Expert Analysis

• Reflecting On The UK Senior Managers Regime 10 Years On

  

  While the ongoing changes to the senior managers and certification regime to streamline processes and remove certain restrictions are welcome, the scheme has worked well overall since its 2016 inauguration, and firms’ compliance and risk management-thinking have shown a marked improvement, say lawyers at Faegre Drinker.

• How Revised EU Rules Would Alter Sustainability Reporting

  

  Two draft delegated regulations recently published by the European Commission give effect to the Omnibus I simplification, highlighting a consistent policy direction: fewer companies in scope, later and lighter obligations, and explicit protections for smaller value chain counterparties, say lawyers at MoFo.

• How UK Security Act Plans Will Affect Foreign Investors

  

  The U.K. government's recently proposed changes to the scope of National Security and Investment Act transaction screening for foreign investment in sectors including communications, data infrastructure and energy should create a more proportionate, predictable and targeted regime, say lawyers at Skadden.

• How Anthropic's Mythos May Upend Defense Cyber Rules

  

  Anthropic’s recent announcement that Claude Mythos, an AI general-purpose language model, could soon enable virtually anyone to exploit vulnerabilities in major web browsers and operating systems marks an imminent increase in threat levels that current defense cybersecurity regulations were not designed to navigate, say attorneys at Fluet.

• How New Act Expands UK Managers' Corporate Crime Liability

  

  The recent enforcement of the Crime and Policing Act is a watershed moment for U.K. corporate criminal liability, facilitating the prosecution of organizations for the actions of their senior managers by extending liability beyond the individual with the directing mind and will to those who play a significant role in a business’s decision‑making, say lawyers at WilmerHale.

• CMA's Actions Signal New Spotlight On UK Consumer Law

  

  The Competition and Markets Authority’s recent hidden fee fine against the AA — its first infringement decision using its new direct enforcement powers — as well as its investigations into fake online reviews and scrutiny of subscription contracts, demonstrate the regulator's new focus on tackling the most egregious breaches of U.K. consumer law, say lawyers at Wilson Sonsini.

• What Dutch AI Decision-Making Guidance Means For Cos.

  

  The Dutch Data Protection Authority’s recent draft guidelines on customers' rights to an explanation in automated decision-making processes under the General Data Protection Regulation raise important operational and governance considerations for companies, say lawyers at Hogan Lovells.

• Understanding The Legal Risks Of Fragile Supply Chains

  

  To ensure supply chain resilience in times of crisis — such as the recent blockage of the strategically vital Strait of Hormuz — it is important for everyone involved in the chain to understand the distribution arrangements and laws applicable across jurisdictions, say lawyers at Brown Rudnick.

• How New E-Evidence Rules Will Affect EU-US Data Transfers

  

  The forthcoming European Union e-evidence regulation signals the need to preserve digital evidence that is stored outside the issuing jurisdiction, bringing the EU significantly closer to the model employed by the U.S. and reflecting a shift in the legal landscape for cross-border data transfers, say lawyers at MoFo.

• Compliance Landscape Shifts As CMA Targets Fake Reviews

  

  The Competition and Markets Authority’s investigations into five companies’ alleged misleading online reviews are the first use of its administrative powers under the Digital Markets, Competition and Consumers Act, marking a turning point in U.K. consumer protection enforcement, say lawyers at Fieldfisher.

• SFO Plan Focuses On Resilience But Funding Doubts Persist

  

  The Serious Fraud Office’s emphasis on tighter case management and making greater use of technology in its latest business plan suggests a concern with strengthening complex financial crime enforcement, however the agency may not have the resources to deliver meaningful change, say lawyers at Signature Litigation.

• EU Defense Road Map Opens Doors To New Market Entrants

  

  The European Economic and Social Committee's and European Investment Bank Group’s recent endorsements of the European Commission’s EU defense industry transformation road map signal positivity for ongoing implementation, making public procurement more accessible to innovative newcomers and creating fresh opportunities to participate in security-relevant innovation projects, say lawyers at Dechert.

• Sanctions Spotlight: Key Priorities Of OFSI's 3-Year Strategy

  

  The Office of Trade Sanctions Implementation's 2026-2029 strategy to assist businesses by providing practical compliance advice and more predictable support will be welcomed, although the process for obtaining guidance and whether the ensuing information will be made publicly available remains unclear, says Alexandra Melia at Steptoe.

• EU Risks Falling Behind With Delay In Digitization Rule Fixes

  

  With financial organizations calling for the European Union to fast-track modifications to the Distributed Ledger Technology Pilot Regime and the EU signaling that tokenization is a permanent feature of the financial landscape, the sector needs to prepare for the now inevitable shift, says Antonio Lanotte at Futura Law.

• What To Know About Proposed EU Industrial Accelerator Act

  

  The European Commission’s proposed Industrial Accelerator Act aims to reverse the decline of the European Union's manufacturing sector and support cleaner technologies by introducing EU origin and low-carbon requirements, but with the definition of “Made in the EU” still under debate, the text may yet undergo significant changes, say lawyers at Crowell.