External action meaning

This Checklist covers the key considerations when formulating a strategy to combat counterfeiting and piracy. Use this Checklist together with Practice Note: Anti-counterfeiting and anti-piracy—strategy. Begin by evaluating how widespread the issue is. Consider who has been consulted: Internal teams close to the market, such as customer services dealing with consumer complaints External investigators gauging counterfeit prevalence across specific channels (online and in store) and carrying out test purchases Agencies including the Chartered Trading Standards Institute (‘Trading Standards’) and HMRC Internet service providers and website operators where targets largely trade online Be aware that staff or members of the public may spot fake goods in shops, market stalls, at events or while on holiday and may proactively alert the rights holder. Confirm whether the following key details have been established: Most affected territories Most affected products Health and safety concerns Degree of risk to consumers and brand value Principal perpetrators Any...

Removing a child from the jurisdiction Taking a child out of the jurisdiction without the necessary consent(s) can constitute an offence under the Child Abduction Act 1984 (CAA 1984). Refer to the Practice Note titled: Child abduction—criminal action and electronic tagging. Where there is no existing child arrangements order (CAO) in force regulating the child’s living arrangements, the requisite consent must be obtained in advance of removing the child from the jurisdiction from the following: each person with parental responsibility the father (whether or not he has parental responsibility for the child) Failure to do so creates a risk of breaching CAA 1984 and/or the Hague Convention on Civil Aspects of International Child Abduction. If a CAO is in place regulating the child’s living arrangements, section 13 of the Children Act 1989 (ChA 1989) provides that a child may not be removed from the UK without either the written consent of every person with parental responsibility or the court’s leave....

Stage 1—preparing to bring a claim and pre-action matters Guidance on UK trade mark infringement, offences, passing off, interim injunctions, running IP disputes, privilege, dispute resolution (mediation and arbitration), and the Disclosure Scheme; plus checklists and forms (injunction, application, hearing) Stage 2—Letter before action alleging infringement Notes on infringement, passing off, unjustified threats and drafting; includes a trade mark letter of claim precedent Stage 3—commencing proceedings Procedure, defences and exceptions, IPEC flowchart, pleadings and initial disclosure precedents, and CPR/Part 36 forms Stage 4—case management Procedure and Disclosure Scheme notes, court guides (Chancery, Patents Court, IPEC and Small Claims), and case management questionnaires, Disclosure Review Document, Certificate of Compliance, budgets and directions Stage 5—disclosure and evidence Surveys and witness evidence (PD 57AC), privilege, disclosure (including electronic) and flexible trials; witness statement and Extended Disclosure precedents; affidavits, applications and certificates Stage 6—trial...

This flowchart shows how to handle a data protection incident (including a cyber security incident) in line with the UK General Data Protection Regulation (UK GDPR). It mirrors the UK GDPR’s rules on reporting and recording personal data breaches, alongside the Information Commissioner’s Office (ICO) guidance on breach management. It charts the end-to-end breach lifecycle, offering direction and links to the relevant precedents for each step of the process. See Precedents: Personal data breach plan, Data breach report form—internal and Data breach assessment and action plan, which steer you through every stage of this workflow. Note 1—assemble data breach team The initial action is to bring together your data breach team. Decide who in the organisation is best positioned to respond promptly to the incident and who should support the ensuing enquiry. This typically calls for contributions from specialists across the business, including IT, HR and compliance/legal, and may, in some instances, involve engagement with external stakeholders and suppliers. The Precedent: Personal data breach plan urges you to...

Oswin v Otila; and Ondray Claim No ARB 032/2025 What was the background? This matter arose from a falling-out between Oswin (the Claimant) and Ondray (the Second Defendant) over how to run their joint venture company, Otila (the First Defendant). Oswin owned 49% of the First Defendant’s shares and Ondray 51%. The board could act only by unanimous vote, while shareholder resolutions required a 75% super-majority. When they were unable to agree on management and operations, the company became deadlocked. Their relationship was governed by a Joint Venture Agreement (JVA) dated 12 March 2019, which included an arbitration clause calling for DIFC-seated proceedings under the DIFC-LCIA Rules. The Claimant also operated a medical and hazardous waste facility under an Operations and Management Agreement due to expire on 21 August 2025. On 15 August 2025, the Claimant issued a Dispute Notice under clause 21.2 of the JVA, alleging that the Second Defendant was assuming strategic decision-making without proper authority—covering directions on renewal of the O&M Agreement, instruction of external...

In this issue A review of key cases in 2025 Decision to prosecute and alternatives to prosecution Criminal procedure and evidence Proceeds of crime Bribery, corruption, sanctions and export controls Environmental offences Financial services and pensions offences Health and safety and corporate manslaughter offences Local authority prosecutions Money laundering Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information A review of key cases in 2025 Headline corporate crime matters in 2025 included the UK Supreme Court overturning the convictions of two traders jailed for rate manipulation; the anti-fraud agency deploying a seldom‑used legal power to recover criminal cash; and the first conviction for sanctions breaches. See News Analysis: The biggest financial crime cases of 2025. Decision to prosecute and alternatives to prosecution SFO compliance guide highlights early remediation is key On 26 November 2025, the Serious Fraud Office (SFO)...

