Expert Analysis

• 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.

• Insights From FCA's Latest Customer Due Diligence Review

  

  The Financial Conduct Authority’s recent report on customer due diligence controls explains what distinguishes good policies and procedures from those that are lacking, and should encourage firms to check that their processes are detailed, practical and relevant to the business, say lawyers at Womble Bond.

• How New EU Third-Country Branch Rules Will Affect UK Banks

  

  The European Union's new directive on third-country branch rules for non-EU banks will have a significant impact on U.K. banks, which will no longer be permitted to provide core cross-border services into the EU without a local presence, unless an applicable exemption or carveout applies, say lawyers at Farrer & Co.

• Lessons From ESMA's Record €1.4M Trade Repository Fine

  

  The European Securities and Markets Authority's recent fine against REGIS-TR for data and procedure breaches under Market Infrastructure and Securities Financing Regulations demonstrates that a license confers no immunity from sanctions, and that dually registered trade repositories face a greater financial exposure in the event of noncompliance, say lawyers at White & Case.

• CMA's 5-Point Plan Signals Shift In Enforcement Priorities

  

  The Competition and Markets Authority’s recently published annual plan is notable for a strong shift toward prioritizing U.K. enforcement of consumer protection laws, encouraging innovation and policing public procurement markets for anticompetitive conduct, which contrasts with previous plans that focused on competition in digital markets, complex merger review and sustainability, say lawyers at Cooley.

• A New Era For UK Financial Sanctions Enforcement

  

  A major overhauling of the U.K.'s Office of Financial Sanctions Implementation brings it into closer alignment with its U.S. counterpart, though it also deliberately diverges in ways that carry real consequences for exposure modeling and enforcement strategy, says Irene Polieri at Gibson Dunn.

• ECJ Ruling Shows When Cos. Can Reject Data Requests

  

  The European Court of Justice’s recent decision in Brillen Rottler v. TC clarifies that although data controllers must be cautious in declining data subject access requests under the EU General Data Protection Regulation, a company may refuse to respond where the request is manifestly unfounded or excessive, even at first contact, says Rob Dalling at Jenner & Block.