02/09/2024

In this edition of Gilbert + Tobin’s Financial Services Regulation Newsletter, we focus on key legal developments over the last fortnight.

Contents

On the pulse

ASIC’s 2024/25 Corporate Plan – see media release.

Report 790 Anti-scam practices of banks outside the four major banks, August 2024 – see media release.

Online investment trading scams top ASIC’s website takedown action – see media release.

APRA finalises new cross-industry Prudential Standard CPS 001 Defined terms – see media release.

APRA releases notes on Life Insurance CEO Roundtable - July 2024 – see media release.

APRA outlines new priorities in 2024-25 Corporate Plan – see media release.

APRA announces internal reorganisation to better support strategic priorities – see media release.

APRA releases enhanced quarterly insurance statistics – see statistics.

AICD: Cyber Security Governance Principles: Review and Refresh – see media release.

AICD: Government retains continuous disclosure reforms for private litigation – see media release.

AICD: New climate target setting guide | Climate Governance Forum – see media release.

Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024 – see media release.

Small and medium-sized banks review – see media release.

Attorney General: Guidance for corporations on preventing foreign bribery – see media release.

G+T Insight - Climate-related financial disclosure: passed by the Senate and one step away from enactment – Ilona Millar and Lily Morton (30 August 2024).

G+T Insight - Australia's whole-of-ecosystem approach to combatting the scourge of scams – Antonia Garling and Silvana Wood (30 August 2024).

G+T Insight - Boardroom Brief Week commencing 26 August 2024 – Justin Mannolini and Cassandra Lee (27 August 2024).

G+T Insight - When humans repeat what AI makes up? – Peter Waters (26 August 2024).

G+T Insight - Boardroom Brief Week commencing 19 August 2024 – Justin Mannolini and Cassandra Lee (20 August 2024).

G+T Insight - White House on Open Source AI: keep your hands off regulators – Peter Waters and Andrew Low (19 August 2024).

G+T Insight - AI and Patents: Key Considerations – John Lee and Chris Williams (19 August 2024).
 

Australian Securities & Investments Commission (ASIC)

ASIC

ASIC’s 2024/25 Corporate Plan

ASIC chair Joe Longo has announced that ASIC’s 2024/25 Corporate Plan includes a new pillar in its strategic priorities that underscored a commitment to strengthening integrity across Australia’s markets, which is aimed at driving consistency and transparency across markets and products.  

As set out in the Corporate Plan, this new strategic priority will involve:

  • Reviewing the growth in private markets: Examine changes in public and private markets, including the significant growth of private markets and the implications for the integrity and efficiency of public markets. The expected timeframe for this activity is 2 years+.
  • Monitoring digital assets, tokenisation and decentralised finance: Create a central coordination function to monitor and engage entities on digital assets, tokenisation and decentralised finance. The expected timeframe for this activity is 2 years+.
  • Reporting on market cleanliness: Enhance monitoring and reporting on our market cleanliness and expand beyond equity markets. ASIC will also review firms’ confidentiality protections.
  • Implementing trade reporting rules: Provide guidance and engage with stakeholders to ensure the smooth implementation of the ASIC Derivative Transaction Rules (Reporting) 2024. The rules will commence in October 2024.
  • Implementing competition in clearing and settlement service rules: Create clearing and settlement service rules to support ASX in fostering competition for clearing and/or settlement. These rules will aim to facilitate outcomes that are consistent with those that are expected in a competitive market for clearing and settlement services.
  • Monitoring financial reporting and audit firms: Carry out a surveillance of financial reports of listed entities, unlisted entities that are of public interest, previously grandfathered large proprietary companies and superannuation funds. ASIC will also conduct a review of audit files and publish our findings. To improve confidence in audit quality, we will also review audit firms’ adherence to ethical and independence standards.

The Corporate Plan also outlines other key priorities for 2024-28, including:

