Allen & Overy Launch: The Careers Podcast

Welcome to episode #3 of the A&O Career Insights podcast. This podcast series aims to shine a light on individuals in the firm, to explore how they navigated their careers to become more senior and successful. Our host, Danielle Viner, a training events coordinator in London, will be interviewing a different guest in each episode to help inspire people to shape their own careers, In this episode, Danielle meets with Jantien van Renterghem, a financial crime and sanctions lawyer in the BAU. In this episode, Jantien shares invaluable insights into the role of the BAU, outlining how she ensures that accepted business aligns with the firm's commercial objectives and legal obligations. We also delve into the effects of global conflicts on new business, including the recent Russian invasion of Ukraine.

In this final episode of Voices for Change season one, Justin Farrance is joined by Hilde van der Baan, A&O's Social Impact Group partner and Sara Bowcutt, Managing Director of Women for Women International UK.  Hilde and Sara share their thoughts on the importance of engaging with men on global issues impacting women, how everyone has the power to make a change, plus lessons from our impactful partnership with Women for Women International.  Voices for Change was a project built to create a community of diverse thinkers and doers, and we hope each episode raised awareness of key stories and lessons. As Sara puts it, ‘don't underestimate the impact your passion can have on other people'. 

La Legge sulla Competitività dei Capitali vuole favorire la raccolta dei capitali sul mercato, sia incentivando la quotazione di nuove società sia semplificando le regole applicabili alle società già quotate. Alessandra Pala, counsel del dipartimento International Capital Markets, e Marco Biallo, senior associate del dipartimento Corporate, parlano dei cambiamenti più rilevanti per le società, dalla corporate governance e lo svolgimento dell'assemblea delle società quotate, al voto plurimo e maggiorato, fino alle misure adottate in tema di piccole e medie imprese.

In this episode, we continue our discussion with Dr. Sandie Okoro OBE, Group General Counsel at Standard Chartered Bank joins Justin Farrance. Sandie was told at the age of eight that ‘little black girls like you don't become judges'.  Having ignored the naysayers and risen to be listed by Powerlist as one of the most influential people of African and African Caribbean heritage in the U.K., Sandie shares her story, meaningful advice to those who feel pressured to conform within their careers, and some of her decisions along the way, including why her ‘Women in Law' portrait is captioned, ‘this is what a single mother from Balham looks like'.

In this episode, we continue our discussion with Dr. Sandie Okoro OBE, Group General Counsel at Standard Chartered Bank joins Justin Farrance. Sandie was told at the age of eight that ‘little black girls like you don't become judges'.  Having ignored the naysayers and risen to be listed by Powerlist as one of the most influential people of African and African Caribbean heritage in the U.K., Sandie shares her story, meaningful advice to those who feel pressured to conform within their careers, and some of her decisions along the way, including why her ‘Women in Law' portrait is captioned, ‘this is what a single mother from Balham looks like'.

In this episode, Dr. Sandie Okoro OBE, Group General Counsel at Standard Chartered Bank joins Justin Farrance. Sandie was told at the age of eight that ‘little black girls like you don't become judges'.  Having ignored the naysayers and risen to be listed by Powerlist as one of the most influential people of African and African Caribbean heritage in the U.K., Sandie shares her story, meaningful advice to those who feel pressured to conform within their careers, and some of her decisions along the way, including why her ‘Women in Law' portrait is captioned, ‘this is what a single mother from Balham looks like'.

In this episode, Dr. Sandie Okoro OBE, Group General Counsel at Standard Chartered Bank joins Justin Farrance. Sandie was told at the age of eight that ‘little black girls' like you don't become judges.  Having ignored the naysayers and risen to be listed by Powerlist as one of the most influential people of African and African Caribbean heritage in the U.K., Sandie shares her story, meaningful advice to those who feel pressured to conform within their careers, and some of her decisions along the way, including why her ‘Women in Law' portrait is captioned, ‘this is what a single mother from Balham looks like'. 

Cristiano Tommasi, Alessandra Pala ed Emiliano La Sala del dipartimento International Capital Markets di Allen & Overy in Italia, fanno il punto sui principali cambiamenti che porta il DDL Capitali, una legge che si pone come obiettivo la crescita del mercato dei capitali italiano.

