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R (Greyhound Board of Great Britain Ltd) v Welsh Ministers [2026] EWHC 670 (Admin) What are the practical implications of this case? The ruling reinforces the constitutional divide between the courts and the legislature. It explains that the scheme and framework of the Government of Wales Act 2006 (GWA 2006) embody that separation of powers, and that any judicial attempt to recognise and enforce a common law obligation on Welsh Ministers to consult prior to introducing legislation in the Senedd would trespass upon that boundary. This is not a departure from established principle; case law has already upheld comparable rules for lawmakers in Scotland and at Westminster. However, this is the first express confirmation of the position for Welsh lawmakers, and the first time this dimension of the GWA 2006 has been analysed in such depth. The court examined earlier
The solution arrived through the United Nations Compensation Commission (UNCC), a quasi‑judicial body handling mass claims, created under UN Security Council Resolution 687. By addressing environmental harm—most notably via its ‘F4’ claim class—the UNCC set a seminal benchmark shaping how international law and contemporary arbitral panels allocate financial responsibility for wartime ecological devastation. With present-day wars in areas such as Eastern Europe and the Middle East bringing dam breaches, strikes on chemical facilities, and the burning of farmland, the UNCC’s legacy endures as an essential reference point for states, global investors, and companies engaged in post‑conflict arbitration. The F4 claims: Quantifying the unquantifiable Prior to the 1990s, mechanisms in international law for war reparations overwhelmingly favoured property loss, foregone earnings, and bodily injury. The natural world was commonly treated as a mute, non-compensable victim of armed hostilities...
Understanding the farming business as a business Many farms still use long-standing structures that arose by habit, not strategy. Sole traders, informal partnerships and outdated partnership deeds are common. While once effective, such setups can cause major issues around succession, tax planning and involving the next generation. A corporate team can take a fresh, business-led view of the farm, asking: Who owns the land and other critical assets? Who manages daily operations? Who carries the risk and who enjoys the return? What is the enduring plan for succession? From this review, the team can confirm whether the current setup is fit for purpose or if an alternative — for example an updated partnership agreement, a company, a limited liability partnership, or a blended model — would better meet the family’s aims. Tax efficiency through joined-up advice Tax sits at the centre of most
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The Financial Conduct Authority ( FCA) has released the results of a review evaluating financial services firms’ frameworks and controls relating to financial and trade sanctions. The publication sets out illustrations of effective and weak practice, plus development priorities, to support firms in meeting sanctions legislation. According to FCA, firms have advanced in avoiding sanctions breaches, yet deficiencies persist......
Risk & Compliance weekly highlights-28 May 2026 In this issue: Sanctions Fraud Other financial crime Daily and weekly news alerts Horizon scanning Trackers New and updated content Sanctions FCDO announces Russia sanctions targeting crypto exchanges and A7 network The Foreign, Commonwealth and Development Office ( FCDO) has unveiled a fresh UK sanctions package aimed at cryptocurrency exchanges and the Kremlin-backed ‘ A7 network’, which Russia uses to evade existing measures and channel funds into its war economy against Ukraine. The actions are intended to curb Russia’s growing reliance on ‘dark networks and shadow financial systems’ to sidestep controls and disrupt related financial flows. The package introduces 18 designations against Russia’s illicit financial infrastructure, covering A7-linked individuals, a Kyrgyz bank suspected of processing payments for the network, and three Georgian firms operating Russia-focused exchanges seeking to avoid...
CPA 2026 materially widens corporate criminal exposure by extending attribution for all offences to conduct by ‘senior managers’ exercising significant decision-making power. This moves risk beyond the narrow ‘directing mind’ test and brings companies-particularly large, decentralised groups-under sharper enforcement scrutiny. Expect prosecutors to probe operational leadership, governance gaps and aggregate evidence across individuals. Boards should revisit delegation, clarify accountability and reinforce oversight of operational choices. A continuing hurdle is pinpointing who is a senior manager in complex structures, with courts likely to prioritise substance over form. More broadly, the regime will reshape how organisations record authority, decisions and escalation, with greater emphasis on demonstrating how choices are taken and supervised in practice. A reshaped strategic risk profile The most immediate effect of CPA 2026 is a broader range of situations in which a company can be criminally liable. Historically, attribution turned on the...
