On September 9, 2026, the U.S. Federal Bureau of Investigation (“FBI”) announced the publication of the FBI Cyber Strategy (the “Strategy”).  The Strategy, which “provides a roadmap for defending the American people and the nation’s critical infrastructure in cyberspace,” is broken into four pillars:

  1. Investigate, Disrupt, and Impose Cost on Cyber Adversaries;
  2. Support Victims;
  3. Increase Impact Through Partnerships; and
  4. Enhance FBI’s Cyber Capabilities.

The Strategy may be of interest to organizations as they develop and assess their own threat monitoring and incident response programs, particularly because of the Strategy’s emphasis on the FBI’s continued cooperation and information sharing with the private sector.  For purposes of this blog post, we have focused on the first three pillars, as the fourth pillar primarily focuses on the FBI’s internal capabilities.

Continue Reading Key Takeaways for Private Sector Entities from the FBI’s New Cyber Strategy

Hot off the press, yesterday evening, 29 September 2026, the German Government’s expert committee presented the eagerly awaited proposal for a new “location clause” (Standortklausel) to incentivize pharmaceutical R&D and manufacturing in Germany. Under this proposal, pharmaceutical companies can apply for a reduction or complete waiver of the just recently enacted 8.5% additional “manufacturer markdown” (Herstellerabschlag). So, what does this newly proposed German location clause mean for pharmaceutical companies?

This blog outlines the proposed location clause and summarizes initial stakeholder reactions. We also discuss whether the proposal would really be an improvement for pharmaceutical companies or rather a bureaucratic worsening compared to the currently applicable exemption.

Continue Reading Germany Reviews a New Pharma “Location Clause” (Standortklausel) for Pricing & Reimbursement Incentives – Improvement or Worsening for the Pharmaceutical Industry?

On 29 September, the European Commission launched a call for feedback on its plans for new trade tools that would strengthen the EU’s trade diversification and economic resilience. The initiative is intended to address situations where a high level of strategic dependence on a single supplier country creates a risk to the EU’s security of supply. The consultation is open until 27 October 2026.

Continue Reading EU Commission launches consultation on new legislative instrument for trade diversification

Driverless and autonomous vehicles (“AVs”) are moving from test tracks and pilot schemes to commercial deployment around the world. In the U.S. and China, robotaxi fleets and autonomous trucking services are proliferating. Similar developments are happening in the EU and UK. In London, the first commercial autonomous ride-hailing service launched in early September 2026, with a supervised fleet carrying paying passengers. In Germany, regulators have granted the first nationwide authorisations for Level 4 urban testing and cab-less Level 4 autonomous trucks. At the international level, UNECE has adopted the first global rules for fully driverless vehicles, as discussed in our earlier blog post here.

As AV technology matures, the regulatory and liability frameworks that will govern it are starting to emerge. This article provides an overview of the key developments that will affect autonomous vehicle manufacturers, and technology companies and mobility-service providers operating in this sector.

Continue Reading Overview of EU and UK Regulatory Developments relating to Autonomous Vehicles

On September 16, 2026, European Commission President von der Leyen opened her annual State of the Union address with the warning that “[a] fight for industrial capacities is shaping global competition“. Her speech indicated how the European Commission intends to respond to concerns about European competitiveness and economic security. Those priorities already appear in reforms and proposals such as the Draft Merger Guidelines and the proposed Industrial Accelerator Act (“Draft IAA”), alongside broader changes to foreign investment screening across the EU. The address therefore offers a useful guide to the considerations likely to shape EU merger control, competition enforcement and Member State investment screening. This post distils the implications for investors and businesses active in the EU.

Key Points

  • Competitiveness, resilience and economic security will shape EU merger control to some degree, as reflected in the Draft Merger Guidelines’ focus on scale, innovation and security of supply, as well as competition enforcement and foreign investment screening.
  • Foreign investment policy will continue to scrutinise strategic sectors and technologies—including AI, semiconductors, critical minerals, energy and defence—while enabling partnerships that build capacity, diversify supply chains and strengthen resilience.
  • Trusted international partnerships will increasingly shape foreign investment assessments, with greater weight on investors’ jurisdictions and strategic alignment with EU industrial policy.
  • Climate change and AI are identified as “tipping points” driving regulatory focus across sectors including energy and water infrastructure, agriculture and food, health, transport, advanced manufacturing, and defence and space.
Continue Reading President von der Leyen’s 2026 State of the Union Address – Decoding the Competition and Foreign Investment Implications

