Risk Sleuth
NTRS · 10-K filed 24 Feb 2026 · year to 31 Dec 2025

Northern Trust

29 named things its latest annual report says its results depend on, each in the company's own words. 18 of them are also named by other companies we've read.

Suppliers

Sub-custodians

depends onnamed as a risk
These risks are heightened by the fact that our operating model relies on the use of unaffiliated sub-custodians to a greater degree than certain of our competitors that have banking operations in more jurisdictions than we do.Risk factors (Item 1A)

Third-party IT and cloud service providers

depends onnamed as a risk
Third-party vendors provide key components of our business operations such as data processing, recording and monitoring transactions, online banking interfaces and services, and network access.Risk factors (Item 1A)

Other companies

The Northern Trust Company (Bank) dividends

depends onnamed as a risk
The Corporation relies in large part on dividends paid to it by the Bank to meet its obligations and to pay dividends to stockholders of the Corporation.Risk factors (Item 1A)

Places

Non-U.S. operations

earns from · 30% of our revenue in 2025named as a risk
Our non-U.S. operations accounted for 30% of our revenue in 2025.Risk factors (Item 1A)

Also named by AIG, ESI, FDS, MKC, MRSH, SOLS, TTMI

Asia-Pacific

concentrated in · 42% Asia-Pacific
The regional breakout of our employee base is 42% Asia-Pacific, 41% North America, and 17% Europe, Middle East, and Africa.Business (Item 1)

Also named by AIG, AVY, BLK, BNY, CCK, CL, COHR, DCI and 17 more

Russia

operates innamed as a risk
As of December 31, 2025, we held cash that accumulates in relation to Russian securities with our subcustodian and/or clearing agencies for the benefit of certain clients in our Asset Servicing business which are subject to restrictions that inhibit our ability to access or transfer such deposits, and which amount is expected to increase significantly over time as long as the sanctions and other relevant restrictions remain in effect.Risk factors (Item 1A)

Also named by ALSN, ATR, AVY, AXP, BKR, BSX, C, CDNA and 50 more

Regulators

Office of Foreign Assets Control (OFAC)

subject tonamed as a risk
If the Corporation or the Bank finds a sanctioned name or jurisdiction on any transaction, asset or account, the Corporation or the Bank may be required to reject or block such account or transaction and notify the appropriate authorities.Business (Item 1)

Also named by ABNB, ADP, AIG, APP, BMI, BMNR, BPOP, CAT and 46 more

Federal Reserve Board

subject tonamed as a risk
Under U.S. law, the Corporation is a bank holding company that has elected to be a financial holding company subject to the supervision, examination, and regulation of the Federal Reserve Board.Business (Item 1)

Also named by ALLY, AMP, BPOP, C, CFG, CFR, CME, COMP and 9 more

U.S. Securities and Exchange Commission (SEC)

subject to
Northern Trust Securities, Inc. and other subsidiaries of the Corporation are registered with the SEC as investment advisers and are subject to regulation by the SEC.Business (Item 1)

Also named by AB, ADSK, AMG, AMP, ARCC, ARES, BAM, BCSF and 44 more

U.S. Commodity Futures Trading Commission (CFTC)

subject to
The Bank is registered with the CFTC as a swap dealer and is subject to CFTC and NFA rules and supervision related to its swaps business.Business (Item 1)

Also named by AB, ADM, AGNC, AMG, BAC, BGC, BMNR, C and 35 more

Federal Deposit Insurance Corporation (FDIC)

subject to
The Bank is a member of the Federal Reserve System, with deposits insured by the Federal Deposit Insurance Corporation (FDIC) up to the federal deposit insurance limits, and is subject to regulation by both agencies.Business (Item 1)

Also named by AFRM, BAC, BNY, CASH, CFG, CFR, COF, FCFS and 27 more

European Central Bank (ECB)

subject to
For example, Northern Trust Global Services SE, as an EU-domiciled credit institution in Luxembourg, is subject to the prudential supervision of the ECB and the CSSF.Business (Item 1)

Also named by BNY, GS, JPM, PYPL, STT, V

Illinois Department of Financial and Professional Regulation

subject to
As an Illinois banking corporation, the Bank is also subject to Illinois state laws and regulations and to examination and supervision by the Division of Banking of the Illinois Department of Financial and Professional Regulation.Business (Item 1)

UK Prudential Regulation Authority and Financial Conduct Authority

subject to
They are authorized by the Prudential Regulation Authority (PRA) and/or the Financial Conduct Authority (FCA).Business (Item 1)

Australian Prudential Regulation Authority and Monetary Authority of Singapore

subject to
Additionally, the Bank is licensed as a foreign authorized deposit-taking institution in Australia under the Banking Act (Australia) and as a wholesale bank in Singapore under the Banking Act (Singapore) and as a result is subject to the supervision of the Australian Prudential Regulation Authority and the Monetary Authority of Singapore, respectively.Business (Item 1)