In this podcast, our tax experts look into the implications of Pillar Two, the OECD/G20's initiative to introduce a global minimum tax, for structured finance transactions. Tax partners Chris Harrison, Esther Lemmon and Charles Yorke speak to tax knowledge counsel Brin Rajathurai about various topics including: A recap of the global minimum tax – what is Pillar Two and how does it work? The tax consequences of the new rules in the context of structured finance transactions and the potential commercial repercussions The significance of consolidation for Pillar Two purposes and unexpected grouping of orphan vehicles How the UK and other jurisdictions are addressing some of the potential issues for structured finance transactions

Livio Bossotto e Giorgia Giorgetti, rispettivamente partner e counsel del dipartimento Employment di Allen & Overy in Italia, parlano del recente provvedimento con cui il Garante della Privacy ha chiarito i limiti per il trattamento dei metadati contenuti nella posta elettronica dei dipendenti da parte del datore di lavoro e della portata di tale provvedimento per le aziende.

In this podcast, Godwin Tan and Vicky Chen from A&O's Society of East Asian Lawyers (SEAL) chat with Grace Wang and Miao Wang, two recently promoted A&O partners based in New York and Luxembourg respectively. Grace and Miao discuss their career journeys, the challenges and opportunities they faced as lawyers of East Asian ethnicity, and their advice for junior lawyers. Tune in to hear about the experiences and achievements of two East Asian lawyers across three continents!

In this podcast, members from our global ESG and sustainability team discuss what lies ahead on the sustainability agenda and the key regulatory developments to watch in 2024.  The main themes include: Political and economic drivers of market activity and regulation, including the implications of 2024's “year of elections” and of the commitments made at COP28 [01:23]; Sustainability data and reporting – key trends in the global sustainability reporting landscape [17:26], and three significant challenges for business, namely: scope 3 GHG emissions, transition plans, and nature [26:17]. Supply chains – significant regulatory initiatives focusing on adverse impacts on human rights and the environment [31:56], deforestation [40:09], and critical minerals for the net zero transition [35:08]. Carbon pricing, carbon trading and related measures, including carbon border adjustment mechanisms [44:05], voluntary carbon markets and Article 6 of the Paris Agreement [47:47]. Closing thoughts [50:26], including on ESG litigation, greenwashing claims and enforcement, the weaponisation of ESG, PFAS regulatory enforcement and litigation, and the interplay between taxonomies, reporting frameworks and transition plans. This podcast was recorded on 31 January 2024. 

In this episode, Johanna Tschurtschenthaler (Counsel, Tax), Stephanie Yiolitou (Senior Associate, Tax) and Chiara Wolf (Junior Associate, Tax) uncover the impact of ATAD 2's reverse hybrid mismatch rule on Luxembourg fund structures and dive deep into the implications of this rule for Luxembourg fund entities. They share best practices related to tax structuring and risk management for Luxembourg funds and give an update on the latest guidance from tax authorities regarding the respective tax forms. An episode full of practical examples and answers to the market's most common questions!

In this episode, Johanna Tschurtschenthaler (Counsel, Tax), Stephanie Yiolitou (Senior Associate, Tax) and Chiara Wolf (Junior Associate, Tax) uncover the impact of ATAD 2's reverse hybrid mismatch rule on Luxembourg fund structures and dive deep into the implications of this rule for Luxembourg fund entities. They share best practices related to tax structuring and risk management for Luxembourg funds and give an update on the latest guidance from tax authorities regarding the respective tax forms. An episode full of practical examples and answers to the market's most common questions!  

