Ten recommendations, one clear signal: TTMF directs transatlantic regulation to move as one

Financial institutions with UK and US operations should treat the TTMF recommendations as a live signal of where regulatory frameworks and commercial opportunity are heading and be prepared to react accordingly.

Digital assets recommendations

Private sector-led testing of cross-border tokenized asset use cases
A private sector-led group will spend the next year testing cross-border use cases for tokenized assets and feeding best practice back to regulators.

This is a genuine opportunity for institutions to help shape the standards the industry will later have to follow, rather than wait to be told the rules. Regulators are handing industry the pen; the question is who picks it up first.

Common regulatory approaches to tokenized assets
The Bank of England, CFTC, FCA and SEC will work toward common approaches on settlement finality for tokenized securities transactions and, significantly, whether stablecoins and tokenized money market funds can count as margin collateral at central counterparties.

This collateral question deserves more attention than it has received. If it lands as expected, it is a direct capital efficiency lever for repo and derivatives desks and treasury functions, arguably more consequential day to day than the tokenization testing group itself.

A policy framework for a multi-money ecosystem
The UK and US will support financial innovation through policy frameworks in which stablecoins, tokenized deposits and other forms of digital money can coexist to deliver benefits for consumers and businesses.

This is a clear policy signal that no single form of digital money is expected to displace all others. Product and treasury strategies should therefore be premised on an ecosystem approach rather than an assumption that tokenized deposits or other products will have an exclusive role to play.

Targeted review of Basel Committee prudential standards for crypto assets
The UK and US will support a targeted review of prudential standards for crypto assets at the Basel Committee on Banking Supervision, aiming for rules that are future-proofed, technology-neutral and evidence-based.

Basel remains the body that will actually set any new standard, but the UK and US are positioning themselves as the ones driving the agenda, rather than simply waiting on Basel to move first. Banks currently absorbing what the industry regards as disproportionately conservative capital charges for crypto exposure have a genuine opening here to make their case.

UK-US joint statement on stablecoins
The UK and US have now published a joint statement on stablecoins: ten shared principles guiding their developing regulatory and legislative regimes. It affirms stablecoins as a legitimate vehicle for digital money innovation, commits both governments to enabling their cross-border use in payments and capital markets and sets shared expectations on reserve backing, custody and insolvency treatment.

The substance sits in three commitments: stablecoins must be backed at least one-to-one by high-quality liquid assets, reserves must be segregated from the issuer's own funds and holders receive a protected legal claim on reserves ahead of other creditors if an issuer fails. These track closely to the US GENIUS Act's reserve and custody requirements, and both governments have signaled an intent to converge their regimes where doing so serves their shared interests.

Capital markets recommendations

FCA and SEC staff to explore options to ease cross-border capital raising
FCA and SEC staff will jointly assess potential staff-level actions to provide clarity to market participants and address frictions or impediments to cross-border capital raising.

No specific proposals exist yet, but staff-level guidance of this kind tends to move faster than formal rulemaking, so institutions should not assume they have time to wait. This is one of the more open-ended recommendations, which means it needs to be watched closely.

Reform of the SEC's Foreign Private Issuer framework
Following the SEC's June 2025 Foreign Private Issuer (FPI) Concept Release, SEC staff are considering rulemaking recommendations and will factor in FCA views on how the UK's regulatory and disclosure standards should be reflected in the treatment of UK FPIs.

This recommendation and the SEC's own, separate FPI rulemaking process are two halves of the same story. UK issuers with US listing ambitions, including UK-domiciled insurers with FPI status, should track both work-streams together; the TTMF recommendation will influence, but not control, where the SEC's rule ultimately lands.

FCA-SEC collaboration on consolidated tape transparency
As the UK's consolidated tapes come into effect, the FCA and SEC will explore opportunities to collaborate to support and enhance transparency between the UK and US approach.

This is a simple but genuine dividend for anyone currently managing fragmented market data and best execution obligations across both markets. It will not make headlines, but it will make it into compliance budgets.

Converting UK Swap Execution Facility relief into substituted compliance
The CFTC and FCA intend to explore converting existing temporary no-action relief for UK Swap Execution Facilities into a longer-term substituted compliance determination before its current expiry date and to assess existing supervisory cooperation arrangements.

A permanent arrangement would materially cut dual-compliance costs for derivatives desks.

Reaffirmed commitment to global accounting and auditing standards
The UK and US reaffirm a shared commitment to high-quality, proportionate, globally accepted accounting and auditing standards, with the FCA, PRA, SEC and other authorities collaborating internationally to strengthen standard-setting bodies.

This recommendation commits both governments to continued engagement with international standard-setters, with an emphasis on together seeking to influence best practice.

Note: UK industry engagement in the TTMF was led by Eversheds Sutherland partner and Global Head of Financial Services Matthew Allen in his capacity as Chair of the US Market Advisory Group at TheCityUK.

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If you have any questions about this Legal Briefing, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work.