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Ready for being ready The FCA recently held a webinar on Operational Resilience as a ‘checkpoint’ for firms to see how they measure up against FCA expectations. This is two months ahead of the 31 March deadline for the first operational resilience policy milestone – identifyin... Carpe Crypto Earlier this week, HMRC announced that it was the first UK law enforcement entity to seize an NFT. The turn of phrase struck me - how exactly does one go about seizing a cryptoasset? The difficulty is not that NFTs, like all cryptoassets, are at their roo... Some reflections (and concerns) over the ‘Brexit Freedoms Bill’ As the legal, business and political communities continue to consider the implications and likely outcomes of the UK’s government’s proposal for a so-called ‘Brexit Freedoms Bill’ (and associated policy paper on ‘The benefits of Brexit’), a few reflection... ECB publishes revised Guide to fit and proper assessments Following a consultation in the summer of last year, the ECB, on 8 December 2021, has published a revised version of its Guide to fit and proper assessments ("Guide") and an updated fit and proper questionnaire ("Questionnaire"). The new version will repl... Italian Supreme Court limits scope of beneficial ownership under Interest and Royalties Directive Italian Supreme Court Decision No. 3380 of 3 February deals with the interpretation of the beneficial owner (BO) requirement under the Interest and Royalties Directive (IRD) and the abuse of that directive. The decision held that the BO requirement should... Another one bites the dust: Further vicarious liability data breach claim fails In a critical decision for organisations handling sensitive data, Luton Borough Council has been found not vicariously liable for the acts of a rogue employee who deliberately leaked sensitive data about a woman and her children. What happened? Isma Ali p... Tackling cyber supply chain risk: new laws proposed From reports of cyber attacks at the UK’s Foreign office and European oil facilities to crisp shortages caused by a ransomware attack at KP snacks, cyber is again hitting the headlines. It is no surprise then that the government has recently said in its 2... Henry's back... The release of Sue Gray’s update report on 31st January somewhat overshadowed the Prime Minister’s announcement of a Brexit Freedoms Bill, timed to coincide with the two-year anniversary of the UK’s withdrawal from the European Union.  On exit day retaine... Cryptoasset promotions: sweat the small stuff The FCA has published a consultation paper setting out its approach to strengthening its financial promotion rules for high risk investments. As Tim mentioned in his blog post, this is connected to HM Treasury publishing a paper bringing cryptoassets with... Getting transfers done: ICO finalises the UK’s international transfers documents Last week, the UK’s International Data Transfer Agreement (IDTA) was laid before Parliament, along with an addendum (the EU Addendum) to the EU standard contractual clauses (EU SCCs) (that we discussed here). The ICO also announced changes to the definiti...