While the update mentions investment firms and cross-border services, it is primarily an administrative reporting requirement for investment firms that does not directly regulate payment services, client money handling, or payment-specific conduct.
Cross-Border Payments (25%)The circular references AML/CTF obligations and cross-border activity, but these are supervisory reporting requirements rather than substantive payment service regulation or enforcement action.
The circular mandates cross-border investment services reporting by Cypriot Investment Firms to CySEC, which is a regulatory reporting obligation requiring submission of data on client activity and service provision.
Supervision (72%)Low confidence — requires human review. The circular mentions AML/CTF notification requirements and potential administrative penalties for non-compliance, but these are secondary to the primary reporting mandate and lack specificity on enforcement action.
CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]
Horizon Scanning Outline.
Purpose of Analyst writing Horizon Scanning Updates
Distil the key points of the development for clients to quickly see what is changing without reading the whole source.
Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes.
Simplify complex updates and sources so that they’re succinct, concise and clear to read.
Consistently structure and write updates in the same format.
Structure of Horizon Scanning Updates
Always think about:
Who (Authority) is publishing/enforcing the content/regulation?
Where (Jurisdiction)?
What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed?
Who is this update applicable to (credit, e-money institutions, etc.)?
Why is this update noteworthy? What is its significance?
When is the update applicable?
Title
Describe what the update is about.
Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what).
All titles should be written in present tense.
Avoid using acronyms
Approx 10 - 20 words
Example
Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance
Paragraph 1
Open with the date of the update (When)
Name the authority that released the update (Who)
Summarise the release (What)
Example
On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets.
Paragraph 2
Summarise key points.
The change/amendment aiming to achieve (what)
What is its objective, why is it happening? Why is it significant? (why)
Who does it impact or concern? (Who)
The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document.
Example
SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to:
Study Indian and global best practices.
Prepare the guidelines.
Address the concerns and issues arising from AI/ML usage.
SEBI is consulting on the following principles to develop the guidelines:
Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models.
Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information.
Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results.
Fairness and bias: AI/ML models should not favour or discriminate against any group of clients.
Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security.
Paragraph 3
Acts as a “Call To Action”. Provide forward looking context:
What actions need to be taken?
Who needs to take action?
Next steps to the development.
Include any relevant dates (When)
Response dates - should always be provided for consultations
Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted.
Example
The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026.
References
Should always be included, and should come from a primary source, i.e., an authority, not a news source.
General Style Notes:
200-250 words
Active voice
Authorities and companies referenced as a single entity (“It”, not “they”)
Titles in title case
Internal Vixio vocabulary guide
Content Style Guide
Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content.
A
Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA).
Act - when just referring to “the act”, it does not need a capital a.
Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell).
- advice (noun) - give formal suggestions (for example, I gave them advice).
Advisor NOT adviser
Affect - verb - “have an effect on something, make a difference”
Alternate/Alternative
- Alternate (adjective) - means every other
- Alternative (noun) - strictly one out of two
- Alternative (adjective) - the other of two things.
Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”.
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
Among/while NOT Amongst/whilst
API - application programming interface
Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act.
Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”.
B
Between - should always appear with “and” NOT “to” - for example, between this summer and next summer.
Big tech - two words, breaks convention of other tech words
Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522).
Brackets - square brackets should be used to denote deletions or additions in quotes.
Buy now, pay later - no hyphens
Bullet points - see Lists
C
Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a)
Cardrooms not card rooms
Cases - legal cases should appear in italics, with a v for versus.
Casino-resorts NOT casino resorts or resort-casinos
Chief executive NOT chief executive officer
Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes)
Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000)
Comparisons - compare with (highlighting differences)
- compare to (highlighting similarities)
Companies/organisations - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Ltd, not Limited
Complement - to accompany something/add value
Compliment - give praise (complimentary = free)
Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings)
Comprise/comprising - should NOT be followed with “of”, as it means to “consist of”
Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,)
Continually - if something occurs repeatedly/regularly in the same way
Continuously - if something occurs without interruption or gaps
Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone)
Contrast - by contrast - when comparing one thing to another
- in contrast - simply noting a difference
Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting
Court of Justice of the European Union (CJEU) rather than ECJ
Cryptocurrency - one word, not hyphenated.
Crypto-assets - hyphenated
Cybersecurity - one word, not hyphenated
CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism
Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar)
m for million, bn for billion, trn for trillion.
D
Date format - Month, Day, Year (e.g., March 7, 2019)
For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…”
For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...”
For NIBs: always use dates rather than days.
