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APAC ESG Update | Spring Quarter 2024

This White Paper focuses on ESG developments through the Asia-Pacific (“APAC”) region since the start of 2024. For businesses present in the APAC region, as well as doing business there, it is imperative to be vigilant of...more

UK Supreme Court Quashes Planning Permission Due to a Failure to Consider Downstream (Scope 3) Greenhouse Gas Emissions

The Situation: On June 20, 2024, the UK Supreme Court handed down a landmark decision in R (on the application of Finch on behalf of the Weald Action Group) (Appellant) v Surrey County Council and others (Respondents) [2024]...more

EU Corporate Sustainability Due Diligence Directive

On April 24, 2024, the European Parliament voted to adopt the Corporate Sustainability Due Diligence Directive ("CS3D"). As described in a recent Jones Day Alert, this followed the Council of the European Union ("the...more

Pay Equity and Transparency: Expanding Obligations for U.S. Employers with EU Operations

The Situation: While U.S. states continue to legislate pay equity and transparency obligations, significant changes are on the horizon in the European Union that will impact U.S. companies with sizeable operations there. The...more

Third Time's a Charm: EU Moves to Approve the Sustainability Due Diligence Directive

The Council of the European Union ("EU") approved the Corporate Sustainability Due Diligence Directive ("CS3D") on March 15, 2024. The CS3D contains due diligence and governance obligations that will have an extensive impact...more

European Institutions Reach Deal on EU Corporate Sustainability Due Diligence Directive

The Council of Europe and the European Parliament announced on December 14, 2023, that they reached a political agreement on the text of the upcoming European Union ("EU") Corporate Sustainability Due Diligence Directive...more

Who, What, When: The Impact of the EU CSRD on Non-EU Companies

The EU’s Corporate Sustainability Reporting Directive (“CSRD”) requires the most detailed and onerous ESG reporting and disclosures anywhere in the world. All told, it is estimated that more than 50,000 companies, including...more

High Court Dismisses ClientEarth's Application to Initiate Proceedings Against Shell's Directors

Introduction - On July 24, 2023, the High Court dismissed ClientEarth's application for permission to bring a shareholder derivative claim against Shell's directors (the "Board") for breach of directors' duties under the...more

New EU Deforestation Regulation and the Challenges in Its Implementation

In Short - The Situation: The European Union ("EU") has adopted a new regulation designed to tackle deforestation and forest degradation in the EU and globally by preventing European citizens from buying, using, and...more

The European Parliament Adopts New Sustainability Reporting Rules

The European Parliament has adopted the near-final version of the Corporate Sustainability Reporting Directive under which European Union ("EU") companies (including non-EU companies with substantial business activity in the...more

Global Spotlight on Labor Trafficking in Health Care and Corporate Supply Chains

Courts and legislatures both in the United States and abroad continue to prioritize the eradication of labor trafficking in corporate supply chains, including those in the health care industry. For example, in the United...more

Extraterritorial Reach of Upcoming European ESG Rules

In Short - The Situation: Certain large companies incorporated in the European Union ("EU") are already required to disclose nonfinancial information under the current EU regulatory framework. Two upcoming EU...more

ClientEarth Threatens Legal Action Against Shell's Directors in England and Wales

On 15 March 2022, ClientEarth announced that it had written to Shell's board of directors informing them of its intent to bring a claim on behalf of the company for the board's failure to implement a Paris Agreement compliant...more

European Large Asset Managers Now Unable to Opt Out of Article 4 SFDR

After June 30, 2021, large asset managers will no longer have the option to "explain" noncompliance with Article 4 of EU Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector...more

Model Terms Demanded for Cloud Service Agreements with European Banks

An interest group of EU banks that was formed to assist European financial institutions with their use of public cloud technology recently suggested model terms for the compliant use of cloud technology. On May 17, 2021,...more

A Multifaceted Maze: The FCA's Role and Powers in Distressed Situations

The last five years have seen a substantial increase in the number and variety of regulated firms operating in the United Kingdom, with the development in particular of financial services provided by new technology firms,...more

Temporary Post-Brexit Regime Applies to UK Financial Institutions Operating in Italy

In Short  The Situation: As of the close of the Brexit transition period ending on December 31, 2020 ("Withdrawal Date"), UK banks, UK investment firms, and UK electronic money institutions ("UK Financial Institutions") can...more

Capital Relief for Software Assets: European Commission Amends Own Fund Requirements

The Development: New Regulation (EU) 2020/2176 (the "Regulation") provides regulatory capital relief, allowing certain software assets to be considered when calculating Common Equity Tier 1 ("CET1") capital. It entered into...more

UK Financial Services Bill Includes New Powers for FCA to Manage LIBOR Transition

The proposed powers for the Financial Conduct Authority ("FCA") to manage the London Interbank Offered Rate ("LIBOR") transition should address so-called "tough legacy" contracts involving UK participants but could also have...more

Changes to the Regulatory and Prudential Requirements for European Investment Firms

Regulation (EU) 2019/2033 on the prudential requirements of investment firms and Directive (EU) 2019/2034 on the prudential supervision of investment firms (collectively, "IFR/IFD Framework") significantly change the...more

AIM-Listed Company Implements Investor Compensation Scheme Following FCA Public Censure

The Situation: The UK Financial Conduct Authority ("FCA") publicly censured a UK publicly listed IT services provider for false disclosure but avoided a fine on the basis that the company provided essential services during...more

Getting Cautious on Cloud Outsourcing: ESMA Consults on Proposed Guidelines

The Situation: On June 3, 2020, the European Securities Market Authority ("ESMA") published a consultation paper on Outsourcing to Cloud Service Providers ("Proposed Guidelines"), which will apply to any institution under the...more

Turning Tides in FCA SMCR Enforcement: Easier Targets, Non-Financial Misconduct, Changing Priorities

The Situation: The Financial Conduct Authority ("FCA") is extending the Senior Managers and Certification Regime ("SMCR") to FCA solo-regulated firms on 9 December 2019 and has also released a number of statements in relation...more

Leveling the Financial Institutions Playing Field: EBA Publishes Revised Guidelines on Outsourcing Arrangements

The Situation: The European Banking Authority ("EBA") published its Final Report on EBA Draft Guidelines on Outsourcing Arrangements ("Guidelines") on February 25, 2019, which will eventually replace the existing CEBS...more

Bank of England Establishes Enforcement Decision Making Committee

In Short: The Bank of England ("BoE") has published its final policy statement and procedures for its new Enforcement Decision Making Committee ("EDMC"). The Result: The EDMC will be the BoE's independent decision-making...more

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