the French territory, investment-related prospecting activities with Qualified prospects are now a grey zone.

In the Behaviour Template, the condition “on an occasional basis” has been added to socialising activities in France, to remind that any kind of activity taking place on the French territory could be considered a relevant element in application of the “bundle of indicators” method. Thus, even for simple socialising activities, it is recommended that Monegasque relationship managers avoid a too regular presence in France.

Further non-material developments and amendments have been made throughout all the documents.

Regulatory Summary

This document has now a more user-friendly layout and reflects the changes contained in the RT.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “FRANCE” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, November 21^st, 2025

The post France out of Monaco – CM PB appeared first on BRP.

Several Jurisdictions – Update November III 2025

We would like to inform you that BRP has updated various country manuals external asset managers during this month:

No Material changes

Australia

No Material changes

Belgium

France

Alerts

The full & detailed description of the Country Manuals updates is available on the BRP Platform (www.mybrponline.com). To access the relevant Alert, please connect to the BRP Platform and follow the below instructions.

For more information, please contact us: info@brpsa.com

Best regards,

The post Updates Several Jurisdictions – CM EAM appeared first on BRP.

Georgia

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

Regulatory Summary

This document now has a more user-friendly layout and reflects the changes contained in the RT.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “GEORGIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, November 20^th, 2025

The post Georgia – CM PB appeared first on BRP.

Armenia

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “ARMENIA” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, November 20^th, 2025

The post Armenia – CM PB appeared first on BRP.

Sweden out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

Since the last update of this Manual, the relevant Swedish regulatory framework has been modified by the new Consumer Credit Act (Konsumentkreditlag 2010:1846) — SFS 2024:1238). The label “high-cost credit” (högkostnadskredit) as a special category was removed, but overall consumer protection was tightened. Important new rules concern in particular the following:

A hard one-time rollover limit and group-refinancing anti-avoidance.

The duty of debt-risk and debt-advice warnings in all credit advertisements and marketing;

A numerical cap on borrowing and default interest for virtually all consumer credit, and ban on extra late fees;

A 100% total cost cap including default interest and collection charges, plus anti-refinancing aggregation;

An absolute cap on upfront arrangement fees;

Non-material changes

Some comments and content have been slightly reworded, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, November 19^th, 2025

The post Sweden out of EEA – CM PB appeared first on BRP.

Netherlands

BRP has published its latest Country Manual Trustee for

Netherlands

Regulatory Summary and Behaviour Template

Material changes

The Act on the Supervision of Trust Offices 2018 (“WTT 2018”) was revised this year. A few changes were made, such as the definition of ‘trust offices’ and ‘trust services’, but this has not resulted in any changes to our approach or responses.

Non-material changes

We took advantage of this update to revise the wording of certain sentences.

We also added some information on wealth planning and real estate activities in the Netherlands.

The behaviour rules have been made more precise.

The section on anti-avoidance rules has been updated, in particular the list of low-tax jurisdictions.

Behaviour Template

The changes are as follows:

Since reverse solicitation appears to be recognised onsite (no formal rules), negotiation activities at the client’s request seem permitted under conditions. Similarly, if the trustee undertakes pre-contractual activities via remote means of communication based on a relationship initiated in accordance with cross-border rules, there is no prior solicitation of a regulated service; active trustee services could be undertaken remotely under this condition.

To maintain a consistent approach, responses have been aligned with CM Private Banking for referring a Custodian Bank, Investment Advisor or Asset Manager.

For more information, please contact us: info@brpsa.com

Geneva, November 18^th, 2025

The post Netherlands – CM T appeared first on BRP.

Netherlands out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

According to local experts, the framework of the general good provisions and mandatory consumer protection rules in the Netherlands has remained almost unchanged, with the exception that according to a new decree (Besluit Gedragstoezicht financiële ondernemingen Wft9, financial services must be accessible to consumers with disabilities, and the Bank must document and disclose accessibility compliance.

Non-material changes

Some comments and content have been slightly reworded, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, November 18^th, 2025

The post Netherlands out of EEA – CM PB appeared first on BRP.

Romania out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

No relevant modifications of the Romanian regulatory framework comprising provisions of the general good and mandatory consumer protection rules have been indicated to us since the last update.

Non-material changes

Some comments and content have been slightly reworded, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, November 18^th, 2025

The post Romania out of EEA – CM PB appeared first on BRP.

Norway out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

No fundamental modifications of the general good provisions and mandatory consumer protection rules framework have been indicated since the last update. Some updates and clarifications concern:

Marketing materials must not emphasize that credit is easily available, including that the credit may be used or application granted quickly, that the application process is simple or that the threshold for granting credit is low. The word emphasize entails that such information must not be given more prominence than the disclosure of the annual percentage rate.

