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Lobbying.  The descriptor we use for seeking to influence key decision makers. It’s been a part of commercial life for centuries and many societal structures were and are built on it such as the medieval guilds, modern trade associations, and a myriad of other bodies who exist to influence, persuade and argue.  Law firms too.  Covington, for instance, is the law firm with the biggest lobby turnover of 93 law firms registered to lobby in the EU.  When organized lobbying can be powerful and while that power can be used abusively, it is also a necessary for informed policy formation in a democratic society.

Who lobbies who can be controversial as we see with the current controversy surrounding the ex UK Prime Minister David Cameron’s lobbying on behalf of Greensill Capital, a then troubled finance company.  What is lobbied can be equally controversial as land zoning corruption scandals in 1990s Ireland has shown.  So while it has had a bad name on the back of scandals where influence was wrongly peddled and traded, lobbying is nevertheless necessary and a force for good.  Policy makers and legislators need lobbyists to identify when a new policy or new law is needed and to understand how the policy or law will impact and, critically, what the alternatives might be.  Lobbyists need legislators to legislate effectively and with as little bureaucracy as possible.  That tension is usually a good one, despite the occasional bad actors.

But sometimes the balance goes askew – as it did in Ireland in the years prior to the economic and property crash of 2008.  Several tribunals of enquiry had examined allegations of corruption in the beef industry, retailing, and in planning matters.  Allegations of improper influence by key players and payments to politicians loomed large and involved senior politicians and businessmen.  In one instance the Taoiseach (head of government) and former Minister for Finance, failed to give a credible account for large donations he received while indicating he kept his money under his mattress.  Another former Taoiseach, with a penchant for expensive French shirts and racehorses, was unable to clarify how he had amassed his obvious wealth.  The various tribunals of enquiry racked up significant expenditure and while ultimately seen as legally toothless they were nevertheless credited for highlighting illicit and unethical behavior in high places.  It impacted political and business reputations.  A leading lobbyist was convicted of corruption, and a former Minister for Justice accused of corruption, was imprisoned for failure to declare tax on payments received.  Others lost their political positions.  Lobbying became a tainted concept.

In the aftermath of the subsequent financial crash and the shock of having the IMF informing key decisions, Ireland enacted the Regulation of Lobbying Act in 2015.  Born of a nation fed up of political wrongdoing and the perception of lost sovereignty, the new legislation was positively received.  This positivity has largely continued over the last 6 years and the register is now seen as a marketing tool by many lobbyists and a welcome source of information for media and political pundits.  In publishing the headline issues being lobbied upon, it also has the effect of ensuring such issues are not ignored.  By providing factual information it limits the potential for inaccuracies and speculation.  It’s limited in its impact beyond that as it only gives a snapshot of issues and applies only in the more serious lobbying influence situations.  While criticized for not going far enough, it nevertheless is accepted and worked to with compliance levels reported by the regulator as high.

The Regulation of Lobbying Act 2015 is about the who lobbies, what about and with whom.

  • Who is making, managing or directing is defined as a representative or advocacy body or other 3rd party with at least one full time employee or an employer with at least 10 such employees.  It does not generally include unpaid volunteers unless they are directed by an employee or official of the organization they represent.  So  most local issues by local groups are outside the remit of the legislation.  However, there is a particular place for land lobbying, reflecting the Irish obsession with property ownership and the planning scandals of the past.  Planning and rezoning lobbies are thus specifically covered (unless related to an individual’s principal private residence on less than 1 acre) and without the requirement to have an employee.
  • What is the relevant issue for lobby reporting is defined to include the initiation or development or modification of public policy or a public programme.  Lobbying on the preparation and amendment of law is covered but excluded is the implementation of such policy or programme or where the matter is of a technical nature only.  Also representative bodies do not have to declare the identities of individual members on whose behalf they are lobbying.  Normally the sector only is identified.
  • The with whom is limited generally to designated senior public servants and to politicians.

Excluded from the Act are the activities of expert policy groups (like the Company Law Review Group) generally established to advise the State.  The representative nature of these groups in itself will often balance out the interests of stakeholders and as such are valuable to Government Ministers in formulating public policy.  Also excluded are contributions to public consultations issued by government and it’s agencies.  So the obligation to report a lobby excludes much of the local and more minor issues that politicians and less senior public officials will be approached on as well as government initiated public consultations.

