European regulators have in the past identified global custodians as comparable with central securities depositories (CSDs), especially when they internalise settlement.

Following several high profile thefts from private registries of carbon credit markets in Europe, the European Commission suspended most of its Emissions Trading Schemes in the EU.

In the wake of the global financial crisis, Tier 1 and 2 banks and brokers have, or are reviewing, their procedures for monitoring risk across their global sub-custodian network.

We have been here before when CESR tried to regulate CSDs as if they were banks.

The European Commission seems now to be in favour of a dedicated legislative instrument to define and regulate CSDs in the EU.