Marketing must be clearly recognisable as such and claims in marketing relating to factual circumstances must be documented.

Customers have the right to op out of electronic communication.

Credit may not be marketed by way of door to door sales.

Where bonuses or other additional advantages are marketed in conjunction with credit (airline miles, etc.), these advantages cannot be given a more prominent place in the marketing than the information required by law.

Non-material changes

Legal references have been updated and minor non-material streamlining has been implemented throughout the documents.

For more information, please contact us: info@brpsa.com

Geneva, November 17^th, 2025

The post Norway out of EEA – CM PB appeared first on BRP.

Iceland out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

No relevant material changes of the provisions of the general good and mandatory consumer protection rules have been communicated since the last update of the Manual.

Non-material changes

Some legal basees have been updated and further non-material amendments have been made throughout the documents.

For more information, please contact us: info@brpsa.com

Geneva, November 17^th, 2025

The post Iceland out of EEA – CM PB appeared first on BRP.

Colombia – Update 2025

out of Credit Institution’s Country of Establishment (Def, BT & Def)

Regulatory Template, Behaviour Template and Definitions and Concepts

Material changes

We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual. 

Non-material changes

The manual has more comprehensive information concerning the general legal framework, it outlines additional mandatory Colombian legal provisions under the civil and commercial codes, such as the usury cap and restrictions on abusive penalty clauses, that apply to cross-border credit offerings. If these provisions are violated, the credit agreement may be subject to judicial adjustment or deemed unenforceable under Colombian law.

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

 For more information, please contact us: info@brpsa.com

Geneva, November 14^th 2025

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Several Jurisdictions – Update November II 2025

We would like to inform you that BRP has updated various country manuals external asset managers during this month:

No Material changes

Brunei Darussalam

Hong Kong

Philippines

Alerts

The full & detailed description of the Country Manuals updates is available on the BRP Platform (www.mybrponline.com). To access the relevant Alert, please connect to the BRP Platform and follow the below instructions.

For more information, please contact us: info@brpsa.com

Best regards,

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Croatia out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The Capital Markets Act specifies that the Bank is obliged to provide a prospect/client with all the information necessary pursuant to the Capital Market Act in electronic form, but that retail investors must be informed that they can also request the information in paper form.

Since the last update, Croatia has amended the Consumer Crediting Act and put into force an Act on Means, Conditions, and Procedure of Servicing and Purchasing of Claims Act, which according to local counsel, are considered to, in large part, reflect provisions on relevant EU directives. For the purposes of the present Private Banking manual, only the rules on a cap on variable rates for consumer loans and the fact that debtors may not be charged any cost for compulsory notices have been retained.

Non-material changes

Some comments and content have been streamlined and/or reworded in the Country Manual, without introducing substantive chSome comments and content have been streamlined and/or slightly reworded in the Country Manual, without introducing substantive changes.  

For more information, please contact us: info@brpsa.com

Geneva, November 13^th, 2025

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Latvia out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

On 11 July 2025, the Latvian legislator introduced a new Article 60-1 into the Credit Institutions Act (Kredītiestāžu likums), establishing a comprehensive language framework for the provision of financial services by credit institutions. The new rule is applicable to business relationships with all types of prospects and clients, not only consumers.

This amendment gives clients in Latvia the right to receive financial services provided by credit institutions in Latvian language and the new article 60-1 of the Credit Institution Act obliges credit institutions to ensure that all core client-facing channels—including contractual documentation, standard forms, digital interfaces (such as websites and mobile applications), language-choice mechanisms, call-centre communication and in-person service are available in Latvian at all times.

The law also permits the use of other languages on the level of individual client relationships, but only under specific conditions:

EU and EU candidate country languages, such as English or Ukrainian, may be used if the prospect or client asks for it or agrees, and if the credit institution is both able and willing to communicate in that language. Consent may be given explicitly or implicitly, for example, where a contract is signed solely in English. However, prospects or clients cannot require the institution to provide services in a language it does not offer;

By contrast, the use of third-country languages, such as Russian or Chinese, are much more restricted. They may be used only in direct employee–client communication, whether oral or written if the employee agrees, but they cannot be used for contracts, digital platforms, or other official service infrastructure.

The overarching principle is that a Latvian language version is always available and offered as the primary option, while EU languages are permitted only as a consensual add-on, and third-country languages are tolerated only in informal communications.