  • Implementing the Financial Accountability Regime (FAR): ASIC will continue to work closely with APRA to implement the FAR by providing guidance, engaging with industry and developing effective registration and other processes.
  • Ensuring the objectives of the reportable situations regime are met: ASIC will continue to: (a) conduct a targeted surveillance of licensees with low numbers of reportable situations and, where appropriate, take enforcement action; and (b) develop a framework for the ongoing publication of the information ASIC receives.
  • Acting against non-lodgement of financial reports: ASIC will take action, including enforcement action, against public companies, large proprietary companies, registrable superannuation entities and Australian financial services licensees who do not comply with obligations to lodge financial reports. 
  • Acting against misconduct that impacts small businesses: ASIC will take enforcement action against financial services participants whose actions impact small businesses, including in relation to unfair contract terms and the promotion and supply of high-risk or unsuitable products. ASIC will also continue to work with the ATO’s Phoenix Taskforce to target illegal phoenix activity and address issues in the small business sector.
  • Contributing to the development of a licensing regime for buy now pay later providers: ASIC will work with Treasury to support the implementation of the regulatory framework for buy now pay later providers. Subject to the passage of legislation, ASIC will consult on regulatory guidance to help providers comply with the new regime. 
  • The Regulatory Initiatives Grid: ASIC will work with the Australian Government to support the introduction of the Regulatory Initiatives Grid (RIG). The RIG will provide industry with information, in a single location and from across multiple agencies, about upcoming reforms and regulatory actions that will materially affect the financial sector.

ASIC Report 790 Anti-scam practices of banks outside the four major banks

In August 2024, ASIC published Report 790 Anti-scam practices of banks outside the four major banks (REP 790). Anti-scam prevention practices include scam prevention, detection and response activities.

In REP 790, ASIC considers the anti-scam practices of 15 Australian banks, outside the major four banks, as at 30 June 2023.

ASIC is encouraging all banks and financial services businesses, regardless of size and scale, to consider the findings of REP 790 and ASIC’s initial report (REP 761). Together, these reports set out a baseline of measures covering scam governance, prevention, detection and response.

Data findings in REP 790 for the 2022-23 financial year:

  • $232 million in total scam transactions made by customers (including those that were subsequently detected and stopped and recovered).
  • 19% of these transactions by value were detected and stopped (excluding other scams that were prevented by the bank prior to the customer performing the transactions).
  • 20% of funds transferred were recovered from the receiving banks/financial institutions.
  • 96% of total scam losses (i.e., total scam transactions less amounts detected and stopped and/or recovered) were born by reviewed bank customers.  
  • 2% of scam losses were reimbursed and/or compensated by the reviewed banks if the customer did not complain, 7% of scam losses were reimbursed/compensated when the customer complained.

ASIC’s key observations:

  • Given the findings in ASIC’s initial report and the national focus on scams, ASIC found the scam detection, prevention and response practices of the reviewed banks to be less mature than expected.
  • Apart from education initiatives, most of the banks had not fully implemented the key scam detection, prevention and response activities that were outlined in REP 761. ASIC summarised its findings in this regard as follows:
    • Governance and reporting tended to be fraud (not scam) focussed.
    • Capabilities to hold or delay potential scam payments were inconsistent across payment channels.
    • Lack of protection against brand misuse across all telecommunication channels. 
    • Poor customer experiences due to lack of resourcing and customer focus.
    • Adoption of inconsistent and narrow approaches when considering liability.

Disrupting investment scams remains a key priority for ASIC. Following REP 790, ASIC will:

  • continue to engage with the four major banks about their anti-scam practices and their development of initiatives to combat scams, as part of ASIC’s ongoing programmatic supervision of these banks;
  • monitor the progress of work by the 15 reviewed banks in response to REP 790 and broader industry activities; and 
  • continue to review the scam prevention, detection and response activities of superannuation trustees.

In this week’s ASIC announcement, Deputy Chair Sarah Court said:

‘Australians are still losing billions of dollars each year to scams. Scammers are criminals targeting the hip pockets of hard-working Australians – they don’t discriminate, and they use sophisticated techniques to steal information and money.

‘The scams landscape is rapidly evolving. Innovative technology developments may improve how we live and work, however they also provide new opportunities for scammers to exploit.

‘Every day an average of 20 investment scam websites are taken down. The quick removal of malicious websites is an important step to stop criminal scammers from causing further harm to Australians.

‘Scammers will continue to adapt and find new ways to lure consumers, and ASIC remains proactive in detecting and disrupting investment scams,’

ASIC works with other government agencies and the industry to coordinate scam disruption strategies including through the National Anti-Scam Centre (NASC). ASIC co-led the first NASC Fusion Cell, focused on combatting investment scams. The NASC’s 2023 targeting scams report reported a drop in overall losses from investment scams from $1.5 billion in 2022 to $1.3 billion in 2023. The downward trend in losses correlates to several key regulator and industry initiatives such as ASIC’s investment scam website takedown capability.

ASIC also publishes investment scam warnings and through its consumer website, Moneysmart. Moneysmart provides detailed information on investment scams and how they work, including impostor bond scams, superannuation scams, and cryptocurrency scams.

Online investment trading scams top ASIC’s website takedown action

As it marks the first-year anniversary of investment scam disruption, ASIC announced on 19 August the takedown of more than 7,300 phishing and investment scam websites that seek to swindle consumers out of their information.  

