← The ARM Radar Capital Structuring Briefing

23 August 2026

Published 06:30 Brussels

Briefing · 23 August 2026

AMLA reviews EU payment-firm AML contact points; FCA renews warning on unregulated capital-raising notes

Luxembourg
21 Aug 2026 Luxembourg T2–T4 Disclosure & AML

AMLA surveys EU payment firms on Central Contact Point framework

AMLA has opened a voluntary survey, running until 15 September 2026, asking electronic money institutions and payment service providers about their experience with the current framework for Central Contact Points — the local AML/CFT liaison function branch operators must maintain when passporting into other EU member states. Luxembourg's CSSF circulated the survey to its supervised population, framing it as an early step in reviewing how the requirement operates in practice.

Implications for capital — Firms operating EMI or payment-institution branch networks across the EU should expect survey findings to inform eventual guidance or rule changes to cross-border AML liaison arrangements, though no proposal has yet been published.

Source: CSSF

United Kingdom
20 Aug 2026 United Kingdom T1–T2 Disclosure & AML

FCA renews mini-bond warning after Woodville Consultants collapse

The FCA has restated its warning against unregulated loan notes and mini-bonds following the administration of Woodville Consultants Ltd, a litigation funder that had raised retail capital through unregulated loan notes. The regulator reiterated that marketing such speculative illiquid securities to retail investors has been banned since January 2021, that a new regime governing public offers of securities has applied since January 2026, and that holders of these instruments typically fall outside Financial Ombudsman Service and Financial Services Compensation Scheme protection.

Implications for capital — Capital raised through unregulated loan notes and mini-bonds continues to sit outside the FCA's protection and compensation framework; vehicles marketing such instruments to UK retail investors remain exposed to regulatory scrutiny and potential enforcement referral.

Source: Financial Conduct Authority