The range of public policy issues lobbied in the last 2 years covers a broad span.  Health leads the field with a significant footprint, as might be expected given the pandemic.  The second most commonly lobbied area is economic development and industry followed by agriculture.  Education and training with justice and equality issues follow in fourth and fifth place respectively.  Sub categories of business issues are not easily identified.  However the most lobbied on business issues were politicians, followed by the government department with responsibility for business issues and the Taoiseach (head of government).

The experience of the lobby register in Ireland is interesting for a number of reasons.

  1. Most lobbying comes from the business and farming sectors.
  2. The geographic spread of registrants shows a concentration of lobbyists in areas with a significant multinational or sectoral presence. As expected Dublin has the highest number of lobbyists.  Both Galway (a medical device hub) and Cork (a pharmachem hub) are strongly represented.
  3. Only 16 Northern Irish lobbyists have registered most likely reflecting the UK lobbying regulation.
  4. Irish lobby returns are almost 14 times that of the UK despite the Irish republic population being 13% that of the UK.
  5. Unsurprisingly, the most lobbied topic for 2020 was health, however it has also topped the league in each previous year since reporting began in 2015.
  6. Draft legislation, currently being debated, proposes to enforce a 12 month cooling off period for former officials/advisors taking up positions as lobbyists, an increasingly common practice here.

The Report is the result of President Biden’s February 24 “Executive Order on America’s Supply Chains” (the “Order”), which directed federal departments and agencies to conduct a review of supply chain risks in four critical product areas,[1] including pharmaceuticals and active pharmaceutical ingredients (“APIs”).  The Report and its recommendations further the Biden administration’s broader goal of rebuilding the U.S. industrial base, reducing reliance on foreign competitors, and bolstering national and economic security.The U.S. Department of Health and Human Services (“HHS”) led the review of the supply chain for pharmaceuticals and APIs, which focused primarily on drugs, in particular small-molecule drugs and therapeutic biological products.  The Report makes a number of recommendations discussed herein that have the potential to impact pharmaceutical companies’ business plans and generate significant opportunities, though many such recommendations are long-term and will require dedicated funding so the actual impact of the Report’s suggestions remains to be seen.

Pharmaceutical Supply Chain Vulnerabilities

Informed by the vulnerabilities that the COVID-19 pandemic has highlighted, the Report underscores a number of fundamental risks to the stability and resilience of the U.S. pharmaceutical supply chain:

  • The U.S. supply chain is overly dependent on foreign supplies of pharmaceutical products and APIs, particularly from China and India.
  • Due to various economic pressures, contracting practices, foreign anticompetitive actions, and low margins, generic manufacturers, which produce 90 percent of drugs prescribed in the United States, have relocated production overseas.
  • Low geographic diversity of manufacturers, as well as consolidation in the production of APIs and finished dosage forms overseas, place the U.S. supply chain at risk of disruption due to geopolitics, natural disasters, or other events.
  • Limited redundant capacity in manufacturing creates similar risks, as the median number of drug manufacturers per a unique drug or dosage form is between two and three.
  • The pharmaceutical industry faces obstacles in responding to disruptions and surges in demand, due to factors like high costs in expanding manufacturing capacity, the need for regulatory approvals, and just-in-time inventory management practices.
  • The prescription drug market offers few incentives for manufacturers to invest in upgrading equipment and manufacturing technologies or improving quality management.
  • The Food and Drug Administration (“FDA”) lacks sufficient insight into the supply chain to monitor and identify risks.

Key Recommendations and Takeaways

To respond to these vulnerabilities, the Report proposes a whole-of-government and -industry effort, with a focus on improving supply chain transparency, incentivizing resilience and reductions in drug shortages, and increasing the economic sustainability of U.S. drug manufacturing.

The Report organizes its recommendations into three overarching categories.