Join Allen & Overy U.S M&A partner Dario de Martino, Senior Counsel Kuang Chiang, Associate Puja Patel and Associate Mara Goodman, and as they analyze key tech M&A and regulatory trends of 2023 and discuss predictions for 2024. The panel discusses the downturn in tech M&A during 2023, attributing it to macroeconomic factors, including geopolitical conflicts and heightened regulatory scrutiny. A key issue highlighted is the valuation discrepancies between buyers and sellers in 2023, often bridged by earnouts. Mara Goodman delves into the increased adoption of earnouts in tech and life sciences M&A. These arrangements, generally pegged to financial metrics like revenue, earnings or EBITDA targets, have been pivotal in reconciling differing valuation expectations. However, Dario de Martino and Mara Goodman caution that one of the issues in the use of earnout provisions is the complexity of these provisions. If not drafted simply, with clear language and objective criteria, they can lead to post-transaction disputes that are costly and time consuming. They further discuss the use of arbitration clauses for dispute resolution in the event of a post-transaction dispute. The conversation also highlights the vital role of tech M&A in corporate growth strategies, emphasizing drivers such as AI (including AI-enabled enterprise software), cybersecurity and Web3, which are poised to propel future M&A activities in 2024. The team also discusses the aggressive antitrust merger enforcement regime seen in the U.S. in 2023 and how it has affected dealmakings. Anti-trust specialist Puja Patel examines expected developments in 2024, including the release of new FTC/DOJ Merger Guidelines and the proposed changes to the HSR Act notification form, and discusses how these changes will influence dealmaking. Lastly, the team discusses the outlook for cross-border tech M&A deals in 2024 and evaluates how the recent increase in scrutiny of inbound investments for national security issues may impact tech transactions. CFIUS specialist Kuang Chiang analyzes how the current regulatory regime, including mandatory filing requirements, the increase in foreign direct investment regimes, and new regulation on outbound investments, impacts dealmakers. 

In this episode, we continue our discussion with Tuvia Borok, Goldman Sachs' Managing Director and Global Head of Policy and Document who shares his career journey and insights, as well as the importance of inclusive leadership and theories including stereotype threat.

In this episode, we continue our discussion with Tuvia Borok, Goldman Sachs' Managing Director and Global Head of Policy and Document who shares his career journey and insights, as well as the importance of inclusive leadership and theories including stereotype threat.

In this podcast Emma Danforth, Vittoria Faraone and Joseph Ray discuss some of the key European and UK regulatory changes on the horizon which asset managers and funds should have on their radar as we move towards 2024, including the hot topics of ESG, AIFMD II and retailisation of funds. This podcast forms part of the Great Fund Insights series, a global resource providing practical insights into legal and regulatory developments affecting fund managers and institutional investors across Europe, Asia, Africa, the Middle East and the U.S.

In this episode, Tuvia Borok, Goldman Sachs' Managing Director and Global Head of Policy and Document joins Justin Farrance to share his career journey and insights, as well as the importance of inclusive leadership and theories including stereotype threat. Part 1 of the discussion is available to watch now, with part 2 being released on Monday 15th January.

In this episode, Tuvia Borok, Goldman Sachs' Managing Director and Global Head of Policy and Document joins Justin Farrance to share his career journey and insights, as well as the importance of inclusive leadership and theories including stereotype threat. Part 1 of the discussion is available to watch now, with part 2 being released on Monday 15th January.

Todd Fishman and Gene Ingoglia are back with the first episode of Deconstructing Crypto in 2024.  In this new episode, Todd and Gene review the rapid transformation of financial markets in 2023 and the opportunities and challenges driven by two interrelated forces: the gamification of trading and the rise of artificial intelligence. Gamification influences the behavior and preferences of retail investors, who have flocked to online platforms that offer low-cost, easy-to-use, and fun-to-play features. Social media has amplified the gamification effect by creating online communities where investors can share information about stocks, cryptocurrencies, or other assets, and coordinate collective actions to influence market prices and volumes. Social media driven trading, now in combination with artificial intelligence applications, has caused significant market volatility and regulatory scrutiny. Risks include increased market instability and contagion; distorted price discovery and valuation; facilitated market manipulation and fraud; exposed investors to excessive risk and losses; and challenged existing regulatory frameworks and oversight capacities. Citing those risks, in December 2023, the US Financial Stability Oversight Council in its annual report identified artificial intelligence as an emerging vulnerability to financial institutions. Todd and Gene explore the role of social media in creating and amplifying market volatility and discuss the implication of AI for market efficiency, integrity and competition.

The rise of generative AI presents vast opportunities for advertising. What IP issues do advertisers need to be aware of when using synthetic media? In this podcast Clemency Wells, AI Communications Lead, asks Beverley Potts, Senior IP Knowledge Lawyer and Rob Dickens, IP Associate, to explain the opportunities and issues posed by synthetic media and practical steps that advertisers can take to mitigate against risks. 

Partner Dr. Josef Parzinger spricht im Spotlight Podcast über seinen Weg ins Insolvenz- und Restrukturierungsrecht, Praxisbeispiele und den Partner-Prozess.

