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UK/EU risk and compliance weekly: sanctions consolidation and licences, CJEU pseudonymised data ruling, UK AML reforms, cyber resilience, EU AI Act timing, CSRD/CS3D updates

Published on: 16 October 2025

Published by a LexisNexis Risk & Compliance expert
Legal News
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Article summary

Risk & Compliance weekly highlights—16 October 2025

In this issue:

  • Data Protection
  • Sanctions
  • AML, CTF & Counter-Proliferation Financing
  • Cybersecurity
  • Other Risk & Compliance updates this week
  • Daily and weekly news alerts
  • Trackers
  • New and updated content

Data Protection

When pseudonymised data gets personal (EDPS v SRB)

This appeal considered whether pseudonymised information must always be treated as personal data under the General Data Protection Regulation (Regulation (EU) 2016/679). The Court of Justice dismissed the appeal in part, offering guidance on three areas: how pseudonymised data should be classified; what counts as data ‘relating to’ an individual; and the transparency duties when sharing data with third parties. The Court rejected the stance that pseudonymised data is invariably personal in all scenarios. Where effective measures prevent a recipient from re-identifying individuals, and the re-identification risk is minimal, the data can be anonymous for that recipient, even if it remains personal data for the controller. The Court also concluded that controllers must declare all disclosures to third parties in privacy notices, even where the data will be effectively anonymous once in the third party’s possession...

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