Cleary Gottlieb Steen & Hamilton LLP (LexBlog United Kingdom)

For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration. President Trump has announced two new trade deals negotiated by the United States: the U.S.-UK Economic Prosperity Deal (“EPD”), announced on May 8, and an executive order, Modifying Reciprocal Tariff...

On March 20, 2025, the United Kingdom’s Serious Fraud Office (“SFO”), France’s Parquet National Financier (“PNF”), and Switzerland’s Office of the Attorney General (“OAG”) signed a founding statement to establish a new International Anti-Corruption Prosecutorial Taskforce.[1]  The new taskforce will include a Leadership Group to exchange insight and strategy, as well as a Working Group...

The following is part of our annual publication Selected Issues for Boards of Directors in 2025. Explore all topics or download the PDF. UK and European capital markets underwent significant reform in 2024. The UK Financial Conduct Authority (FCA) overhauled the UK listing regime and implemented new listing rules (UKLRs) as part of the UK government’s efforts to simplify...

On October 17, 2024, the European Commission (“Commission“) published its forth annual report on the screening of foreign direct investments (“FDI“) into the Union (the “Report“), following previous editions published in October 2023, September 2022 and November 2021. Notable findings include the follow: Read the full publication

On September 12, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) June 12, 2024 determination entitled “Prohibition on Certain Information Technology and Software Services” entered into effect.  The determination prohibits the direct or indirect provision to Russia from the United States or by U.S. persons of (1) information technology (“IT”)...

On 10 September 2024, the UK Government published its third Annual Report (the “Report”) on the enforcement of the National Security and Investment Act 2021 (the “NSI Act”), covering the period from 1 April 2023 to 31 March 2024. The NSI Act requires pre-closing notification of transactions where the buyer acquires more than 25% of...

On 21 May 2024, the UK Government published updated guidance on the application of the National Security and Investment Act (NSIA).  This includes: The new guidance does not affect the scope of the 17 sectors in relation to which transactions are subject to mandatory notification.  A consultation on changes to these sectors is expected in...

On April 12, 2024  the United States, in coordination with the United Kingdom, issued new prohibitions with  respect to Russian aluminium, copper and nickel. The new actions prohibit the import of Russian-origin aluminum, copper and nickel into the United States and limit their use on global metal exchanges and in over-the-counter derivatives trading. In the UK,...

Proposal for a revised EU FDI Screening Regulation The European Commission has recently adopted five initiatives as part of the European Economic Security Strategy unveiled in June 2023. The initiatives are aimed at bolstering the EU’s economic security interests. Their main focus is a proposal for a new EU FDI Screening Regulation, which remains subject to...

The Financial Reporting Council (FRC) has published an updated UK Corporate Governance Code (the Code), most of which will take effect from 1 January 2025. These revisions will replace the current version of the Code published in 2018.  As foreshadowed in its November 2023 statement, the FRC has taken forward only a small number of...

The following post was originally included as part of our recently published memorandum “Selected Issues for Boards of Directors in 2024”. Antitrust in 2023 was marked by a series of policy developments—some still nascent, some ripe for enforcement for the first time.  In the U.S., the FTC and DOJ finalized their drastically transformed merger guidelines. ...

Quantum technology is seen as having the potential to revolutionize many aspects of technology, the economy and society, including the financial sector. At the same time, this technology represents a significant threat to cybersecurity, especially due to its potential to render most current encryption schemes obsolete. With a view to meeting these challenges, the World...

Quantum technology is seen as having the potential to revolutionize many aspects of technology, the economy and society, including the financial sector. At the same time, this technology represents a significant threat to cybersecurity, especially due to its potential to render most current encryption schemes obsolete. With a view to meeting these challenges, the World...

On 15 January 2024, the UK Information Commissioner’s Office (“ICO”)[1] launched a series of public consultations on the applicability of data protection laws to the development and use of generative artificial intelligence (“GenAI”). The ICO is seeking comments from “all stakeholders with an interest in GenAI”, including developers, users, legal advisors and consultants.[2] This first...

UK Government consults on changes to National Security and Investment Act On November 13, 2023, the UK Government opened a consultation on proposed changes to the National Security and Investment Act, less than two years after the regime came into force. Oliver Dowden MP, the Deputy Prime Minister and formal decision-maker under the regime in his role...