OFSI General licence INT/2024/4761108 The Office of Financial Sanctions Implementation ( OFSI) has revised General Licence INT/2024/4761108. The update: Introduces a fresh definition of ‘cryptoasset’, meaning a cryptographically secured digital expression of value or contractual rights that relies on a form of distributed ledger technology and is capable of being transferred, stored, or traded electronically Adds a new obligation to report for any person using cryptoassets to send or receive a payment under the General Licence The updated licence is available here. Source: OFSI General licence INT/2024/4761108......
Risk & Compliance weekly highlights—16 April 2026 In this issue: Data protection Sanctions Daily and weekly news alerts Trackers New and updated content Data protection EDPB adopts DPIA template to strengthen consistency in GDPR compliance processes The European Data Protection Board ( EDPB) has approved a template for Data Protection Impact Assessments ( DPIAs) to streamline adherence to Regulation ( EU) 2016/679 ( General Data Protection Regulation ( GDPR)) and foster greater alignment across Europe. The template helps organisations to organise, harmonise and evidence DPIA reporting, supported by an accompanying explainer to aid practical implementation. The draft is open to public consultation until 9 June 2026. See: LNB News 15/04/2026 22. Sanctions HM Treasury publishes OFSI strategy 2026–29 HM Treasury has released the Office of Financial Sanctions Implementation ( OFSI) strategy for 2026–29, confirming OFSI’s core aim to ensure financial sanctions remain...
Risk & Compliance weekly highlights—9 April 2026 In this issue: Data protection Other Risk & Compliance updates this week Daily and weekly news alerts Trackers New and updated content Data protection ICO updates UK GDPR lawful basis guidance following Data ( Use and Access) Act The Information Commissioner’s Office ( ICO) has revised its UK General Data Protection Regulation ( GDPR) lawful basis guidance to align with changes introduced by the Data ( Use and Access) Act 2025 ( DUAA 2025). A seventh lawful basis, ‘recognised legitimate interest’, has been added for pre-approved purposes such as safeguarding vulnerable people, dealing with emergencies, preventing or investigating crime, addressing national security matters, and sharing personal information for public tasks. This basis does not extend to public authorities processing personal information to perform their official functions. See: LNB News...
Risk & Compliance weekly highlights—2 April 2026 In this issue: Data protection AML, CTF & counter-proliferation financing Sanctions Other Risk & Compliance updates Lex Talk®Risk & Compliance: a Lexis®Nexis community Daily and weekly news alerts Trackers New and updated content Data protection ICO consults on updated guidance for automated decision-making and profiling The Information Commissioner’s Office ( ICO) has opened a consultation on refreshed guidance covering automated decision-making ( ADM), including profiling. Triggered by the Data ( Use and Access) Act 2025 ( DUAA 2025), the update concentrates on provisions specific to this topic. It is intended for data protection officers, compliance specialists and technical leads. The ICO indicates the guidance offers expanded detail on ADM as set out in Articles 22A–22D of the UK GDPR, where outcomes are determined solely by automated processing and have legal or similarly significant effects on individuals. It is designed to help organisations understand and fulfil their...
Risk & Compliance weekly highlights—26 March 2026 In this issue: Data protection Sanctions Daily and weekly news alerts Trackers New and updated content Data protection ICO updates data protection guidance following DUAA 2025 and publishes guidance on recognised legitimate interest The Information Commissioner’s Office ( ICO) has refreshed three key guidance documents: Guidance on data protection principles, updated to incorporate changes made by the Data ( Use and Access) Act 2025 ( DUAA 2025), including specific provisions on compatibility and the re-use of personal information Guidance on the legitimate interests lawful basis, revised to reflect amendments introduced by DUAA 2025 and also aligned with the ICO’s latest style guide Purpose limitation guidance, amended to reflect DUAA 2025, including specific provisions on compatibility and the re-use of personal information, and aligned with the ICO’s latest style guide The ICO has also...