Department for Digital, Culture, Media & Sport - ampersand
Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2)
- try to use widely known titles rather than just numbers to ensure the directives are more easily recognised.
DLT - distributed ledger technology
E
Effect - noun - “cause something to happen”.
Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–).
Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”.
esports NOT eSports or e-sports
Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”.
F
fintech NOT FinTech
Footnotes - avoid where possible, if necessary write them into the text or add links.
G
GGR - “gross gaming revenues”
Government - does not need a capital g.
Governor - should be written out in full, NOT Gov.
Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines)
H
Headlines - all words should begin with a capital
Horseracing NOT horse racing
Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money
- DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper
I
Impact - should be used as a noun - i.e. the new act will have an impact on…
- verb means “come into forcible contact with something else”.
- using “affect” as a verb is more accurate.
J
Judgment - legal decision
Judgement - one’s own opinion
Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters.
Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive.
OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur
DON’T need capitals unless a figure of importance (i.e., Prime Minister, President)
Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be.
Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team).
K
KYC - know your customer
L
Legislature - does not need a capital l.
Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables.
Licence - noun (UK), i.e. a driver’s licence
License - verb/noun (US)
Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent).
M
MONEYVAL NOT Moneyval
More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players.
N
Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive.
Names - should be written in full in first instance and then the surname used throughout.
Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences.
Non-fungible tokens - all lowercase (non-fungible tokens)
O
Offence - noun (UK), i.e. commit an offence
Offense - noun (US)
Organisations/companies - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears).
Over - should not be used as a replacement for “more than”.
P
Parliament - does not need a capital p.
Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act
Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”.
- passed is the past tense of “to pass” - “the law was passed in government”.
Prepaid, not pre-paid
Percentages - numbers should always be written as figures
percent NOT per cent or %
Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent)
Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to”
Principal - main, most important
Principle - a fundamental source or basis of something
Programme (UK)
Program (US, UK - for computer program, Australian English)
Q
Quotes - speaker should be referenced in the past tense (said NOT says)
Quote marks - double quote marks should be used for speech
- single quote marks should only be used for titles and within quotes.
(See Quote reference sheet for more information on how to use quotes.)
R
regtech NOT RegTech
Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines)
Racetracks not race tracks
S
Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018.
Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act.
Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.)
Sports betting NOT sportsbetting
Sports team names
Storey (pl. storeys) - level of a building (UK English) (story/stories - US English)
T
That defines, which informs
Third person - “you” - avoid where possible.
Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a)
Tenses - content should generally be written in past tense
- present tense should be used for something that has just happened and will be continuing into the future.
U
United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC
USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”)
U.S. Department of Justice - Justice Department (with capitals as requested)
V
Vixio GamblingCompliance / Vixio PaymentsCompliance
Vixio (to be used on its own after first instance)
W
Which informs, that defines
While/among NOT Whilst/amongst
While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”.
X
Y
Year quarters - Q1, Q2, H1, H2, etc.
Z
Acronyms
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
API - application programming interface
DLT - distributed ledger technology
Horizon Scanning Outline.
Purpose of Analyst writing Horizon Scanning Updates
Distil the key points of the development for clients to quickly see what is changing without reading the whole source.
Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes.
Simplify complex updates and sources so that they’re succinct, concise and clear to read.
Consistently structure and write updates in the same format.
Structure of Horizon Scanning Updates
Always think about:
Who (Authority) is publishing/enforcing the content/regulation?
Where (Jurisdiction)?
What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed?
Who is this update applicable to (credit, e-money institutions, etc.)?
Why is this update noteworthy? What is its significance?
When is the update applicable?
Title
Describe what the update is about.
Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what).
All titles should be written in present tense.
Avoid using acronyms
Approx 10 - 20 words
Example
Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance
Paragraph 1
Open with the date of the update (When)
Name the authority that released the update (Who)
Summarise the release (What)
Example
On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets.
Paragraph 2
Summarise key points.
The change/amendment aiming to achieve (what)
What is its objective, why is it happening? Why is it significant? (why)
Who does it impact or concern? (Who)
The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document.
Example
SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to:
Study Indian and global best practices.
Prepare the guidelines.
Address the concerns and issues arising from AI/ML usage.
SEBI is consulting on the following principles to develop the guidelines:
Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models.
Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information.
Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results.
Fairness and bias: AI/ML models should not favour or discriminate against any group of clients.
Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security.
Paragraph 3
Acts as a “Call To Action”. Provide forward looking context:
What actions need to be taken?
Who needs to take action?
Next steps to the development.
Include any relevant dates (When)
Response dates - should always be provided for consultations
Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted.
