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EU Banking Package: Commission proposes new notification and assessment procedures On 27 October 2021, the European Commission published the EU Banking Package 2021 , which is intended, among other things, to complete the implementation of Basel III (sometimes referred to as ‘Basel 3.1’ or ‘Basel IV’). This includes the introduction of ... Kalifa Review: First year school report As I wrote at the time it was published, the Kalifa Review of the UK fintech industry set out an ambitious framework to support the continued growth and prosperity of an area in which the UK has been the envy of much of the financial services world. One y... Non-performing loans - Overview of the new EU status of credit servicers and credit purchasers In the wake of the EBA’s final guidelines on the management of non-performing loans (“NPLs”) at the end of 2018, the European Union has published on 8 December 2021 a Directive on credit servicers and credit purchasers of NPLs ("the NPL Directive"). The e... 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...