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The FCA, PRA, and Bank of England have published their finalised critical third party (CTP) rules (and accompanying guidance) in PS24/16 Operational resilience: Critical third parties to the UK financial sector....more
The new regime will take effect on 1 January 2025, but will not diminish the responsibilities of financial services firms relying on the services of critical third parties....more
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
The Personal Information Protection Act ("PIPA") comes into full force on 1 January 2025. All organisations in Bermuda are expected to be in compliance with it by that date – time is running out! The Privacy Commissioner...more
The announcement in 2021 of the intention to implement new rules directly targeting the types of tech service provider relied on by most financial institutions may be a necessary corrective given the heavy market...more