A key feature of the UK’s financial sanctions framework is that not only designated persons (listed on the UK’s Consolidated List) are subject to sanctions, but also entities that are ‘owned or controlled’ by designated persons, even if not themselves listed. This alert memorandum discusses recent developments relating to the ‘control’ test and its application,...

On 13 November 2023, the UK Government opened a consultation on proposed changes to the National Security and Investment (NSI) regime, less than two years after the regime came into force. Oliver Dowden MP, the Deputy Prime Minister and formal decision-maker under the regime in his role as Cabinet Secretary, describes the consultation as an...

On 11 July 2023, the UK Government published its second Annual Report on the National Security and Investment Act 2021 (the “Act”). The Annual Report begins with an introduction by Oliver Dowden MP, the Deputy Prime Minister, who is the formal decision-maker under the Act in his role as the Secretary of State in the...

Minnesota bans new employee non-competes beginning July 1, 2023, and the United Kingdom intends to cap their duration at 3 months Minnesota Becomes the 4th U.S. State to Ban Employee Non-Competes Following in the footsteps of California, North Dakota and Oklahoma, Minnesota has banned all employee non-competes beginning July 1, 2023, and bars employers from...

On 19 May 2023, the UK expanded its list of Designated Persons under the Russia (Sanctions) (EU Exit) Regulations 2019 by adding 86 new persons, comprising 42 individuals and 44 Russian legal entities. The newly Designated Persons are primarily involved with, or linked to, the defense, transportation, extraction, metallurgy, financial and agricultural sectors of the...

On 27 April 2023, the UK Government published updated guidance on its recently introduced national security and investment screening regime. Since the National Security and Investment Act came into force in January 2022, the UK Government has reviewed more than 800 transactions for possible national security concerns.  Five transactions have been prohibited, of which four...

On March 8, 2023, the UK government published the Data Protection and Digital Information (No. 2) Bill (the “Bill”) which proposes to update the current UK data protection regime.  The Bill and its Explanatory Notes can be found here and here (respectively). The Bill is the culmination of a process that started with the UK...

On 24 November 2022, the UK government announced its adequacy decision for the Republic of Korea, which will allow UK organizations to share personal data with Korean organizations more freely under the UK General Data Protection Regulation (“UK GDPR”). The adequacy decision is expected to come into effect on 19 December 2022. The adequacy decision...

The Information Commissioner’s Office (“ICO”) has opened a consultation on new draft guidance on monitoring at work (the “Draft Guidance”).  The Draft Guidance applies in both the private and public sectors in respect of any worker, a term which is used to include employees as well as non-employee workers, independent contractors and volunteers. The Draft...

On September 5, 2022, following the election of the new UK Prime Minister, the UK Government decided not to proceed with the second reading and other motions relating to the Data Protection and Digital Information Bill (the “Bill”), which was due to have taken place on the same day.  According to the Leader of the...

Welcome to the Winter edition of our UK Public M&A Round-up. This issue includes: UK Public M&A Snapshot Winter 21/22 Auctions in UK Public Bids We hope you find the topics in this issue to be of interest and invite you to contact the articles’ authors or your normal Cleary contact if you have any...

On February 10, 2022, the United Kingdom published new legislation (the “Amendment”) significantly expanding the scope of targets on which the UK government may impose sanctions relating to Russia.[1]  The Amendment, which was issued in response to the current situation in Ukraine and takes immediate effect, broadens the designation criteria of the existing Russia (Sanctions)...

The National Security and Investment Act 2021, which was passed on 29 April 2021, comes into force today. The new regime, which subjects investments in many companies active in the UK to mandatory review on national security grounds, will be among the most wide-ranging in the world. It represents the most significant change in the...

The National Security and Investment Act 2021, which was passed on 29 April 2021, comes into force today. The new regime, which subjects investments in many companies active in the UK to mandatory review on national security grounds, will be among the most wide-ranging in the world. It represents the most significant change in the...

The UK’s Financial Conduct Authority (FCA) recently published its Policy Statement on “Enhancing climate-related disclosures by standard listed companies”.[1] This follows a consultation carried out by the FCA in June 2021. The FCA has decided to extend the climate-related disclosure requirements that currently apply to UK premium listed commercial companies to (1) issuers of standard...