First, HHS outlines a number of initiatives to boost domestic production capacity.  HHS’s strategy recognizes, however, that the United States cannot produce every drug at home.  Of particular note to pharmaceutical manufacturers:

  • The Biden administration plans to establish a consortium for advanced manufacturing and onshoring of domestic essential medicines production, leveraging Defense Production Act (“DPA”) authority and existing public-private partnerships. Among other functions, the consortium of government and private sector stakeholders will help identify financial incentives and investments to promote the development of domestic production capacity, evaluate the merits of a successor financing program to the DPA Loan Program, and address regulatory questions.  As a first step, the consortium will identify 50 to 100 critical drugs from the Essential Medicines List to be the focus of its onshoring efforts.
  • The Report details various programs to promote research and development in innovative manufacturing processes and production technologies, especially in advanced manufacturing. HHS plans to make an initial commitment of $60 million from the American Rescue Plan’s DPA appropriation to develop novel platform technologies to increase the domestic manufacturing capacity for APIs.
  • HHS proposes targeted actions to create redundancy in the production of sterile injectables, which the Report found are particularly susceptible to shortage. To reduce the likelihood of shortage due to low margins, the government will review reimbursement models to determine whether changes can be made to increase profit margins from federal payers.  The Report also suggests using procurement guarantees to address manufacturers’ need for consistent demand to justify investment in new production.
  • To incentivize improvements in quality management, HHS and FDA propose creating a rating system for evaluating a manufacturing facility’s quality management maturity. The rating system could be used to inform purchasers and would reward manufacturers that focus on continuous improvement, business continuity plans, and early detection of supply chain issues.
  • The Report recommends that FDA and HHS encourage stakeholders to increase their use of commercial data to identify and mitigate supply chain risks, and urges Congress to expand FDA’s authority to collect supply chain data.  Proposals include requiring manufacturers to notify FDA of increases in demand and requiring manufacturers label finished products with original manufacturer information.

Second, HHS proposes building emergency capacity, centered on a virtual stockpile of materials necessary for producing the Essential Medicines.  In lieu of a physical stockpile, a virtual stockpile would consist of contracts with API and drug suppliers to hold the surplus, along with support for surge manufacturing capacity.

Finally, HHS’s strategy calls for international cooperation with allies to develop supply chain resilience.  Among other initiatives, the Report recommends that the U.S. and its partners develop complementary onshoring strategies and minimize unnecessary duplication, as well as build a centralized cross-country API supplier database.

In connection with the Report, the Biden administration also announced several initiatives implicating all four critical products highlighted in the Report, including a proposal for a Supply Chain Resilience Program under the Department of Commerce with $50 billion in funding to make investments in strengthening supply chains.

The recommendations detailed in the Report are ambitious and potentially transformative, but their impact on the pharmaceutical industry will depend on their design and implementation.  Many of the recommendations are long-term initiatives, and (as the Report notes) will require dedicated funding.  Some proposals, such as improving data collection, will also require statutory changes.

As these proposals take shape, they may lead to new business opportunities, regulatory obligations, or supply chain management strategies for pharmaceutical companies.  The Report correctly emphasizes engaging with industry stakeholders in developing initiatives.  Along with keeping close eye on opportunities for collaboration, for additional insight on implementation, industry members should look towards HHS’s one-year review of the public health and biological preparedness industrial base that the Order mandates, along with HHS’s work on the Pandemic Supply Chain Resilience Strategy, which the Report mentions should be completed this month.

 

[1] In addition to pharmaceuticals and active pharmaceutical ingredients (APIs), the Report also discusses semiconductor manufacturing and advanced packaging, and large capacity batteries, critical minerals and materials.

Special thanks to Nicole Ng for her excellent assistance with this Inside Government Contracts post.

More than a year later, in a public opinion of over 120 pages, the French Competition Authority (“FCA”) provides its initial conclusions (i) noting the emergence of new services, initiation channels and alternative payment methods, (ii) reporting on a new market dynamic with the arrival of new players and the impact on traditional banking groups and (iii) addressing some of the competition issues facing the sector.

The emergence of multiple new services, initiation channels and alternative payment methods

Today, the payment sector is revolutionized by two new technologies: cloud services and blockchain, which, although not specific to this sector, are likely to, in the FCA’s view, profoundly modify its functioning in the long term.

  • Cloud services include outsourcing solutions for data storage which are becoming a must-have for many financial players, both new entrants (e.g., Apple Pay) and traditional players (BNP Paribas), due to their flexibility and performance benefits;
  • As to blockchain, the FCA views the application of this technology as particularly promising as it should (i) promote the development of innovative services, (ii) improve both the / execution of transactions in crypto-assets and the security of payments in general, (iii) reduce the cost of payment services and (iv) accelerate cross-border transactions.

