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Faces and breaches: ICO doubles down on tailored approach to UK data enforcement In the first few weeks of 2023, the ICO has continued to espouse its commitment to exercising its full spectrum of enforcement powers. Monetary penalties increasingly form only a small part of the UK’s regulatory picture as the ICO shifts from blunt,...
UK and US Governments crack down on ransomware criminals Handling ransom demands (and whether it possible and/or desirable to pay) is one of the most critical aspects of managing a cyber attack. This involves considering the applicable, and evolving, sanctions position, among other risks. Last week, the UK and...
Bizkaia: a tax ecosystem for entrepreneurs Although the recent approval of the Start-up Law in the “common” Spanish territory (as opposed to the historic territorios forales of the Basque Country and Navarre) is to be applauded (see previous posts for example here and here), it is nevertheless...
BMW AG v CMA ruling - No extraterritorial effect for CMA's investigatory powers The Competition Appeal Tribunal (CAT) and High Court have issued a single ruling in Bayerische Motoren Werke AG v Competition and Markets Authority [2023] CAT 7 relating to an appeal by BMW AG and an application for judicial review by Volkswagen AG, which...
The Lords vs LDI In September 2022, the UK's central bank, the Bank of England, was forced to intervene in the gilt market to the tune of £19.3 billion after the UK Prime Minister at the time, Liz Truss’, “mini budget”. Gilt prices fell precipitously, which caused defined...
GloBE Administrative Guidance In order to achieve consistency, any jurisdiction adopting the global minimum tax or “GloBE” rules has to follow the Model Rules and the Commentary as amended from time to time by Administrative Guidance. This guidance is expected to be issued on a...
Are the Floodgates Opening? The Future of Large Datasets in AI The use of large third-party datasets in the development of AI models has been a contentious issue for some time now.  In the latest development, Getty Images are bringing a copyright claim in the UK against AI developer Stability AI, in relation to...
Cryptoassets: the next chapter Yesterday, HM Treasury published its much anticipated vision for the future of the financial services regulatory regime for cryptoassets. Comprehensive, detailed, and 82 pages long, this consultation paper and call for evidence brings some coherence to an...
Crypto: Promo Go Slow (Part 2) Just a week after the FCA's review of AML registration applications by crypto firms, we've now got two important publications from the UK government on the future regulation of cryptoassets. It feels like they're my 43 bus from London Bridge (or perhaps...
Crypto-ing the line Back at the very beginning of 2020 Covid-19 still hadn't been designated a pandemic, Brexit still wasn't quite 'done' and you could start a cryptoasset business in the UK without needing to so much as notify the FCA you were doing so.  In the intervening...