Partnerin Dr. Heike Weber spricht im Spotlight Podcast über interne und externe Mandanten, die Rolle des Steuerrechtlers im M&A-Deal und über Teamwork.

Partnerin Denise Benz und Partner Dr. Jan Ebersohl sprechen im Spotlight Podcast über die Zusammenarbeit mit Mandanten, Smartphones in den 2010er Jahren und das Besondere am Patentrecht.

Die Partner Max Landshut und Dr. Jonas Wittgens sprechen im Spotlight Podcast über Standortunabhängiges Selbstverständnis, feindliche Übernahmen und die Dynamik in der M&A-Arbeit.

UK tax incentives for sustainable investments is the first in a series of podcasts from the Allen & Overy tax team, exploring how tax incentives are used to incentivise sustainable behaviour. Each podcast in the series will focus on a different jurisdiction, with this initial podcast looking at the latest position in the United Kingdom.   Governments worldwide are facing increasing pressure to develop policies that aid the transition to net zero and support social change. The introduction of the Inflation Reduction Act in the US, which introduced substantial tax credits has been grabbing headlines, but what are other jurisdictions doing in this space?   This podcast featuring members of our UK tax team is moderated by senior associate Gordon Hopkinson (London), this podcast features partner Charles Yorke (London), knowledge counsel Naomi Lawton (London), and associate Sadia Khan (London).   The team discuss the following topics: Is full expensing, as announced in the latest Autumn Statement, the UK's answer to the US Inflation Reduction Act tax incentives? What has the UK been doing to incentivise environmentally friendly behaviours both in terms of direct and indirect taxes? What is on the horizon in terms of environmental incentives? What impact could government initiatives such as freeports and investment zones have in this area? How is the UK encouraging social impact investing?

In this episode of our Market Horizons podcast series, partner Amanda Thomas (London) and counsel Jennifer Cresswell (London) from our International Capital Markets practice return to the topic of the divergence ahead in the prospectus space from a debt security perspective. Together they aim to identify possible areas of divergence from an EU and UK perspective as both prospectus regimes continue along their paths of review and reform.  

Pol Theisen (Counsel, M&A et Real Estate) et Philippe Eicher (Senior Associate, M&A et Real Estate) lancent une nouvelle série de podcast autour du marché immobilier au Luxembourg. Dans le premier épisode de cette série, ils discutent de l'état actuel du marché immobilier qui fait face à une situation difficile ainsi que des différentes mesures proposées par le nouveau gouvernement afin de redynamiser le secteur.

Livio Bossotto, partner Employment di Allen & Overy in Italia, Veronica Rossetti, senior associate del dipartimento di Litigation, ed Emilio de Giorgi, partner Antitrust, fanno il punto sugli adempimenti previsti dal decreto legislativo 24/2023 e lo stato di applicazione delle nuove norme evidenziandone alcuni nodi operativi.

In episode 8 of Deconstructing Crypto, Todd Fishman and Gene Ingoglia break down the trial of FTZ founder Sam Bankman-Fried, in which a federal jury found him guilty of seven counts of fraud.  This is the most high profile case in the crypto space, and has sent shockwaves through the market. Todd and Gene explain the charges filed against Sam Bankman-Fried, the facts of the trial and the important implications for the rest of the cryptocurrency market.  They also look at the increasing pressure on the crypto market from US lawmakers, including the recent guilty plea from former Binance CEO regarding violations of U.S. anti-money-laundering requirements under the Bank Secrecy Act, and the criminal charges brought against Binance.

The Electronic Trade Documents Act 2023 has the potential to transform trade finance by permitting market participants to ditch paper documentation and move to digital. Last week's episode explored the background, rationale and implications of the Act. This time, our panel turns their attention to practical aspects of complying with the new law and next steps for digitalisation of world trade.  Hosted by Catherine Lang-Anderson, a partner at Allen & Overy, the podcast brings together a panel of experts from the Law Commission, Lloyds Bank and current Fuse cohort member, Enigio, a tech company offering digital solutions for trade finance. Professor Sarah Green, the Law Commissioner for Commercial and Common Law at the Law Commission of England and Wales, has been instrumental in the legal developments around the digitalisation of trade. She is joined by Rogier Van Lammeren, Managing Director, Head of Trade and & Working Capital Products at Lloyds Bank, and Alex Waites, Executive Director at Enigio. In this second episode, the panel considers the impact of the legislation in the UK and beyond, discussing the economic and efficiency gains as well as the ripple effect it has on international developments around the world. They emphasise the need for industry-wide collaboration and cooperation to implement the shift to digital trade documents, aided by legal consistency and system interoperability across jurisdictions.