Laws and programs

General Data Protection Regulation (GDPR)

subject to · €20 million or 4% of their annual worldwide revenuenamed as a risk
Organizations that violate certain provisions of the GDPR could be fined up to €20 million or 4% of their annual worldwide revenue for the preceding fiscal year, whichever is greater.Business (Item 1)

Also named by A, AB, ABNB, ADBE, ADP, AGX, AIOT, AJG and 100 more

Long-Term Debt and clean holding company proposal

subject to · 6% of risk-weighted assets (RWA)named as a risk
If adopted, this proposal would require the Corporation and the Bank to each maintain a minimum outstanding eligible Long-Term Debt amount of no less than the greatest of (i) 6% of risk-weighted assets (RWA), (ii) 2.5% of total leverage exposure, and (iii) 3.5% of average total consolidated assets.Business (Item 1)

Also named by COF, TFC

Inflation Reduction Act of 2022 stock buyback excise tax

subject to · 1% excise taxnamed as a risk
The Inflation Reduction Act of 2022, imposes a 1% excise tax on the fair market value of stock repurchases after December 31, 2022.Risk factors (Item 1A)

FDIC special assessment

subject to · $83.4 million
In conjunction with the FDIC special assessment rules, Northern Trust has accrued a total of $83.4 million.Business (Item 1)

Also named by BPOP, CFG, CFR, CUBI, EFSC, EWBC, FCNCA, GBCI and 10 more

Federal Reserve stress capital buffer

subject to · 2.5%
On February 4, 2026, the Federal Reserve notified the Corporation that because the Stress Testing Transparency Proposal remains subject to public comment, absent further action from the Federal Reserve, the Corporation’s stress capital buffer requirement will remain at 2.5% until September 30, 2027.Business (Item 1)

EU AI Act

subject tonamed as a risk
The EU AI Act will have a significant impact on organizations that develop, deploy, or use AI systems both inside and outside the EU.Business (Item 1)

Also named by ACN, ADBE, AMD, AXON, CGNX, CRM, CRWD, CTSH and 36 more

GENIUS Act

subject tonamed as a risk
Widespread adoption and rapid evolution of emerging technologies, including with respect to digital assets, such as stablecoins, as well as developments in the regulatory landscape relating to emerging technologies, such as the enactment and implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (GENIUS ACT) and potential enactment of the Digital Asst Market Clarity Act of 2025 (CLARITY Act) or similar market structure legislation, may affect our clients’ needs and expectations for products and services.Risk factors (Item 1A)

Also named by AUB, C, CFR, COF, COIN, CUBI, EWBC, FCNCA and 15 more

Basel III Endgame Proposal

subject tonamed as a risk
The potential impacts on the Corporation and the Bank of a final rule remain uncertain until a final rule is published.Business (Item 1)

Also named by ALLY, CFG, HBAN, PNC, RF, STT

Bank Secrecy Act / USA PATRIOT Act

subject tonamed as a risk
Certain subsidiaries of the Corporation are subject to the Bank Secrecy Act of 1970, as amended by the USA PATRIOT Act of 2001 and Anti-Money Laundering Act of 2020 and implemented in the regulations of the federal banking regulators and the Financial Crimes Enforcement Network (FinCEN), which requires banks and other financial institutions to comply with anti-money laundering (AML) and financial transparency requirements, such as conducting due diligence, verifying client and beneficial owner identification, and monitoring client transactions and detecting and reporting suspicious activities.Business (Item 1)

Also named by EEFT, RF

UK Financial Services and Markets Act 2023

subject tonamed as a risk
Consequently, over time it is likely that the rules and regulations relating to financial services will diverge, which may result in additional compliance costs for our UK and EU businesses.Risk factors (Item 1A)

Volcker Rule

subject to
Northern Trust maintains an enterprise-wide compliance program to comply with the Volcker Rule.Business (Item 1)

Also named by AMP, BAC, GS, HBAN, MS, PNC, RJF, SCHW and 5 more

Dodd-Frank Act Section 165(d) resolution planning

subject to
As required by Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Corporation is required to submit periodically to the Federal Reserve Board and FDIC a resolution plan for its rapid and orderly resolution in the event of material financial distress or failure.Business (Item 1)

Also named by PNC

Federal Reserve enhanced prudential standards (Category II)

subject to
Under the Federal Reserve Board’s tailoring rules, the Corporation is subject to the enhanced prudential standards applicable to Category II banking organizations.Business (Item 1)

EU Bank Recovery and Resolution Directive (BRRD)

subject to
As such, Northern Trust Global Services SE falls within the scope of the BRRD and its recovery and resolution planning is overseen by the CSSF and the CSSF Resolution Board.Business (Item 1)