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

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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

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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

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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

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We are thrilled to share some news that fills us with pride: our parent company, aosphere, has acquired Investment Navigator.

Founded in 2014, Investment Navigator has established itself as a utility provider for banks in managing cross-border compliance and investment processes.

Its digital services include the digitalisation of cross-border banking manuals and a workflow tool designed to support internal and cross-organisational collaboration on regulatory matters.

Its investment product eligibility platform integrates compliance checks and selling restrictions into investment management workflows, both before and after trade execution.

In today’s fast-paced digital landscape, it’s more important than ever to have access to cutting-edge digital solutions. This partnership is set to be a game-changer, combining unparalleled expertise to create a winning formula. BRP is set to benefit from Investment Navigator‘s technology for digitised data management, which will be seamlessly integrated with the best core banking and portfolio management systems on the market. Our goal is crystal clear: to combine the very best of existing solutions to continuously improve the user experience and provide our customers with user-friendly solutions that deliver significant added value.

As a first step towards strengthening our cooperation, we will be making the BRP content available on the Investment Navigator platform. This will also be the opportunity to launch a new version of our Dos & Don’ts. These have been developed to be even more user-friendly and comprehensive. Rest assured that we will keep you informed about any forthcoming developments.

This exciting acquisition is a huge step forward in the aosphere Group’s long-term strategy, which aims to drive innovation and accelerate digital transformation.

We remain at your disposal for any questions and we thank you for your confidence.

Best regards,

Nous sommes ravis de partager une nouvelle qui nous remplit de fierté : notre société mère, aosphere, a acquis Investment Navigator.

Fondée en 2014, Investment Navigator s’est imposée comme un prestataire de services incontournable pour les banques dans la gestion de risques transfrontières et des processus d’investissement.

Ses services numériques incluent la digitalisation des Country manuals ainsi qu’un outil de workflow conçu pour faciliter la collaboration interne et inter-organisationnelle sur les questions réglementaires.

Sa plateforme d’éligibilité des produits d’investissement intègre des contrôles de conformité et des restrictions de vente directement dans les processus d’investissement, tant avant qu’après l’exécution des transactions.

Dans un environnement numérique en constante évolution, il est plus que jamais essentiel de disposer de solutions digitales de pointe. Ce partenariat marque un tournant stratégique, en réunissant des expertises complémentaires pour créer une formule gagnante. BRP bénéficiera de la technologie d’ Investment Navigator pour la gestion digitalisée des données, qui sera intégrée de manière fiable aux meilleurs systèmes informatiques bancaires et de gestion de portefeuille.

Notre objectif est clair : combiner le meilleur des solutions existantes pour améliorer continuellement l’expérience utilisateur et offrir à nos clients des solutions intuitives à forte valeur ajoutée.

Dans un premier temps, nous rendrons le contenu des manuels BRP disponible sur la plateforme Investment Navigator. Ce sera également l’occasion de lancer une nouvelle version de nos « Dos & Don’ts », conçue pour être encore plus conviviale et exhaustive. Soyez assurés que nous vous tiendrons informés des prochaines évolutions.

Cette acquisition représente une avancée majeure dans la stratégie à long terme du groupe aosphere, visant à stimuler l’innovation et à accélérer la transformation digitale.

Nous restons à votre disposition pour toute question et nous vous remercions de votre confiance.

Meilleures salutations,

Mit besonderer Freude informieren wir darüber, dass unsere Muttergesellschaft aosphere das Schweizer Unternehmen Investment Navigator AG übernommen hat.

Investment Navigator wurde 2014 gegründet und hat sich seither als verlässlicher Partner für Banken im Bereich des Managements von Compliance- und Anlageprozessen im Cross-border-Bereich etabliert.

Zu den digitalen Dienstleistungen des Unternehmens gehören die Digitalisierung von Cross-border Manuals für Banken sowie ein Workflow-Tool, zur Unterstützung der internen und organisationsübergreifenden Zusammenarbeit in regulatorischen Angelegenheiten.

Die Investment Product Eligibility Platform von Investment Navigator ermöglicht es, Compliance-Checks und Vertriebsbeschränkungen nahtlos in die Prozesse des Investmentmanagements zu integrieren – und zwar vor als auch nach Ausführung der Transaktion.

In der schnelllebigen digitalen Landschaft von heute ist es wichtiger denn je, Zugang zu modernsten digitalen Lösungen zu haben. Diese Partnerschaft wird hier neue Massstäbe setzen und hält mit der Kombination von einzigartigem Fachwissen den Schlüssel zum Erfolg. BRP profitiert dabei von der modernsten Technologie von Investment Navigator für die digitale Datenverwaltung, welche sich nahtlos in marktführende Kernbanken- und Portfoliomanagementsysteme einfügt. Unser Ziel ist klar: Wir wollen die besten bestehenden Lösungen verknüpfen, um die User Experience laufend zu verbessern und unseren Kunden bedienerfreundliche Lösungen mit hohem Mehrwert anzubieten.