COP 28 is a significant milestone. Not only will the conference hear the findings of the first-ever Global Stocktake, which reviews progress against the goals of the Paris Agreement, but extensive discussions are expected around the future of fossil fuels and the significant scale-up of renewables. Financing will remain a central theme, notably the loss and damage fund and new carbon trading mechanisms.  To set the scene, a panel of experts from across the Allen & Overy network share their insights on the key issues to watch at COP 28. This podcast was recorded on 27 November 2023. 

The Electronic Trade Documents Act 2023 has the potential to transform trade finance by solving a piece of the puzzle that will permit market participants to ditch paper trade documentation and move to digital. It is still early days for this legislation, and making the most of the opportunity it provides will require collaboration across all players in the industry. Catherine Lang-Anderson, a partner at Allen & Overy, hosts a panel of experts from the Law Commission, Lloyds Bank and current Fuse cohort member, Enigio, a tech company offering digital solutions for trade finance. Professor Sarah Green, the Law Commissioner for Commercial and Common Law at the Law Commission of England and Wales, has been instrumental in the legal developments around the digitalisation of trade. Joined by Rogier Van Lammeren, Managing Director, Head of Trade & Working Capital Products at Lloyds Bank, and Alex Waites, Executive Director at Enigio, together they discuss the background, rationale and implications of the Act, which gives digital documents the same legal recognition under English law as paper documents. They also explore the concepts of electronic trade documents and reliable systems under the Act, and how the Act will benefit businesses, especially SMEs, by reducing costs, risks and inefficiencies in trade transactions. This is part one of a two-part series, so stay tuned for the next episode, where the panel will delve into more practical aspects of complying with the new law and what's next for the industry. 

Jason Denisenko, Christopher Scarf and Vivien Liu from our regulatory team in Sydney summarise the latest developments in the saga that is Australia's financial services licensing regime. They briefly discuss the new proposed forms of relief and exemptions available to foreign financial services providers, how they will be applicable and some of the key points that foreign entities may want to consider when applying or transitioning from existing arrangements. Update: As of 1 December, a bill including the proposed changes discussed in this podcast was introduced to Parliament. Following several years of consultations, this is a significant step for the foreign financial services licensing regime.  We will continue to monitor the progress of this bill.

Join Justin Farrance, A&O's DE&I Ambassador, as he interviews colleagues from across A&O, as well as clients and alumni about their personal stories, commitment on DE&I and advice for others to learn from. In this episode, partner, Will Samengo–Turner and guest Precious Oyelade talk to Justin about their journey and in particular, the firm's collaboration with Google as part of the Black Founders Fund. This works to address the funding gap and systemic barriers that Black entrepreneurs face in accessing capital, networks and resources. The podcast flags some of the stats, such as, prior to the fund's launch in 2021, only 0.25% of venture capital funding went to Black founders.

Join Justin Farrance, A&O's DE&I Ambassador, as he interviews colleagues from across A&O, as well as clients and alumni about their personal stories, commitment on DE&I and advice for others to learn from. In this episode, partner, Will Samengo–Turner and guest Precious Oyelade talk to Justin about their journey and in particular, the firm's collaboration with Google as part of the Black Founders Fund. This works to address the funding gap and systemic barriers that Black entrepreneurs face in accessing capital, networks and resources. The podcast flags some of the stats, such as, prior to the fund's launch in 2021, only 0.25% of venture capital funding went to Black founders.

In this podcast, our colleagues at A&O Consulting discuss the importance of getting your FAR implementation right, so that your accountable persons are set up for success and your internal processes are designed to be sensible and effective. Some of the key areas that will be crucial for accountable entities to consider during the transition period from BEAR to FAR. They also share key learnings and insights from the UK Senior Manager Certification Regime – the closest proxy for the future direction of our industry.

Tune in to uncover insider tips and embark on a career journey with G&R. Listen to our recruitment team as they answer the frequently asked questions and share valuable insights into our recruitment process.