Example
The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026.
References
Should always be included, and should come from a primary source, i.e., an authority, not a news source.
General Style Notes:
200-250 words
Active voice
Authorities and companies referenced as a single entity (“It”, not “they”)
Titles in title case
Internal Vixio vocabulary guide
Content Style Guide
Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content.
A
Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA).
Act - when just referring to “the act”, it does not need a capital a.
Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell).
- advice (noun) - give formal suggestions (for example, I gave them advice).
Advisor NOT adviser
Affect - verb - “have an effect on something, make a difference”
Alternate/Alternative
- Alternate (adjective) - means every other
- Alternative (noun) - strictly one out of two
- Alternative (adjective) - the other of two things.
Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”.
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
Among/while NOT Amongst/whilst
API - application programming interface
Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act.
Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”.
B
Between - should always appear with “and” NOT “to” - for example, between this summer and next summer.
Big tech - two words, breaks convention of other tech words
Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522).
Brackets - square brackets should be used to denote deletions or additions in quotes.
Buy now, pay later - no hyphens
Bullet points - see Lists
C
Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a)
Cardrooms not card rooms
Cases - legal cases should appear in italics, with a v for versus.
Casino-resorts NOT casino resorts or resort-casinos
Chief executive NOT chief executive officer
Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes)
Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000)
Comparisons - compare with (highlighting differences)
- compare to (highlighting similarities)
Companies/organisations - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Ltd, not Limited
Complement - to accompany something/add value
Compliment - give praise (complimentary = free)
Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings)
Comprise/comprising - should NOT be followed with “of”, as it means to “consist of”
Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,)
Continually - if something occurs repeatedly/regularly in the same way
Continuously - if something occurs without interruption or gaps
Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone)
Contrast - by contrast - when comparing one thing to another
- in contrast - simply noting a difference
Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting
Court of Justice of the European Union (CJEU) rather than ECJ
Cryptocurrency - one word, not hyphenated.
Crypto-assets - hyphenated
Cybersecurity - one word, not hyphenated
CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism
Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar)
m for million, bn for billion, trn for trillion.
D
Date format - Month, Day, Year (e.g., March 7, 2019)
For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…”
For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...”
For NIBs: always use dates rather than days.
Department for Digital, Culture, Media & Sport - ampersand
Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2)
- try to use widely known titles rather than just numbers to ensure the directives are more easily recognised.
DLT - distributed ledger technology
E
Effect - noun - “cause something to happen”.
Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–).
Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”.
esports NOT eSports or e-sports
Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”.
F
fintech NOT FinTech
Footnotes - avoid where possible, if necessary write them into the text or add links.
G
GGR - “gross gaming revenues”
Government - does not need a capital g.
Governor - should be written out in full, NOT Gov.
Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines)
H
Headlines - all words should begin with a capital
Horseracing NOT horse racing
Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money
- DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper
I
Impact - should be used as a noun - i.e. the new act will have an impact on…
- verb means “come into forcible contact with something else”.
- using “affect” as a verb is more accurate.
J
Judgment - legal decision
Judgement - one’s own opinion
Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters.
Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive.
OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur
DON’T need capitals unless a figure of importance (i.e., Prime Minister, President)
Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be.
Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team).
K
KYC - know your customer
L
Legislature - does not need a capital l.
Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables.
Licence - noun (UK), i.e. a driver’s licence
License - verb/noun (US)
Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent).
M
MONEYVAL NOT Moneyval
More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players.
N
Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive.
Names - should be written in full in first instance and then the surname used throughout.
Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences.
Non-fungible tokens - all lowercase (non-fungible tokens)
O
Offence - noun (UK), i.e. commit an offence
Offense - noun (US)
Organisations/companies - singular entities (it NOT they)
should be followed by “which/that” rather than “who”
Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears).
Over - should not be used as a replacement for “more than”.
P
Parliament - does not need a capital p.
Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act
Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE))
Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”.
- passed is the past tense of “to pass” - “the law was passed in government”.
Prepaid, not pre-paid
Percentages - numbers should always be written as figures
percent NOT per cent or %
Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent)
Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s).
Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to”
Principal - main, most important
Principle - a fundamental source or basis of something
Programme (UK)
Program (US, UK - for computer program, Australian English)
Q
Quotes - speaker should be referenced in the past tense (said NOT says)
Quote marks - double quote marks should be used for speech
- single quote marks should only be used for titles and within quotes.
(See Quote reference sheet for more information on how to use quotes.)
R
regtech NOT RegTech
Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines)
Racetracks not race tracks
S
Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018.
Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act.
Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.)
Sports betting NOT sportsbetting
Sports team names
Storey (pl. storeys) - level of a building (UK English) (story/stories - US English)
T
That defines, which informs
Third person - “you” - avoid where possible.
Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a)
Tenses - content should generally be written in past tense
- present tense should be used for something that has just happened and will be continuing into the future.
U
United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC
USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”)
U.S. Department of Justice - Justice Department (with capitals as requested)
V
Vixio GamblingCompliance / Vixio PaymentsCompliance
Vixio (to be used on its own after first instance)
W
Which informs, that defines
While/among NOT Whilst/amongst
While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”.
X
Y
Year quarters - Q1, Q2, H1, H2, etc.
Z
Acronyms
AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT
API - application programming interface
DLT - distributed ledger technology
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Now, given the above instructions and style guide, please generate a horizon scanning
update based on the following webpage content. Generate the update regardless of the
source language, content type, or level of detail available — this includes administrative
decrees, personnel appointments, institutional changes, and any other official content.
Use whatever information is present.
TO : Cyprus Investment Firms (‘CIFs’) FROM : Cyprus Securities and Exchange Commission (‘CySEC’) DATE : February 25, 2026 CIRCULAR No : C757 FILE No : E.K. 02.03.001, E.K. 01.03.001 and E.K. 01.13.001.002.002 SUBJECT : Electronic Cross-Border Form, Freedom to Provide Investment Services and Activities(‘Cross Border Activity’) The present Circular is issued pursuant to section 25(1)(c)(ii) & (iii) of the Cyprus Securities and Exchange Commission Law (‘the CySEC Law’). The exercise is initiated by the European Securities and Markets Authority (‘ESMA’) and is addressed to all Investment Firms (‘Firms’) providing investment services in other Member States of the European Economic Area (i.e. including Norway, Iceland, and Liechtenstein), other than their home Member State, during the year 2025. Following Circular C754, the present circular provides detailed information regarding the completion of the online questionnaire via EU’s online platform. The information below, is addressed to Cypriot Investment Firms (‘CIFs’) that fulfil the conditions set out in point 1.1 of Circular C754. 1. General Information 1.1. Information collected through the Cross-border online questionnaire on the CIFs’ cross border activity refers to the reporting period 01/01/2025 – 31/12/2025 and reference date 31/12/2025, as relevant. 1.2. CIFs are required to report data on the cross-border provision of investment services to retail clients in the EU/EEA, only for those host Member States where services were provided to more than 50 retail clients (including those treated as professionals according to Section II of Annex II of MiFID II). 1.2.1. Provision of Cross-border services in other Member States refers to services and activities provided on a “freedom to provide services” basis and CIFs should not account for any services and activities provided on a “freedom of establishment” basis (i.e. through a branch). 1.2.2. CIFs should exclude inactive clients from their reporting. For the purposes of this exercise, clients are considered to be inactive only if the following conditions are cumulatively met: 2 i) client’s inactivity lasted for at least one year, ii) no investment or ancillary services were provided to the client, and iii) the CIF no longer receives any revenues from such clients. Regarding iii), if the CIF is still receiving any form of remuneration from the client during the inactivity period (for instance, the client has a securities account, that has not been holding any securities for more than a year, but during this time the CIF is still receiving a fee because the account is still open), we would expect such clients to be accounted for in the CIF’s reporting. 1.2.3. CIFs may use the residence of the client to assess whether investment services and activities are provided in other Member States. 1.3. CIFs must submit a separate contribution for each host Member State that qualifies under 1.2 above, e.g. if the CIF provides investment services to more than 50 retail clients in four host Member States, the online questionnaire should be filled out and submitted four times, one for each host Member State. 1.4. CIFs should not submit a contribution for their home Member State, i.e. Cyprus. 2. Procedural Information 2.1. An email with the link and password to access the online questionnaire will be sent out to all CIFs that fulfil the conditions set out in point 1.1 of Circular C754. 2.2. Participating CIFs must complete the online questionnaire and submit their contribution for each host Member State that qualifies under 1.2 above, by 27th of March 2026, at the latest. 2.3. Upon successful submission of the Form, the message “Contribution successfully submitted” and a contribution ID will be populated on the screen. As per the below image, you can request a print of your contribution or have your contribution sent to your email in a PDF format. 2.4. CIFs are advised to save the contribution ID for each Member State, for reference purposes. 