Als ersten Schritt zur Stärkung unserer Zusammenarbeit werden die Inhalte von BRP künftig auf der Plattform von Investment Navigator zugänglich gemacht. Gleichzeitig nutzen wir die Gelegenheit, eine neue Version unserer Dos & Don’ts zu veröffentlichen. Diese wurden noch benutzerfreundlicher und umfassender gestaltet. Über sämtliche weiteren Entwicklungen werden wir zeitnah informieren.

Diese spannende Übernahme markiert einen bedeutenden Meilenstein in der langfristig ausgerichteten Strategie der aosphere Group, mit dem Ziel, Innovationen voranzutreiben und die digitale Transformation zu beschleunigen.

Für Fragen stehen wir Ihnen gerne zur Verfügung und danken Ihnen für Ihr Vertrauen.

Mit freundlichen Grüssen

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Greece

BRP has published its latest Country Manual Trustee for

Greece

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. 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, July 11^th, 2025

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Bahamas

BRP has published its latest Country Manual Trustee for

Bahamas

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

Non-material changes

Some content has been reworded, without introducing any material changes.

Furthermore, the BTCRA (Amendment) Bill 2025 and the TA (Amendment) Bill 2025 have been published and are currently under consultation, but they do not appear to introduce future material changes for the purpose of this Country Manual.

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, July 8^th, 2025

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Dear Clients,

We are pleased to inform you that, as of 1st of July 2025, BRP Tax SA has merged with BRP Bizzozero & Partners SA. This integration is part of our strategy to further strengthen and consolidate our products & services within our new group organisation.

Please be assured that nothing changes for you – your usual contacts remain the same, and our commitment to delivering the highest quality products and services continues unchanged.

BRP Tax SA ceases to exist as a separate legal entity, but its activities continue under the BRP Bizzozero & Partners SA brand.

Existing contracts and agreements with BRP Tax SA are taken over by BRP Bizzozero & Partners SA.

We remain at your disposal for any further information. We sincerely thank you for your trust.

Kind regards,

BRP Tax Products Team

Romain Potet, Alexandra Márquez Palgi, Jean-Marc Favre, Daniele Genovese

Geneva, July 3rd 2025

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France

BRP has published its latest Country Manual Trustee for

France

Regulatory Summary and Behaviour Template

Material changes

Following the publication of the decision rendered by the French Court de Cassation on the 15th of November 2023 some answers regarding activities undertaken with qualified prospects have been changed. Indeed, the decision confirms that the exceptions, listed under Article 341-2 of the MFC, to the direct marketing rules can also be used by third-countries and non-passported EEA financial institutions. As a consequence, the rules concerning direct marketing do not apply, notably, to contacts with qualified prospects, in and into France. The monopoly rules remain however relevant when activities take place on the French territory.

You will find below a summary of the main changes:

In France:

The Country Manual also reflects the exception to the direct marketing rules when it comes to existing clients, i.e. when (independently of the client’s qualification) the offered transactions correspond, by virtue of their characteristics, risks, or amounts involved, to transactions usually carried out by such clients

Presenting the Bank or Company in general terms and providing the Bank’s or Company’s annual report and press reviews to qualified prospects, in France actively and passively are now permitted on an occasional basis;

Prospecting activities relating to banking services undertaken occasionally with qualified prospects in France, actively or passively, are now a grey zone. A cautious approach is recommended as they could be qualified as negotiation of banking services, due to the broad interpretation of the concept of negotiation by the French authorities;

Prospecting activities relating to investment services performed in France are also a grey zone, for the same reason as just stated, when undertaken actively with qualified prospects. On a qualified prospect’s initiative, however, these activities seem permitted on the French territory on an occasional basis as reverse solicitation is recognised as a formal exception to the monopoly rules.

Into France:

Presenting the Bank or the Company in general terms, providing the Bank’s or Company’s annual report and press reviews, and undertaking prospecting activities relating to banking and investment services to or with qualified prospects into France actively are now permitted on an occasional basis;

Due to the monopoly rules, active negotiation activities into France are a grey zone for qualified prospects but seem permitted if undertaken on their initiative. The activities should in any case remain occasional, due to the “bundle of indicators” method used by the French authorities to determine if a licensable activity has been undertaken on the French territory. The Bank should, in particular, avoid systematically sending contracts to be signed in France.

Non-material changes

Some content has been reworded, without introducing any material changes.

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, July 2^nd, 2025

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Summer Mode: Activated 🌞 😎

Dear clients,

🐬 REGORA’s public training sessions (webinars and inPerson) are taking a summer break in July & August 2025.

But don’t worry — we’re still offering on-site trainings at your location. You bring the coffee; we bring the expertise! 👀

See you in September for our usual sessions — hopefully with a tan!