Risk & Compliance weekly highlights—19 March 2026 In this issue: Risk & Compliance forecast Sanctions Fraud Data protection Artificial intelligence & information security Daily and weekly news alerts Trackers New and updated content Risk & Compliance forecast New Risk & Compliance forecast as at 17 March 2026 Our latest Risk & Compliance forecast (as at 17 March 2026) is now available. This month we cover: (1) the Home Office’s Fraud Strategy for 2026–29, (2) a call for evidence on economic crime information-sharing gateways, (3) the ICO’s intention to publish revised guidance on special category data, and (4) the forthcoming SRA keeping of the roll exercise. See News Analysis: New Risk & Compliance forecast as at 17 March 2026. Sanctions OFSI blog sets out updated approach to assessing reasonableness in sanctions licensing applications The Office of Financial Sanctions Implementation ( OFSI) has issued a blog setting out its refreshed approach to assessing...
Background to the case Dana Astra IOOO (‘ Dana Astra’) is a property and construction enterprise registered and operating in Belarus, whilst its holding company, Dana Holdings, is registered in Cyprus. Dana Astra does not maintain any place of business or assets in the UK. On 31 December 2020, the UK designated Dana Astra for sanctions (shortly after the EU’s listing on 17 December 2020) under the Republic of Belarus ( Sanctions) ( EU Exit) Regulations 2019, SI 2019/600 (the ‘ Regulations’). The Secretary of State considered there to be reasonable grounds to suspect Dana Astra of being ‘complicit in the repression of civil society’ in Belarus. In particular, it was said that Dana Astra’s proprietors are closely connected to President Lukashenko; that Dana Astra had acted as sponsor of the Belarusian National Olympic Committee as the only entity that was not...
New Risk & Compliance forecast as at 17 March 2026 Our Risk & Compliance forecast as at 17 March 2026 monitors proposed regulatory developments relevant to Risk & Compliance practitioners, enabling you to prepare for any changes that may impact your organisation. You should please read it carefully and in full, although several matters that ought to be on your radar are outlined below......
On 9 March 2026, the CMA released guidance titled ‘ Complying with consumer law when using AI agents’, together with research called ‘ Agentic AI and consumers’. These publications signal rising regulatory focus on the impact of autonomous AI in consumer markets and examine how existing consumer legislation applies to agentic AI. The CMA sets out a policy overview of agentic AI, considers potential future developments, identifies likely benefits and risks for consumers, and outlines actions for businesses building or using agentic AI to ensure compliance with consumer law and to cultivate trust in their systems. This commentary summarises: the scope of the CMA’s analysis key takeaways for practitioners practical steps businesses can take now to meet consumer protection expectations What the publications covers From tools to autonomous agents A central theme is the movement of...
A refreshed second version of the EU code of practice for generative AI has been presented to developers and users, featuring milder, adaptable pledges and generally softer, more flexible commitments overall. Under the EU’s AI Act, makers of tools such as Open AI’s Chat GPT and Anthropic’s Claude must tag synthetic outputs in machine-readable form, while users must flag deepfakes and other material of public significance. This updated voluntary code, intended to help meet the Act’s transparency rules and facilitate compliance, scales back several proposals, recasting elements judged to exceed the AI Act’s remit as optional actions rather than firm obligations. The text adds that the European Commission will further define the reach of transparency duties and any exceptions in forthcoming guidance to accompany the code, clarifying how scope and related carve-outs should apply in...
John Ormerod, a 75-year-old former accountant from London, was hit with UK sanctions in May 2025, linked to his acquisition of 26 vessels valued at hundreds of millions of pounds between December 2022 and August 2023. After they were sold on, Russian company Lukoil employed the ships to move barrels of oil. The fleet became part of Russia’s so-called shadow network, used to evade sanctions imposed after its full-scale invasion of Ukraine. Although Ormerod disposed of the ships in 2023, he was nevertheless designated in 2025 as a UK-based national. His designation was removed on 2 March 2026, only weeks after he publicly condemned Russia’s actions in Ukraine. His lawyers said the listing left him unable to access funds to meet basic needs. Abigail Healey, a partner at Quillon Law acting for Ormerod, said the UK Foreign, Commonwealth &...