Since July 2023, ASIC has coordinated the removal of over 5,530 fake investment platform scams, 1,065 phishing scam hyperlinks and 615 cryptocurrency investment scams. 

ASIC Key actions and proceedings

  • ASIC wins case against Kraken crypto exchange operator for design and distribution failure - the Federal Court ruled Bit Trade Pty Ltd, the operator of the Kraken crypto exchange in Australia, failed to comply with design and distribution obligations when offering a margin trading product to Australian customers (see ASIC media release).
  • ASIC continues action on misleading claims to deter greenwashing misconduct - ASIC has made 47 regulatory interventions to address greenwashing misconduct during the 15-month period up to 30 June 2024, including the commencement of two Federal Court proceedings and over $123,000 in infringement notice payments (see ASIC media release).
  • Former BBY employee sentenced for aiding and abetting - Yat Nam (April) Yuen, who held various roles at collapsed stockbroking firm BBY Limited (BBY) including Manager (Strategy), has been sentenced for aiding and abetting BBY to engage in dishonest conduct (see ASIC media release).
  • ASIC cancels licence of Libertas Financial Planning - ASIC has cancelled the Australian financial services licence of former national financial advisory business Libertas Financial Planning Pty Ltd (in liquidation) (see ASIC media release).
  • ASIC prosecutes 78 individuals for failing to assist registered liquidators - ASIC has prosecuted 78 individuals for failing to assist registered liquidators over the six months from 1 January to 30 June 2024 (see ASIC media release). 
  • AFS licensee to cease providing independent expert reports on corporate transactions - ASIC has accepted a voluntary variation of the Australian financial services licence of AP Lloyds Pty Ltd, excluding the firm and its corporate authorised representative, Advisory Partner Connect Pty Ltd, from providing advice as an independent expert (see ASIC media release).
  • Former Brisbane financial adviser Ben Jayaweera sentenced to 12 years imprisonment for fraud at retrial - Ben Jayaweera, a former financial adviser and director of Growth Plus Financial Group Pty Ltd (in Liquidation), has been sentenced to 12 years’ imprisonment following a hearing in the Brisbane District Court on 26 August 2024 (see ASIC media release). 
  • CLSA pays penalty for providing incorrect regulatory data - CLSA Australia Pty Limited (CLSA) has paid a penalty of $144,300 to comply with an infringement notice given by the Markets Disciplinary Panel (MDP) for failing to provide correct regulatory data to the relevant Market Operator. The MDP also had reasonable grounds to believe that CLSA failed to give post trade confirmations to its clients and immediately report off-market transactions (see ASIC media release).
     

Australian Prudential Regulation Authority (APRA)

APRA finalises new cross-industry Prudential Standard CPS 001 Defined terms

APRA has finalised the new cross-industry Prudential Standard CPS 001 Defined terms (CPS 001). The new standard consolidates all existing standards on definitions for authorised deposit-taking institutions and general, life and private health insurers.

In a letter released on 22 August 2024, APRA sets out its response to submissions to the November 2023 consultation on CPS 001 and issues the final revised CPS 001. The final CPS 001 will be effective from 1 October 2024.

APRA releases notes on Life Insurance CEO Roundtable - July 2024

APRA has published the public notes from the life insurance CEO roundtable held on Wednesday, 17 July 2024.

The roundtable was hosted by APRA Member Suzanne Smith together with Executive Director Sean Carmody and General Manager Nancy Ma. It was attended by 21 life insurance CEOs and other executives, as well as representatives from Treasury, ASIC and the Council of Australian Life Insurers.

APRA outlines new priorities in 2024-25 Corporate Plan

On 28 August 2024, APRA published its latest Corporate Plan outlining how it will maintain the strength and stability of Australia’s banks, insurers and superannuation trustees over the next four years. 

In addition to APRA’s strategic priorities, this latest Corporate Plan incorporates – for the first time – APRA’s annual policy and supervision priorities and data priorities.  

By combining the formerly separate publications, APRA seeks to enhance transparency and assist regulated entities to plan ahead.  

APRA’s top priorities in the 2024-25 Corporate Plan include: 

  • Further strengthening bank capital and liquidity standards to reflect lessons learned from last year’s global banking turmoil.
  • Increasing minimum standards for operational resilience through the implementation of new Prudential Standard CPS 230 Operational Risk.
  • Raising industry standards on cyber risk management.
  • Developing APRA’s first system stress test to model and assess interconnections across the financial system. 
  • Lifting expectations of entities to consider the financial impacts of climate risk in decision-making.
  • Partnering with stakeholders to reduce the protection gap for household insurance. 
  • Working with ASIC to ensure superannuation trustees meet their requirements under the retirement income covenant.

