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An @HSFlegal briefing on the concerns touched on in @pmdfoster's article is now available online. This is not about denying the reality or seriousness of malign activities by foreign governments 1/herbertsmithfreehills.com/latest-thinkin…
The proposed regime is much wider + more onerous than regimes in Australia + US cited as precedents. Section B of the briefing contains many very surprising examples of the kinds of entities, people and activities that *are* caught and a couple of those that are *not* 2/
As drafted the proposed scheme places public registration requirements, + related obligations on organisations + individuals with criminal sanctions punishable with imprisonment, a fine or both on almost all foreign entities (even if fully UK based and operated) 3/
