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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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