Enjoy your summer, 👣

The BRP REGORA Team

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Israel

BRP has published its latest Country Manual Trustee for

Israel

Regulatory Summary and Behaviour Template

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.

Otherwise, tax rules have been introduced in 2024 regarding reporting obligations to the Israel Tax Authority concerning in particular “controlling individuals”, “New Israeli Residents” and “Veteran Returning Residents”, which has led to changes in the dedicated section (Chapter F). More generally, the legislative changes regarding Payment Services and the draft changes proposed on broker-dealer activities in the Securities Law have been highlighted.

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, May 23^rd, 2025

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Israel

BRP has published its latest Country Manual Trustee for

Israel

Regulatory Summary and Behaviour Template

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.

Otherwise, tax rules have been introduced in 2024 regarding reporting obligations to the Israel Tax Authority concerning in particular “controlling individuals”, “New Israeli Residents” and “Veteran Returning Residents”, which has led to changes in the dedicated section (Chapter F). More generally, the legislative changes regarding Payment Services and the draft changes proposed on broker-dealer activities in the Securities Law have been highlighted.

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, May 23^rd, 2025

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Brazil

BRP has published its latest Country Manual Trustee for

Brazil

Regulatory Summary

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.

Otherwise, tax rules have been introduced in 2024 (in relation to CFC rules), which has led to changes only in the dedicated section (Chapter F).

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.

Behaviour Template

For the sake of consistency, all the answers relating to Trustee activities (which are not regulated per se) have been harmonised, e.g. activities related to the collection of supporting information.

Regarding regulated activities, we have aligned the first two answers of each section in accordance with the CM PB. Therefore, answers concerning the presentation and the provision of marketing documentation of a custodian bank, asset manager or investment advisor are now a ‘Grey zone’ onsite (instead of ‘Grey zone/YES’). In fact, these activities are based on an unofficial tolerated practice that could become stricter depending on the regulator’s approach.

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

Geneva, March 25^th, 2025

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United Kingdom

BRP has published its latest Country Manual Trustee for

United Kingdom

Regulatory Summary and Behaviour Template

Material changes

Compared to the previous version, the basic approach has not changed – the BT answers remain unchanged.

Non-material changes

There have been minor alterations to some drafting.

Regulatory Summary

With regard to tax issues the wording has not changed, but the UK tax regime is subject to changes from April 2025 as explained in BRP Alert United Kingdom 6/2024 – Changes for Private clients. These changes will lead to revision of the Trustee Manual after April 2025.

There is further information wording on changes to the regulation of estate agents in the UK.

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

Geneva, March 20^th, 2025

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South Africa

BRP has published its latest Country Manual Trustee for

South Africa

Regulatory Summary and Behaviour Template

Material changes

The country manuals has been reviewed to ensure it remains in line with the regulatory developments.

We can confirm that there are generally no major changes in the South African regulation from a cross-border perspective. Please note that some responses in the Behavior Template have been streamlined with the information provided in the Regulatory Summary, particularly in relation to the introduction of a custodian. In particular, such services should not be presented to a client in and into South Africa on the trustee’s initiative (and remain a gray area during on-site visits if on the prospect’s initiative). Note also that we do not advise the trustee to undertake any pre-contractual activities for the custodian in this regard (and this remains a gray area even if provided on a passive and remote basis into South Africa).

Please note that the manual has been meaningfully updated and expanded with regard to information on trusts, i.e. the types of trusts available under South African legislation, trust registration, tax regime and reporting.

Non-material changes

We reviewed, refined and extended the information provided in the Regulatory Summary. This includes information on foreign exchange controls and on the FSP I license.

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

Geneva, March 11^th, 2025

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BRP has published its latest Country Manual Trustee for

Russia

Regulatory Summary and Behaviour Template

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

Please note: This Country Manual covers the rules in connection with licensing requirements, but it does not address restrictions imposed by the Trustee’s country of establishment (e.g. European or Swiss measures against Russian actions aimed at destabilising the situation in Ukraine). However, this Country Manual presents a summary of the countermeasures adopted to date by Russia (in Chapter B.6. relating to Foreign 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.

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

Geneva, February 21^st, 2025

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BRP has published its latest Country Manual Trustee for

Egypt

Regulatory Summary

Material changes

The wording in the Tax section of the Regulatory Summary covering Anti-avoidance Rules and Structuring Personal Assets has been revised and extended.

There are new sub-sections covering Disclosure of Reportable Tax Schemes and Register of Ultimate Beneficial Owners.

Non-material changes

The wording in the Regulatory Summary covering permanent establishments has been enhanced. 

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

Geneva, January 31^th, 2025

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BRP has published its latest Country Manual Trustee for

Saudi Arabia

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

Geneva, January 28^th, 2025

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