Earlier this month, the House of Representatives adopted resolutions holding two witnesses in contempt of Congress for failing to comply with subpoenas issued by the House Committee on Ethics in connection with the Committee’s investigation of alleged congressional ethics violations by former Representative Sheila Cherfilus-McCormick (D-Fla.).  The House acted unanimously, by a voice vote, after the Committee took the highly unusual step of recommending, in reports released at the end of August, that both witnesses be held in contempt.  The House’s swift adoption of the resolutions is the most recent example of the apparent end of the era in which congressional ethics investigations unfolded quietly and largely out of public view.  This shift presents new risks for private parties potentially swept up in such investigations.

Continue Reading Rare House Contempt Resolutions Signal Heightened Risks for Private Parties

Across three days this month, there were two major events providing meaningful insight into how the European—and potentially the global—space industry is likely to develop in the coming years. On 8 September 2026, the UK Government published its new Space Strategy (the “Strategy”), setting out the UK’s vision to be a competitive space power, backed by GBP 7.8m in funding through to 2030. Over the next two days, on 9-10 September, political leaders, agency chiefs, and industry executives from ninety countries attended the International Space Summit (the “Summit”), to debate key space policy issues, including orbital debris and European launch sovereignty.

The Strategy understandably sets out more detailed policies for the space sector in the UK than the discussions at the Summit, but we expect to see further detail from the EU in due course, particularly as the legislative process around the European Commission’s proposal for a Space Act (which we describe in more detail here) continue. In any event, however, the Strategy and French President Emmanuel Macron’s closing statement at the Summit share key themes. In particular, they both focus on government investment as a driver of the private space industry and the need for a high degree of “sovereignty” for certain space-based activities, i.e., a high degree of domestic control arising from secure space infrastructure and services, and domestic capacity to provide that infrastructure and those services. For more details about the EU’s broader push towards tech sovereignty by advancing these principles, see our prior post here.

Below, we summarize the main points arising from the Strategy and the Summit in more detail, consider further the areas of overlap and divergence, and set out potential next steps for organizations developing and utilizing space services.

Continue Reading Recent Developments in UK and European Space Policy and Industrial Strategy

On September 18, President Trump signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (the “Graham Act” or the “Act”), which passed both the House and Senate with substantial bipartisan majorities. The law is named in honor of the late Senator Lindsey O. Graham (R-SC)…

Continue Reading President Trump Signs Legislation Authorizing Russia-Related Tariffs and Additional Sanctions

Recently, California Governor Gavin Newsom signed a sweeping set of laws related to minors’ privacy and safety, including new laws that restrict covered platforms from providing certain features to users under 16, impose a duty of care on social media platforms, revise the state’s Age-Appropriate Design Code, modify the state’s age-assurance requirements governing age signals, and impose safety requirements on AI chatbots. This blog summarizes the key takeaways from these new laws.

Continue Reading California Enacts Several Minors’ Privacy and Safety Laws

Executive Summary

  • Geopolitical developments are driving significant investment into the defense sectors in Europe. Acquisitions and investments in these sectors are likely to require multiple regulatory approvals across merger control, foreign investment / national security control, and foreign subsidies.
  • Merger control across the EU and UK is becoming more accommodating for defense deals, with the Commission’s new ‘theory of benefit’ framework and the CMA’s efficiencies guidance expressly recognizing defense readiness, innovation, and scale as part of the competitive assessment.
  • Foreign investment screening is moving in the opposite direction — the revised EU FDI Screening Regulation mandates screening in all Member States and even allied-nation investors face increased scrutiny, as recent cases demonstrate.
  • The EU’s Foreign Subsidies Regulation (“FSR”) is a further regulatory process that investors may need to navigate, introducing additional deal timing and execution risks.
  • Successful deal execution requires an integrated regulatory strategy addressing merger control, FDI screening, and the FSR in parallel — each with distinct logic, timelines, and risk profiles that may require extensive commitments to mitigate.
Continue Reading Navigating European Regulatory Regimes for Defense Sector Investments and Deals