Internally, APRA will continue to invest in its people to ensure they retain the necessary skills and experience in an increasingly complex and rapidly evolving operating environment. This includes using the additional funding in the 2024-25 Federal Budget to strengthen APRA’s data collection and analysis capabilities. 

APRA Chair John Lonsdale said the plan is aimed at ensuring the continued financial and operational resilience of APRA-regulated entities, while also responding to new and heightened risks. Key focuses include:

  • Data and resilience: APRA will invest in enhancing its data collection and analysis capabilities to strengthen operational and cyber resilience.
  • Risk management: APRA will explore the links between banking and superannuation to address potential contagion risks.
  • Governance reform: APRA will update its prudential standards on governance over the next 12 months.
  • Supervision priorities: APRA will focus on risk culture, climate change, and crisis preparedness, while maintaining a strong stance on enforcement. 

APRA announces internal reorganisation to better support strategic priorities

On 28 August 2024, APRA announced some changes to its internal structure designed to ensure it remains equipped to deal with emerging and future challenges. 

The changes will support APRA’s updated strategic priorities, as also announced on 28 August in the 2024-25 Corporate Plan. 

The most significant change will see APRA move to having its five industry supervision groups being managed in two supervision divisions instead of the current three frontline supervision divisions – Banking, Superannuation and Insurance (encompassing general, life and private health insurance). 

From 2 September 2024, the two frontline supervision divisions will be: 

  • a General Insurance and Banking division; and  
  • a Life Insurance, Private Health Insurance and Superannuation division. 

In addition, APRA will bring together its existing financial and non-financial risk teams in a Cross-industry Risk division, alongside teams focused on systemic risk work. These moves will create a centre of excellence for risk specialists, improving knowledge transfer and cross-skilling opportunities, and ensuring APRA takes a cross-industry and system-wide view of risks. 

APRA’s three other divisions (i.e., Policy and Advice, Technology and Data and Chief of Staff and Enterprise Services) remain broadly unchanged. 

While the consolidation streamlines the executive team, the frontline supervisory teams focused on each industry and engaging with regulated entities remain unchanged. APRA’s Board Members also remain unchanged.  

The Executive Directors confirmed to lead APRA’s divisions include: 

  • Jane Magill, Executive Director: General Insurance and Banking 
  • Carmen Beverley-Smith, Executive Director: Life Insurance, Private Health Insurance and Superannuation 
  • Chris Gower, Executive Director: Cross-industry Risk 
  • Sean Carmody, Executive Director: Policy and Advice 
  • Bruce Young, Executive Director: Technology and Data 
  • Clare Gibney, Executive Director: Chief of Staff and Enterprise Services 

APRA Chair John Lonsdale said the changes would streamline and simplify APRA’s decision-making processes at a time of heightened financial risk globally.  

APRA Key actions and proceedings

  • BUSSQ seeks judicial review of APRA decision to impose licence conditions - APRA notes the application of BUSS (Queensland) Pty Ltd to the Federal Court of Australia in NSW regarding APRA’s decision to impose additional licence conditions on the trustee, which APRA announced on 14 August 2024.  APRA intends to contest the application. APRA has agreed to suspend the effect of the licence conditions until the court’s determination of this matter, on the basis that BUSSQ has requested an expedited hearing (see APRA media release). 
  • APRA increases ANZ’s capital add-on to $750 million over non-financial risk management concerns - APRA has increased the capital add-on applied to Australia and New Zealand Banking Group to $750 million in response to heightened concerns about the bank’s non-financial risk management practices (see APRA media release). 

Other bodies and regulators

AICD: Cyber Security Governance Principles: Review and Refresh

The AICD and Cyber Security Cooperative Research Centre (CSCRC) have commenced a review of the Cyber Security Governance Principles first published in 2022. The review will update the Principles to ensure that they remain the key source of governance guidance on cyber security in Australia and reflect a dynamic threat and regulatory landscape.

The AICD and CSCRC published the Cyber Security Governance Principles (the Principles) in October 2022 soon after significant cyber incidents at Optus and Medibank. Those incidents were a watershed moment in how Australian businesses and boards oversee cyber security risk. The Principles have been the AICD’s most downloaded resource and have assisted boards of all sizes and types of organisations to grapple with cyber security risk. They have also been recognised by the UK Government as an important source of guidance, following earlier endorsement from the then Minister for Home Affairs and Cyber Security, Clare O’Neil MP.