Rangecourt SA (formerly Banque Havilland SA) & others v The Financial Conduct Authority Rangecourt SA (formerly Banque Havilland SA) and others v The Financial Conduct Authority and another [2026] UKUT 47 (TCC) What are the practical implications of this case? The judgment delivers notable regulatory guidance on when co-operation will be treated as a mitigating factor in enforcement, and resists the FCA’s increasingly tight interpretation of what is ‘exceptional’. The Tribunal placed marked emphasis on post-breach conduct, particularly where a firm proactively uncovers, scrutinises and reports misconduct. It confirms that firms which promptly self-report, investigate effectively, engage external advisers and put remedial measures in place (including staffing changes) can anticipate substantive mitigation—promoting earlier internal inquiries, greater candour and swifter regulatory dialogue. The Tribunal also sets out a more precise test for co-operation: the decisive question is whether the firm’s actions substantially assisted the regulator, rather than satisfying an elevated, exceptional threshold. The FCA’s Decision Note advanced a narrow view, asserting that the Bank’s provision of the Project Gulf report...

The Control of Major Accident Hazards Regulations 2015 (COMAH 2015), SI 2015/483, seeks to avert major workplace accidents and establish controls so that, if an incident does occur, the consequences for people and the environment are limited. COMAH 2015 operates by defining core duties for all obligated sites/businesses and also sets a tiered regime, imposing tighter controls on businesses handling dangerous substances above stated thresholds. The Health and Safety Executive (HSE) issues guidance on applying the COMAH regime, and operators are urged to follow it, and to review and update, where necessary, risk assessments and emergency arrangements under COMAH. This supports ongoing compliance and risk reduction. Legislative framework COMAH 2015 received Royal Assent in March 2015 and came into force on 1 June 2015. COMAH 2015 implemented the requirements of Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of major accident hazards involving dangerous substances, amending and subsequently repealing Directive 96/82/EC (Seveso III), which was published in July...

After a law firm has assessed its position, defined clear objectives and aligned on a strategy, the emphasis must move to delivery. That involves selecting suitable business development efforts, ensuring the firm has the time, people and systems to support them, and consolidating everything into a clear business development plan. This guidance covers three connected areas: choosing and executing effective business development and marketing campaigns managing the people, time, systems and budgets needed to underpin those activities building a business development plan that enables co-ordination, accountability and progress Collectively, these measures convert strategic intent into measurable action. Choosing business development and marketing activities Business development should not be selected in isolation; every initiative must clearly support the agreed goals and strategy. Before approving any campaign or initiative, the firm should be explicit about: the intended outcome of the activity the target audience the success measures responsibility and ownership the time and financial cost...

This Resource Note summarises the core provisions of Rule 21 of the City Code on Takeovers and Mergers (the Code). It covers the limits on an offeror taking frustrating action in connection with an offer, and the approach to inducement fees and other offer-related arrangements. Rule 21 also mandates that competing offerors are given equivalent information, and that the offeree’s independent directors receive all information supplied to external finance providers in a management buy-out. It signposts relevant materials, commentary and guidance from the Panel on Takeovers and Mergers (the Panel), alongside Lexis+® UK analysis and resources, to provide practical direction on the interpretation and application of Rule 21... Materials covered in this Resource Note include: Practice Statements issued by the Panel Executive (the body responsible for the day-to-day supervision and regulation of takeovers) (Executive), offering informal guidance on how the Executive typically interprets and applies the Code Panel Statements issued by the Panel (P/S) and Panel Instruments Public Consultation Papers (PCP) and Response Statements...

1 General information Review period [ Insert review period ]; Review date [ Insert date ]; Reviewer(s) [ Insert name(s) ] 2 Data Criteria For the last [ insert period, eg quarter ] and last 12 months, capture totals for: SARs received; ML/TF/PF‑related SARs; SARs to the National Crime Agency (NCA); DSARs needing consent/defence (granted, refused, pending); SARs not sent to the NCA; superSARs; CDD company discrepancy reports; and PEPs added to the central list 3 Review and findings Confirm a refreshed organisation‑wide ML/TF/PF risk assessment in the last year; AML/CTF/counter‑proliferation policies, controls and procedures reviewed, updated and communicated (incl. branches/subsidiaries); SAR and SuperSAR registers current; dates of staff training and record reviews [ Insert date ]. Note any SARs/superSARs needing further review; status of the high‑risk client/matter list (incl. PEPs) and quarterly reviews; CDD discrepancy register; table of high‑risk third countries; patterns/trends, compliance failures (ensure Compliance breaches policy followed), training needs; emerging risks (internal/external); planned new technology and related risks; required remedial actions; and...

To: [ All staff in [ insert ] office ] From: Response Team Leader RE: Regulatory investigation—prompt attention required Privileged and confidential Dear All Investigators from [ insert ] [ are OR will be ] arriving on site beginning today to commence an investigation. [ Insert organisation name ] treats its legal duties seriously and will co-operate with the investigators, addressing their requests in line with [ our [ Dawn raid action plan ] ]. A ‘dawn raid’ is when representatives of a regulator attend our premises without prior notice to gather evidence for an investigation. Refusing to co-operate with the investigation, or impeding the investigators, will put [ insert organisation’s name ] and individuals at risk of sanctions. Further information is contained in our [ Dawn raid action plan ]...

Person leading strategy review [ insert name ] (strategy lead) Coordinator [ insert name of a person who will assist with coordination ] Steering group [ insert names of personnel responsible for direction of strategy implementation ] Step number 1 Start strategic review process Step Actions Set a date for a strategy away day, allowing at least 12 weeks’ notice. Discuss and agree: who will lead the process who will attend as delegates whether an external facilitator is needed Book an appropriate venue. Complete the Timeline section for the rest of this plan. Begin the Precedent: Strategy away day—logistics planner. Timeline N/A (but start at least 14 weeks before the final strategy is required) 2 Initial communication and calendar bookings Step Actions If using an external facilitator, confirm their services and agree...