A new market dynamic: the new players and the reaction of the traditional banking groups

In the payment sector, two new players are emerging, FinTechs and BigTechs:

  • FinTechs bring together a myriad of entities with varied profiles and economic models. The FCA observes that the main common denominator of these players is that they have developed “niche” business segments that rely on new technologies, especially the smartphone.
  • BigTechs refers to the major digital players such as Google, Apple, Alibaba, Xiaomi, who enter the financial sector. The FCA notes that while these players have varied business models and entry strategies, data acquisition and exploitation is key in their business model.

As for the traditional banking players, they are seeking to adapt by investing directly in FinTechs in order to internalize certain innovations and to create synergies or to conquer new markets (e.g. Société Générale controlling the Fintechs BoursoramaTreezor and Prisméa). In addition, these traditional players also enter into cooperation and partnership agreements, especially with the new non-banking players. The FCA notes that one of the major developments in the payments sector in recent years has been the emergence of agreements between banking groups and BigTech (e.g. the agreements between Apple and the six largest French banking groups to offer Apple Pay to the traditional banking customers). Finally, by investing in research and development, a number of banking groups are creating incubators, bringing start-ups into the payments industry in order to accelerate digital transition and attract new customers.

The competitive analysis and the FCA’s concerns

The FCA starts with a traditional market definition analysis: are the services provided by new entrants compared to those provided by traditional banking players substitutable or complementary. It observes that the payments sector is a two-sided market and characterized by a strong dynamism. For the moment, it would appear that the services introduced by the new players is complementary to those of the traditional players but the FCA notes that this link can quickly change, in particular by integrating these services into the offerings of banks or, conversely, by FinTechs developing their own complete banking offers. Consequently, the FCA concludes that the market dynamism makes the exercise of defining the relevant markets more complex, especially in the context of the prospective analysis in merger control.

The FCA also highlights the existing regulatory and economic barriers to entry and expansion in the payment sector which explains why innovating FinTechs are using new technologies and innovation to enter the market.

In addition to the barriers mentioned above, the FCA identifies two other barriers to entry, (i) access to certain technological infrastructure, particularly the NFC smartphone antenna and (ii) access to data which allow certain FinTech to offer their payment services in the context of the application of the PSD2.

On the first barrier to entry (i), the FCA observes that the effective access (opening or closure) to the NFC antenna on smartphones has a real impact on the ability of the players who have developed contactless mobile payment solutions based on NFC technology to offer their services on devices equipped with these antennas. On the latter barrier to entry (ii) it is noticed that various APIs developed by the account-servicing payment service providers (“ASPSPs”), including the banks in particular, are still not fully operational in France.

These are further barriers that have led the authority to issue points of vigilance. Among these risks, have been identified:

  • competitive risks associated with the use of blockchain; or
  • the risk of calling into question the universal banking model and marginalization of traditional banking players;
  • the risk of hindering the development of payment initiation service providers and account information service providers.

With regard to the latter risk, the FCA observes that the evolutions in the payment sector could lead to a profound change in its functioning. For instance, depositing and cashing checks and cash could be called into question. In addition, the FCA raises the risk for traditional banking players of being confined in the long term to execution tasks with significant fixed cost, while being marginalized in the distribution chain value. On the contrary, BigTechs could control certain innovative technologies, which may play, in the future, a decisive role in the service chain.

The 1998 Good Friday Agreement (also known as the Belfast Agreement), which brought to an end three decades of inter-communal violence, also heralded the advent of 23 years of increased cross-border trade and cooperation as well as an increase in Irish exports to the UK.  That ease of access and trade was facilitated by the membership of both the UK and Ireland of the EU which created stability for the All-Ireland economy through the EU internal market.  That stability has been disrupted by Brexit.

The whole of Ireland is about the same size as the US state of South Carolina; just 60% of the land mass of New York state.  The population of the whole of Ireland is just 6.8 million with almost 1.9m in Northern Ireland. The Irish border, which is just 100 years old this year, runs across farms and communities.  It divides the 32 County Ireland into 24 and six.  The Border is 499 km long and is criss-crossed by over 200 roads.

Given the difficulty of policing so many small roads, it may seem to make sense to place the EU /UK  border in the Irish sea and not across the roads and fields that now form the only EU land border with the UK.  But that would be to ignore the complex and delicate political balance that the Good Friday Agreement was crafted upon.

