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UK Law Commission Launches Consultation on Digital Assets

The UK’s Law Commission (the Commission) published a consultation paper on July 28, 2022, proposing certain reforms to private property law in relation to digital assets, which was in response to the UK government requesting...more

Outsourcing in Luxembourg: CSSF Consolidates Regulations for Financial Institutions

The financial services regulations relating to outsourcing by Luxembourg-headquartered financial institutions have been significantly simplified by the introduction of the Commission de Surveillance du Secteur Financier...more

UK Government Still Seeks Input on Data Storage and Processing Infrastructure, Security, and Resilience

The UK Department for Digital, Culture, Media & Sport (DCMS) recently extended the deadline for responses to a policy paper issued on May 26, 2022, calling for views on UK data storage and processing infrastructure, security,...more

Outsourcing in Luxembourg: Prior Notification for Material IT Outsourcing

In late 2021, the Luxembourg Commission de Surveillance du Secteur Financier (CSSF) published Circular CSSF 21/785 (the Circular), which introduced a more relaxed approach on the communication requirements in relation to...more

Sanctions Apply to Cryptoasset Sector Confirm UK Financial Regulatory

On March 11, 2022, the UK Financial Conduct Authority (FCA), the Bank of England, and the Office of Financial Sanctions Implementation (OFSI) released a joint statement reiterating that all UK financial services firms,...more

US Issues Executive Order on Ensuring Responsible Development of Digital Assets

The White House issued an executive order on March 9 relating to the responsible development of digital assets in the United States. This executive order outlines the first ever whole-of-government approach to both addressing...more

UK Financial Conduct Authority Drives Changes to Buy Now, Pay Later Contract Terms

The UK Financial Conduct Authority (FCA) released a statement on February 14 confirming a series of changes to potentially unfair contract terms that had been agreed with four of the largest providers of Buy Now, Pay Later...more

AI in Financial Services: Bank of England and UK FCA Highlight Key Challenges and Risks

The Bank of England (Bank) and the UK Financial Conduct Authority (FCA) published their final report of discussions from the UK Artificial Intelligence Public-Private Forum on February 17. Over quarterly meetings and several...more

Legislative Approaches to AI: European Union v. United Kingdom

Following an initial announcement in early 2021, the UK government has recently launched its first National Artificial Intelligence (AI) Strategy. This new strategy indicates that the United Kingdom may be planning on...more

National AI Strategy Published in the United Kingdom

The United Kingdom (UK) government on September 22 launched the country’s first National Artificial Intelligence (AI) Strategy to build on the UK’s strengths in the area and maximize new AI opportunities....more

Coalition of European Banks Calls for Model Cloud Services Terms

The European Cloud User Coalition (ECUC) published a paper (the Position Paper) on May 17 recommending, among other matters, the adoption of “model clauses” for the long-term compliant use of cloud technologies....more

Biden-Harris Administration Push for Green Technology

In a recent Lawflash, our colleagues Ken Kulak and Ariel Braunstein reported that at the Leaders Summit on Climate, hosted by the Biden-Harris administration on April 22 and 23 in Washington, DC, President Joseph Biden set...more

EU Considers Strengthening Code of Practice on Online Disinformation Amid COVID-19 Infodemic

The European Commission (the Commission) began to invite feedback on April 1 on its roadmap to strengthen the Code of Practice on Disinformation (the Code) via new guidance. The roadmap was released in response to perceived...more

EU Commission Releases Proposal for Regulating Artificial Intelligence in Europe

The EU Commission recently released its proposal to legislate a European Union–wide artificial intelligence (AI) framework. The EU Commission’s intention is that the proposed regulation on AI will provide greater safety and...more

Financial Services Supervising Authorities Deliver Strong Message on Building Operational Resilience in the United Kingdom

We recently noted that the UK Financial Conduct Authority (FCA) published the outcome of a review into the factors that determine failure or success when implementing technology change in the financial services sector and...more

Key Considerations for Application Purchase Agreements (Part 1)

The purchase of applications (or apps) is a comprehensive arrangement that includes the transfer of a variety of rights and assets, including intellectual property (IP) rights, software, human resources, equipment, and...more

National Artificial Intelligence Strategy Announced in United Kingdom

Having recently announced the launch of the new UK Cyber Security Council, the UK government has followed up by announcing its plans to publish a new National Artificial Intelligence Strategy (the AI Strategy) later this...more

FCA Publishes Report on Implementing Technology Change

The UK Financial Conduct Authority (FCA) has published its findings on an extensive review into the factors which determine failure or success when implementing technology change in the financial services sector....more

ICO GDPR Fines Reduced to £20m and £18.4m to Reflect British Airways and Marriott Mitigating Factors

The UK Information Commissioner’s Office (ICO) has recently handed down two of the largest fines relating to a data breach in UK history. In August 2018, British Airways (BA) was subject to a cyberattack which breached the...more

FCA Decides Not to Implement EIOPA Guidelines in United Kingdom

The UK Financial Conduct Authority (FCA) announced on July 8 that the guidelines issued by the European Insurance and Occupational Pension Authority (EIOPA) on outsourcing to cloud service providers are not applicable to...more

ESMA Draft Guidelines on Outsourcing to Cloud Service Providers

The European Securities and Markets Authority (ESMA) published its draft guidelines on outsourcing to cloud service providers on June 3. Steven Maijoor, the chair of ESMA, indicated that the purpose of the guidelines is to...more

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