Share your insights here What changes have been made by OFSI to its guidance on financial sanctions enforcement and monetary penalties? The latest iteration of the guidance sets out four principal changes: Reworked case assessment process ( Chapter 5): The document now includes an 'indicative matrix' to gauge the gravity of a breach. This matrix aligns breach severity with specified aggravating and mitigating considerations. It identifies four tiers of seriousness. Breaches falling within level 3 (high) or level 4 (very high) are expected to attract monetary penalties, with baseline figures of up to 75% or 75–100% of the statutory maximum, respectively. Level 4 matters may additionally be passed to law enforcement for criminal investigation. A number of case factors have been introduced, altered, retitled or removed......
Risk & Compliance weekly highlights—5 March 2026 In this issue: Data protection Sanctions AML, CTF & counter-proliferation financing Anti-bribery & corruption Other Risk & Compliance updates this week Lex Talk®Risk & Compliance: a Lexis®Nexis community Daily and weekly news alerts Trackers New and updated content Data protection Data by any other name— Court of Appeal reverses Upper Tribunal’s ruling on the protection of ‘personal data’ ( DSG v ICO) In DSG v ICO, the Court of Appeal unanimously upheld the Information Commissioner’s Office ( ICO) appeal. It ruled that data subjected to unauthorised or unlawful processing by a third party still counts as personal data from the controller’s perspective, even where it is pseudonymised for the controller and thereby appears anonymised to the attacker. As a result, controllers must deploy ‘appropriate technical and...
Although the indicators do not materially alter the foreign bribery offence and will be well known to many legal and compliance practitioners, they mark a further move towards the global harmonisation of the criteria used to assess corruption risk. This piece reviews the IFBT’s newest guidance, considers what it means for multinational businesses, and notes developments in other recent cross-border anti-corruption efforts. International Foreign Bribery Taskforce The International Foreign Bribery Taskforce ( IFBT) brings together law enforcement bodies from the so-called Five Eyes: Australia, Canada, New Zealand, the UK and the US, to share intelligence and tackle bribery and related crime. Its members comprise specialists in foreign bribery from the Australian Federal Police; the Royal Canadian Mounted Police; the New Zealand Police and the New Zealand Serious Fraud Office; the UK Serious Fraud Office ( SFO) and the National Crime Agency; and the US Federal Bureau of...
On 18 February 2026, Nikhil Rathi said on a podcast that the FCA would instead use the Consumer Duty to spot instances of harm. Consumer organisations have criticised the FCA for a light-touch stance on regulation after two wide-ranging probes into the insurance sector concluded with no proposals for intervention. Rathi, speaking on a Fairer Finance podcast, argued that not every issue will be resolved quickly through major interventions, additional rules, bans or guidance as he told listeners......
In this issue: Risk & Compliance forecast Sanctions Data protection Artificial intelligence & information security Other Risk & Compliance updates this week Daily and weekly news alerts New and updated content Risk & Compliance forecast New Risk & Compliance forecast as at 17 February 2026 Our refreshed Risk & Compliance forecast (as at 17 February 2026) is now available. This month it highlights: (1) the ICO’s plans to revise existing guidance for the privacy notice generator; (2) OFSI’s Call for Evidence on the ownership and control test in UK financial sanctions regulations; (3) new Economic Crime Levy bands and charges from April 2026; and (4) the publication of final updates to Part I of the JMLSG’s AML guidance. See News Analysis: New Risk & Compliance forecast as at 17 February...
Fiona Ghosh, Patricia Wade and Nilesh Ray of Ashurst delve into each of these matters in greater depth below. Overview The draft Code takes a decisive stride towards turning the broad transparency duties in Article 50 of the Act into concrete, operational expectations for both providers and deployers of generative AI. Shaped by extensive engagement with stakeholders, it offers the first coherent roadmap for how organisations should handle the marking and detection of AI-generated or manipulated content, alongside the labelling of deepfakes, from here on. The Article 50 transparency duties take effect on 2 August 2026. As that date draws nearer, adherence to the steps in the draft Code is poised to serve as a key yardstick for assessing day-to-day compliance. In practice, it will set clear expectations across the market. Who's covered? The draft Code captures 'providers' (those placing Gen AI systems on the market) and...
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This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...
Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...
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