The law foresees a gradual transition, with full implementation required by 30 September 2026. Contracts already concluded in a third-country language will remain valid after that date, but any amendments must be made in compliance with the new requirements, meaning in Latvian language or another EU language with Latvian available.

For more detail, see BRP Alert Latvia 1_2025.

Non-material changes

Some comments and content have been streamlined and/or reworded in the Country Manual, without introducing substantive changes. It has also been clarified that A consumer is generally entitled to unilaterally terminate a contract where the service provider fails to deliver the service within the timeframe prescribed by the contract.

For more information, please contact us: info@brpsa.com

Geneva, November 12^th, 2025

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Several Jurisdictions – Update November II 2025

We would like to inform you that BRP has updated various country manuals external asset managers during this month:

No Material changes

Guinea

Uganda

Zimbabwe

Alerts

The full & detailed description of the Country Manuals updates is available on the BRP Platform (www.mybrponline.com). To access the relevant Alert, please connect to the BRP Platform and follow the below instructions.

For more information, please contact us: info@brpsa.com

Best regards,

The post Updates Several Jurisdictions – CM EAM appeared first on BRP.

Belgium

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Definitions and Concepts, Regulatory Overview and Behaviour Template

Material changes

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. The changes/modifications are as follows:

Activities conducted solely on the basis of documented (specific) reverse solicitation — where the Retail Investor contacts the service provider without any prior marketing — are classified as “Grey zone”, subject to strict interpretation.

In alignment with the Country Manual Private Banking (CM PB), any provision of Macroeconomic information as well as Investment Research & Financial Analysis are permitted only on an occasional basis onshore in Belgium (at target). The Country Manual Products Behaviour Template (CM P BT) therefore now provides the answers “Grey zone/YES” in the relevant scenarios.

In further alignment with the CM PB and in order to better reflect the existing regulatory framework:

The active provision of generic and personalised recommendation lists, as well as other marketing material referring to specific financial products, via remote means of communication into Belgium (remote) is only permitted if the asset class is covered by the advisory agreement. However, to date, the FSMA has not yet taken a formal position on these activities undertaken actively into Belgium (remote), even within the context of an existing advisory agreement (ongoing mandate). Therefore, to maintain a cautious approach, the CM P BT now provides the answer “Grey zone” in the relevant scenarios.

For every onsite activity where a “Grey zone” answer appears in the CM P BT (e.g. for execution only services or for reverse specific solicitation scenarios), the comment “on an occasional basis” has been added.

Finally, we would like to remind you of the FSMA rules regarding the distribution of certain derivatives — specifically Contracts for Difference (CFDs), Binary Options, and Rolling Spot FX contracts — to Retail Investors in Belgium. The FSMA has imposed a permanent ban on the marketing, distribution, or sale of these products to Retail Investors in/into Belgium, with only very limited exceptions. In order to reflect the CM P Regulatory Overview with the applicable Belgian framework:

Active marketing or distribution of Binary Options, CFDs (including OTC CFDs), and Rolling Spot FX contracts to retail investors in or into Belgium (whether onshore or via remote channels) is answered with “NO”.

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

It has further been highlighted that the FSMA interprets the concept of reverse solicitation very restrictively, a cautious approach is recommended.

For more information, please contact us: info@brpsa.com

Geneva, November 10^th, 2025

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Mozambique

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.

Please note that, as per the Central Bank Notice n°3/GBM/2024, the foreign investment limit without requiring Bank of Mozambique approval has increased to USD 1,000,000.

Non-material changes

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

Regulatory Summary

This document has now a more user-friendly layout and reflects the changes contained in the RT.

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “MOZAMBIQUE” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, November 10^th, 2025

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Brazil – Update 2025

out of Credit Institution’s Country of Establishment (Def, BT & Def)

Regulatory Template, Behaviour Template and Definitions and Concepts

Material changes

We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual. 

Non-material changes

The manual emphasizes that certain types of credits (i.e., Portfolio-Backed lending and mortgage credits) may be classified as consumer credits if the borrower is considered a consumer under the Brazilian “Consumer Protection Code” and the purpose of the loan is personal.

Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

 For more information, please contact us: info@brpsa.com

Geneva, November 5^th 2025

The post Brazil – CM C appeared first on BRP.

Malta out of EEA

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The Manual has undergone an extensive review by local counsel to ensure it focuses on non-harmonised local law, removing previously included harmonised provisions and thereby aligning more closely with the intended scope.

Non-material changes

Some comments and content have been streamlined and/or slightly reworded in the Country Manual, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. 

For more information, please contact us: info@brpsa.com

Geneva, November 4^th, 2025

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