The political divide in Northern Ireland is essentially between the Protestant Unionist community that overwhelmingly wants to retain the link to the UK and the Catholic and largely nationalist community that would like to see a united Ireland.  Traditionally, the Protestants have been in the majority in Northern Ireland, but that demographic gap seems to be closing.  The last published census in 2011 showed that just over 48% of the population of Northern Ireland were Protestant and slightly more than 45% were Catholic.  But Catholics outnumbered Protestants in all the under 50 age cohorts.  That statistic means that by this year the population was forecast to be 46% both Protestant and Catholic.  The 2021 census, conducted last March, will be published next year.  If it confirms this trend, then it increases the possibility of a Border Poll on Irish reunification, as provided for in the Good Friday Agreement.

‘Partition’ of the island of Ireland, was a controversial compromise between the British administration and the rebel Irish pushing for independence in the 1920’s.  The then Unionist majority in Northern Ireland wanted to retain the link to Britain, being the descendants of Scottish and English colonists from the 1600s.  Partition in 1921 led to a bloody civil war in Ireland.  Eventually those in favour won out however the issue has remained contentious and resulted in further and extended violence over 30 years to 1998.  That period known as ‘The Troubles’ claimed thousands of lives and caused huge economic damage.

At the time of Partition, Northern Ireland was – and had been – a powerhouse of economic development built largely on shipbuilding and flax for linen making.  This economic success stood in sharp contrast to the economic impoverishment of the new Republic in the south.  100 years later and that situation is reversed – the Republic is an economic powerhouse while Northern Ireland remains reliant on UK subsidies to support a lagging economy.

The Good Friday Agreement brought conditions that enabled the Governments in Dublin and London to cooperate to restart economic growth in Northern Ireland.  The UK government, in particular, poured huge subsidies into Northern Ireland, where over one third of the population are employed in the public sector. Both the Irish and UK governments, with encouragement from the US in particular, co-operated to improve life in the North and prevent a recurrence of the violence.  European unity was, moreover, a key unifier as the European Commission set development priorities, supported human rights issues in a non-partisan way, and enabled freedom to trade within the internal market including trade with the Republic of Ireland.

Traditional all-Ireland trading patterns had, particularly with EU membership and strong political consensus, shown promising signs of recovery in recent years and business communities both sides of the border began to develop a number of cross border initiatives.   Whiskey as an all island brand is a good example.  Whiskey manufactured in the south with blended inputs from both sides of the border, could be bottled in the north of Ireland.   New distilleries sprang up all over the island: 96% of Irish whiskey from the island of Ireland was exported in 2020.

Dairy products are another good example – a global export for the island with a healthy and growing international trade in butter and dairy products (Northern Ireland sends one third of its milk to the south for manufacturing).  The European market is important for both those industries.  And the IT sector was showing promise with a number of international investors showing interest.

Brexit changed much of that.

Trade is not now so easy – as Thomas Reilly explained in his previous blog.  Creating the Great Britain-Ireland border in the Irish Sea should have given impetus to the Northern Irish economy, affording it the unique benefit of being in two markets at the same time – the UK market and the EU.  However, politically, it is very unpopular with many Unionists and risks becoming a lightning rod for renewed violence.

Even on the commercial front, there are a number of immediate downsides, including such practical issues as rules of origin tariffs for products such as whiskey and dairy emanating from both sides of the border (e.g. tariffs on products with inputs from both Northern and southern Ireland but none where produced solely in one jurisdiction).  Customs procedures have created delays at ports, supply chain disruption and VAT complexities have not helped.  Agro-food imports from the UK are down significantly.

The EU/UK Northern Ireland border issues can be illustrated with some statistics.

  • The EU, taken as a whole is the UK’s largest trading partner. In 2019, before Brexit, UK exports to the EU were £294 billion (43% of all UK exports). UK imports from the EU were £374 billion (52% of all UK imports).
  • Northern Ireland had the highest proportion of goods imports to the UK from the EU and had the second highest percentage, after Wales, of goods exports to the EU from regions of the UK in 2019.
  • 30% of UK food originates in the EU.  Much of that is Irish.
  • The UK’s top trading partner for dairy, eggs and meat is Ireland – 67% of beef imports to the UK came from Ireland in 2018.