In this podcast our team of A&O experts bring you up to speed with the key issues company secretaries and their teams need to think about when preparing for their next Annual Report and AGM, and discuss some of the developments on the horizon. Points covered include: AGM share capital authorities - latest guidance and market practice update; executive remuneration - current trends and good practice recommendations; “say on climate”- AGM resolutions and protests; annual reports - new requirements and practice points; UK corporate governance reform - what we're expecting in the future. You can find further information on the support we can provide for Annual Reports and AGMs and details of some value-added services by downloading our brochure.

In the latest episode in our series of podcasts exploring current and emerging developments shaping the future of banking, Sally Dewar, CEO of A&O Consulting, and Clive Garfield, Executive Director of A&O Consulting, join Roger Lui, partner and co-head of the Global Bank Sector team, to discuss the findings of A&O's recent in-depth global research study into organisational culture in financial services. In particular, they look at the role and responsibilities of boards and executive management teams in shaping and driving culture to manage risk, drive performance, and empower employees.

Companion diagnostics are classed in the U.S. and in the EU as medical devices, usually in-vitro medical devices (IVDs). They are a class of products which are rapidly gaining in importance, particularly in treating patients with cancer. About one third of marketing authorisations in the field of oncology in the EU between 2010 and 2020 required a diagnostic test for patient identification. The Global Oncology Companion Diagnostic Market Size was valued at 2.2 billion in 2019.     In this podcast, Sapna Palla, Tine Carmeliet and Rafi Allos discuss the regulation of IVDs in the EU and the U.S. and how they are authorised in these jurisdictions. 

In the final episode of our of the IP arbitration podcast series, Melody Chan and James Fox discuss FRAND disputes – the story so far, why some think arbitration is the only way forward and limitations to its usefulness.

Martina Rossi e Piermaurizio Tafuni intervistano uno dei massimi esperti di mediazione in Italia, Nicola Giudice, Responsabile del servizio di conciliazione della Camera Arbitrale di Milano, per parlare della mediazione, della sua evoluzione dalla sua introduzione nel 2010 ad oggi, con le novità portate dalla Riforma Cartabia, e dei benefici dell'istituto.

In the last couple of years, European co-legislators have worked to design a harmonised and comprehensive regime designed to both incentivise an efficient digital transformation within the Union, as well as to ensure market stability and adequate investors protection in the area of digital assets. In this podcast moderated by Judith Bremer, associate in the financial regulatory team in Frankfurt, Emiliano La Sala, head of domestic capital markets and Fintech group coordinator in Italy, provides an overview on the current situation and the latest regulatory developments in Europe, from the DLT Pilot regime to MiCAR. 

In this podcast, Partners Sigrid Jansen and Nick Charlwood sit down with Associate Ella Richards to discuss the recent landmark Vroon restructuring and their experience of this USD900 million restructuring which involved the first ever parallel use of the new Dutch WHOA and an English scheme of arrangement.

A new video podcast series by Allen & Overy called Voices for Change, for inclusive thinkers and doers.  Join Justin Farrance, A&O's DE&I Ambassador, as he interviews colleagues from across A&O, as well as clients and alumni about their personal stories, commitment on DE&I and advice for others to learn from. Stay up to date with new episodes announced each month. First up, Senior Partner Wim Dejonghe talks to Justin about his early years in law, as well as why “the biggest risk for any successful organisation is to become complacent with DE&I, because the world will catch up with you.”

A new video podcast series by Allen & Overy called Voices for Change, for inclusive thinkers and doers.  Join Justin Farrance, A&O's DE&I Ambassador, as he interviews colleagues from across A&O, as well as clients and alumni about their personal stories, commitment on DE&I and advice for others to learn from. Stay up to date with new episodes announced each month. First up, Senior Partner Wim Dejonghe talks to Justin about his early years in law, as well as why “the biggest risk for any successful organisation is to become complacent with DE&I, because the world will catch up with you.” 

The regulatory frameworks for medicines and medical devices have historically grown up on separate tracks, but increasingly, medicines and medical devices are being used together in patients as drug device combinations, companion diagnostics and medical devices used in clinical trials. Join Sapna Palla, Eda Zhuleku and Rafi Allos in part one of this podcast series to discuss the use of medical devices in clinical trials and the different perspectives between the EU and U.S., as well as the regulatory requirements that may apply.