Fiscal period ending 2025-12-31 versus 2024-12-31
— view filing on EDGAR →
Risk exposure has broadened materially across five or more distinct themes, with no offsetting easings — regulatory, competitive, cyber, liquidity, and operational risks all escalated in the same filing cycle. The most acute escalations are the explicit liquidity and default-fund insufficiency disclosure, a named AWS outage, and a new acknowledgment that risk management controls may be inadequate in the current environment. Digital asset and tokenization regulatory uncertainty, geopolitical data-sharing constraints, and expanded AI-specific operational and legal exposures compound an already deteriorating risk profile.
7 company-specific
· 4 common-mode
Company-specific changes
Revised
New disclosure of digital assets regulatory uncertainty and competitive risk from less-regulated entrants in tokenized securities and synthetic assets.
RISKS RELATED TO LEGAL AND REGULATORY MATTERS We operate several of our businesses in highly regulated industries and may be subject to censures, fines and enforcement proceedings if we fail to…
Revised
SEC fee rule petition denied; exemptive relief expires November 2026. New risks from digital assets, tokenization, prediction market regulation added.
Regulatory changes and changes in market structure and proprietary data could have a material adverse effect on our business. Regulatory changes adopted by the SEC or other regulators with respect to…
Revised
Added specific new competitive threats: tokenized equity securities, ETPs, extended trading hours, and tech company competition for Capital Access/FinTech products. Escalates competitive risk profile.
The industries we operate in are highly competitive. We face significant competition in our Capital Access Platforms, Financial Technology and Market Services segments from other market participants.…
Revised
Added specific emerging technology risks: tokenized equity securities, ETPs, extended trading hours. Escalates from generic tech change to concrete regulatory/market developments requiring platform adaptation.
The success of our business depends on our ability to keep up with rapid technological and other competitive changes affecting our industry. Specifically, we must complete development of…
Revised
Revised disclosure now explicitly highlights liquidity risks, default fund insufficiencies, and adds reputational, regulatory, and litigation consequences from counterparty failures—material escalation.
We are exposed to credit, liquidity and counterparty risks from our clearinghouse operations and third-party relationships that could adversely affect our financial position and results of…
Revised
Added disclosure of actual AWS outage in October 2025 affecting certain offerings, plus new vendor transition and correlated disruption risks.
We rely on third parties to perform certain functions, and our business could be adversely affected if these third parties fail to perform as expected or experience service interruptions affecting…
Revised
New disclosure of specific regulatory frameworks in Europe and explicit risk of fines/penalties for non-compliance escalates regulatory exposure beyond prior year's general sustainability language.
Climate and weather related risk may have an adverse impact on our business, while simultaneously, we face reputational, regulatory and financial risks related to our ability to respond to diverse…
Also disclosed — common-mode (Geopolitical macro uncertainty ×2, Third party AI vendor dependency, AI regulatory compliance)
Geopolitical macro uncertainty
Revised
New specific risks disclosed: data-sharing constraints with U.S. and reduced regional operational support, suggesting escalating geopolitical tensions affecting business operations.
Our businesses operate in various international markets, which are subject to political, economic and social uncertainties. Our businesses operate in various international markets, including but not…
Geopolitical macro uncertainty
Revised
New disclosure of heightened cyber threats during geopolitical uncertainty and war, targeting exchange infrastructure and international employees—a material escalation of risk.
Our role in the global marketplace positions us at greater risk for a cyberattack. Our systems and operations are vulnerable to damage, misappropriation or disruption from security breaches. Some of…
Third party AI vendor dependency
Revised
Added material new risks: agentic AI, third-party model dependency, IP infringement liability, and autonomous decision-making risks. Escalates from general AI concerns to specific operational and legal exposures.
Our AI initiatives and the use of AI in certain of our existing products may be unsuccessful and may give rise to various risks, which could adversely affect our business, reputation, or operating…
AI regulatory compliance
Revised
New disclosure that "rapidly changing environment may limit effectiveness" of risk management methods escalates governance risk by acknowledging environmental constraints on control adequacy.
If our risk management methods are not effective, our business, reputation and financial results may be adversely affected. We utilize widely-accepted methods to identify, assess, monitor and manage…