Settling the Irish border issue is a priority to unclog trading and political relationships and to prevent further damage in particular to the UK/ EU relationship.  In the meantime it’s a headache and an uncertainty – legally, politically and economically – for businesses operating between the only UK and EU land border.

On June 30, President Biden signed into law a joint resolution to repeal the Office of the Comptroller of the Currency’s (OCC) so-called true lender rule.  The rule was repealed under the Congressional Review Act (CRA), which allows Congress to repeal new federal regulations by passing a joint resolution of disapproval that must be later signed by the president.  Federal regulations repealed under the CRA are treated as if they had never gone into effect. Continue Reading Congress Repeals the OCC’s True Lender Rule

For the last several years, GSA has been piloting just such an alternative:  the Transactional Data Reporting (“TDR”) program, through which the government collects transaction-level data on products and services purchased through the Schedule to make data-driven decisions that save taxpayer dollars.  GSA has been running a TDR pilot program for several years to test the potential for a new regulatory regime, though the program sometimes has been the source of criticism and controversy.  Now that controversy has heightened further:  GSA’s Office of Inspector General published an audit report on June 24, 2021 that is sharply critical of the program, only to see GSA’s Federal Acquisition Service (“FAS”) Commissioner publicly reject the report’s conclusions and defend TDR’s effectiveness. Continue Reading The End of CSP and PRC Requirements? — GSA’s TDR Pilot Program Faces Further Internal Criticism

On 6 May 2021, the European Commission (“Commission”) published the findings of its evaluation of the horizontal block exemption regulations for Research & Development (“R&D BER”) and specialisation agreements (“Specialisation BER”, together “HBERs”), as well as the accompanying Horizontal Guidelines (“Evaluation”).

The Commission launched the Evaluation in 2019 to assess the future relevance of the HBERs and the Horizontal Guidelines, since their adoption in 2011 and 2012.  It gathered a variety of evidence on the functioning of the HBERs, which included: Continue Reading The European Commission publishes the results of its evaluation of the horizontal block exemption regulations and guidelines

Covington’s four-part video series offers snapshot briefings on key emerging trends in UK Competition Law. In part three, James Marshall and Sophie Albrighton discuss digital markets, one of the key areas of focus of competition authorities around the world today, including in the UK. They are joined by guest speaker Martin Hansen, Of Counsel in Covington’s Technology Regulatory and Policy practice based in London.

Pressed for time? Click here to download this session’s key takeaways.

Next week will be a committee week in the European Parliament.  Members of the European Parliament (“MEPs”) will gather virtually and in person in Brussels.  Several interesting votes and debates are scheduled to take place.

On Monday, the Committee on the Environment, Public Health and Food Safety (“ENVI”) will vote to adopt proposed amendments to the draft opinion on critical raw materials (“CRM”).  The amendments can be found here.  The opinion is addressed to the Committee on Industry, Research and Energy (“ITRE”) and will contribute to a report on a European Strategy for Critical Raw Materials (see here).  The draft opinion, presented by Rapporteur MEP Sara Matthieu (Greens/ALE, BE), highlights the need for conditions regarding the extraction, processing, and use of CRM to be aligned closer with the EU’s sustainability targets.  The language of the proposed amendments aims to balance environmental concerns with industry’s ability to adjust to the new requirements.  It is widely expected to be adopted.  The European Commission brought the issue of CRMs to the forefront last year when it published its “Action Plan on Critical Raw Materials”.  The Action Plan intends to decrease the dependency of Europe’s industry on third-country suppliers, and, instead, develop the circular and sustainable use of resources and diversify mineral sourcing from third countries, thereby ultimately improving supply-chain resilience.  The Commission’s Action Plan can be found here. Continue Reading The Week Ahead in the European Parliament – Friday, June 25, 2021

Three summits last week—G-7, NATO, and U.S.-EU—launched a wide range of transatlantic initiatives to coordinate policy, particularly on trade, technology, and defense. These new formats and dialogues can ensure a much deeper level of regulatory cooperation between the United States and Europe by exchanging perspectives, briefing materials, and in some cases, staff. For companies on both sides of the Atlantic, these emerging policy trends also open up new opportunities to engage decision-makers both in Washington and European capitals. Continue Reading Transatlantic Summits: Main Takeaways for Tech and Defense

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