3 2.5. In case the CIF needs to correct the data submitted with respect to a specific host Member State, it is necessary to resubmit the questionnaire for the relevant host Member State, with the corrected data. 2.6. In case an error concerns the host Member State identification itself, and the CIF has provided information for a host Member State that should not have been included, the CIF can correct this by resubmitting the questionnaire for that host Member State introducing the value zero “0” in response to question number 8 (number of active retail clients). 2.7. Any enquiries regarding the completion of the form shall be directed to riskstatistics.cifs@cysec.gov.cy any day PRIOR to 20th of March 2026, at the latest. 3. Important changes compared to past exercise 3.1. Deletion of the “save as draft” function. This year, the EU Survey tool does not allow firms to temporarily save a draft of their contribution and return to complete it at a later stage. In this respect, CIFs are advised to complete and submit their contribution for each Member State in a single session. 3.2. Deletion of the “edit contribution” function. This year, the EU survey tool has deactivated the option that allows firms to modify their contribution after submission, to ensure that each entry remains fixed once submitted. In this respect, to make corrections regarding contributions already submitted, please refer to points (2.5) and (2.6) above. 3.3. A new category “Cash management”, has been added under Question 11, taking into consideration the definition of inactive clients in the reporting template. This category includes situations where a client has a securities account that has not been holding any securities for more than a year, but during this time the firm is still receiving a fee because the account is still open (e.g., account maintenance charges, inactivity fee). 3.4. Upon submission of their contributions, CIFs are required to notify CySEC by sending an email to riskstatistics.cifs@cysec.gov.cy, specifying, for each host Member State, the number of complaints directly attributable to AML/CFT obligations, out of the total number of complaints declared in the relevant contribution for that Member State. This would cover cases where clients expressed dissatisfaction as a result of facing restrictions affecting their investment or trading activity and/or overall client experience — including, inter alia, issues with deposits, withdrawals or account access — where the underlying root cause stemmed from the application of AML/CFT regulatory requirements. Indicative examples include: • account restrictions pending the submission of verification documentation; • delays in processing deposits due to Source of Funds checks; • withdrawal limitations where the recipient account differs from the original source of funds; • account closures due to missing due diligence documentation. 4 For the avoidance of doubt, these indicative examples are provided solely for the purpose of facilitating this specific statistical reporting request. They do not constitute an assessment, endorsement or validation by CySEC of the lawfulness and/or proportionality of any specific action or practice adopted by a CIF in the context of AML/CFT compliance. Neither the above examples nor any other client complaint considered by the CIFs directly attributable to AML/CFT obligations should be interpreted as implying that such cases fall outside the scope of client complaints within the meaning of the applicable MiFID II framework. 4. Specific Instructions for the completion of the Online Questionnaire 4.1. CIFs are prompted at the importance of successfully completing the online questionnaire by the set deadline (as set out in point 2.2), and are encouraged to diligently follow the instructions below, as these will ultimately dictate whether a successful submission has been made. 4.2. The reporting template is composed of two Sections: • Information on the Firm (legal name, type of firm, LEI) and contact person within the firm for this reporting template. CIFs must ensure that the information provided is valid and accurate. • Detailed information on the cross-border provision of MiFID investment services to retail clients (and clients treated as professionals on request according to Section II of Annex II of MiFID II). ➢ For every contribution that will be submitted, in point 7 of the form, CIFs should select the respective host Member state for which the questionnaire is completed, regarding the cross-border services offered to more than 50 retail clients, in that specific host Member state. ➢ In point 12 of the form, CIFs should enter the total net turnover as a whole number without using decimals or any separators for thousands, such as commas (,) full stops (.) or spaces. If decimals need to be included, please note that the full stop (.) is used as the decimal separator, not for thousands and it is limited to two decimals. ➢ For some questions, additional instructions on the form are available, to help CIFs complete the survey. CIFs are advised to click on the question mark (?) next to the respective question, to view the additional instructions provided. ➢ Some fields will automatically verify the consistency of the information provided and CIFs will not be able to submit the information in case of errors. Specific details are available alongside the validation cells, under the question mark. CIFs are advised to click on the question mark (?) next to the respective validation check, to ensure the validity of the data reported. ➢ During the completion of the questionnaire CIFs are encouraged to allow reasonable time for the page to load properly, before clicking on the submit button at the bottom of the page. 5 Failure to promptly and duly comply with the above may bear the administrative penalties of section 37(5) of the CySEC Law. It is further noted that CySEC will not send any reminders to participating CIFs, which fail to promptly and duly comply. Yours sincerely, Dr George Theocharides Chairman, Cyprus Securities and Exchange Commission