Compliance Newsletter: Q1 2025

As 2025 gets underway, there’s already plenty to report. From gold surpassing the $3,000 mark to ongoing policy shifts across the EU and UK, the compliance and regulatory landscape remains as dynamic as ever. This edition covers recent developments across trade, sustainability and market risk frameworks.

EU Considers Tariffs on US Silver

In response to US tariffs on aluminium and steel introduced on 12 March, the European Commission launched a consultation on potential retaliatory measures. Silver is among the goods under consideration.

LBMA responded to the consultation, expressing serious concern over the implications for the precious metals market. Silver’s critical role in electronics, renewable energy, investment products, and jewellery makes it a vital commodity for EU industries.

Disrupting this flow with retaliatory tariffs could further stress supply chains, drive up costs for EU manufacturers, and increase global market volatility. The EU is home to 25 LBMA Member companies and 11 Good Delivery Refiners, underscoring the region’s importance to the industry.

Platinum and palladium group metals have also been listed and would be similarly affected. Please speak to LPPM for more information.

FCA Sets Out 5-Year Strategy: Trust, Growth, and Risk Rebalance

In March, the FCA published its new 5-Year Strategy (2025-2030) - a notable shift from its usual three-year cycle. The regulator outlines a long-term vision centred around deepening trust, rebalancing risk, supporting growth, and improving lives.

The strategy is underpinned by four key priorities:

• Becoming a smarter regulator – predictable, purposeful and proportionate. The FCA will streamline authorisations, embrace digital innovation, and take a more flexible approach to supervision.
• Supporting sustained economic growth – by enabling innovation, boosting investment, and keeping UK financial services competitive. Reforms will include capital markets changes, retail access to investment, and integrating the Payment Systems Regulator to drive Open Finance.
• Helping consumers navigate financial decisions – by enhancing access to products, simplifying guidance, and embedding the Consumer Duty to improve outcomes across the board.
• Fighting financial crime – with a focus on disrupting criminal use of regulatory status, enhancing detection through tech, and reinforcing firms’ role as a line of defence.

Notably, the FCA is encouraging informed risk-taking as a necessary step to drive innovation and growth - marking a shift in tone from previous risk-averse approaches.

Other Notable Developments in the UK

• Basel 3.1: The PRA has confirmed that the UK will postpone the introduction of Basel 3.1 by one year, moving the implementation date to 1 January 2027. The delay provides additional time for alignment and clarity around the US approach.
• FCA Non-Financial Misconduct Survey: Reports a 72% rise in complaints since 2021, with bullying and discrimination accounting for a significant share.

Sustainability Simplification - A Global Theme

Simplification continues to dominate the sustainability agenda, with regulatory bodies aiming to ease reporting burdens while maintaining oversight.

EU: Omnibus Simplification Package

On 26 February, the European Commission published its long-awaited Omnibus package, proposing amendments to the CSRD and CSDDD. Highlights include:

• Postponing reporting deadlines for many companies until 2028
• Reducing the number of in-scope companies by up to 80%
• Proposed changes to the EU Taxonomy and CBAM

Negotiations are expected to move quickly given the current transposition deadline of 31 December 2025. We’ve prepared a detailed briefing - please get in touch if you’d like access.

UK: IFRS Alignment

In the UK, the government is set to endorse IFRS S1 and S2 as the basis for its first Sustainability Reporting Standards in Q1. These will apply to UK-listed companies and aim to align domestic reporting with international frameworks.

In Brief - Global Headlines

• EU Market Risk Framework Consultation: The European Commission is consulting on whether to implement market risk rules in 2026, delay to 2027, or apply targeted amendments. Deadline: 22 April.
• Canada is progressing mandatory climate disclosures and supply chain due diligence.
• UAE introduces carbon reporting for high emitters from June 2025.
• Australia releases ESG-antitrust guidance to support responsible collaboration.
• China adopts Basic Standards for Corporate Sustainability, embracing double materiality.
• EU AI Act came into effect in February; US rescinds its federal AI executive order, leaving a regulatory gap.

Gold Hits $3,000 - A Timely Reminder

Gold broke through the $3,000 mark in March - a milestone that warrants reflection. While record prices often signal investor confidence, they also raise the stakes when it comes to illicit interest. High value makes gold more attractive to those seeking to bypass controls.

Read more in my article for the Alchemist: 'Risk, Regulation and Resilience: The 2025 Compliance Playbook'

Thank you for taking the time to engage with this latest update from the Compliance team. To submit any questions or feedback, please reach out to us at [email protected].