Since publication, the cyber threat landscape has continued to evolve with ever more sophisticated cyber criminals, greater reliance on digital technologies and the rapid uptake of emerging technologies, notably artificial intelligence. Separately, significant cyber security and privacy reform is on the horizon, which will dramatically change the regulatory frameworks relevant to how boards oversee cyber security risk and data governance. The update to the Principles will seek to reflect these changes.

AICD: Government retains continuous disclosure reforms for private litigation

The Australian Government has accepted recommendations of an independent statutory review to retain a fault element for establishing breaches of Australia’s continuous disclosure laws in private litigation, a decision strongly supported by the AICD. The fault element will be removed for the purposes of ASIC public enforcement. The authors from the AICD take a look at what directors need to know.

See AICD media release.

AICD: New climate target setting guide | Climate Governance Forum 

AICD announced that it would release in August 2024 a new guide for Australian boards: Principles for setting climate targets. With mandatory climate reporting on the horizon, Australian organisations must be prepared to disclose key details of their targets. The new resource provides 10 guiding principles to support boards in establishing climate targets and managing associated risks.

Corporate cases

No corporate cases to report on this week.

Legislation and proposed legislation

Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024

The second and third readings of the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024 (the Bill) were agreed to by the Senate on 22 August 2024.

The Bill:

  • Introduces a crisis management and resolution regime.
  • Enhances ASIC and the Reserve Bank of Australia’s (RBA’s) licencing, statutory and enforcement powers.
  • Streamlines and adjusts roles and responsibilities between the Minister, ASIC and the RBA.
  • Will require large entities that lodge annual reports under Chapter 2M the Corporations Act 2001 (Corporations Act) to make disclosures related to climate risks and opportunities (discussed below).

New mandatory climate reporting regime in Australia

Schedule 4 to the Bill generally requires entities that lodge financial reports under Chapter 2M of the Corporations Act and meet certain minimum size thresholds, or have emissions reporting obligations under the National Greenhouse and Energy Reporting (NGER) scheme, to make disclosures relating to climate in accordance with relevant sustainability standards made by the Australian Accounting Standards Board (AASB).

Reporting entities will be mandated to provide a “sustainability report” adding to their existing requirements to produce annual financial reports as outlined in Chapter 2M of the Corporations Act.

The Explanatory Memorandum to the Bill relevantly explains that the sustainability report for a financial year consists of:

  • The climate statement for the year
  • Notes to the climate statement
  • Any statements prescribed by the regulations for the year
  • Notes to those prescribed statements (if any)
  • The directors’ declaration about the compliance of the statements and notes with the relevant sustainability standards.

The new requirements generally apply to reporting entities from financial years starting on or after 1 January 2025. These new obligations will generally be phased over 4 years through transitional provisions, with the exact time frame depending on the size and type of the reporting entity.

ASIC’s existing powers, under sections 340 to 342 to relieve entities (or a specified class of entities) from complying with requirements of Parts 2M.2, 2M.3 and 2M.4 (other than Division 4) of the Corporations Act, will extend to the new sustainability reporting requirements including, but not limited to, the requirement to prepare a sustainability report, lodge the report within a certain timeframe and include certain information in the report.

For further information refer see: 

  • ASIC Chair Joe Longo’s, keynote speech at the at the Deakin Law School International Sustainability Reporting Forum (22 April 2024); and
  • AICD media release titled ‘Climate reporting legislation passes Senate - reporting to commence from 1 January 2025’ (22 August 2024). 

Small and medium-sized banks review

On 8 July 2024, the Treasurer asked the Council of Financial Regulators (CFR) in consultation with the Australian Competition and Consumer Commission (ACCC), to conduct a review of the small and medium-sized banking sectors (the Review).  

The terms of reference for the Review are to examine:

  • The role and state of small and medium-sized banking sectors in providing competition.
  • The regulatory and market trends affecting their competitiveness.
  • The current and potential future sources of and barriers to competition from these sectors.

As part of the Review, the CFR and ACCC will:

  • Run consultations with targeted stakeholders
  • Publish a consultation paper.

The CFR will provide a final report to the government by 1 July 2025.

For further details, see the Treasury Review website and the Treasurer’s initial media release (dated 15 June).

Attorney General: Guidance for corporations on preventing foreign bribery

The Australian Government has released a new guidance (the Guidance) to assist corporations to implement effective anti-bribery compliance programs.

The passage of the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 earlier this year significantly strengthened Australia’s criminal offences on foreign bribery.

Under the new laws, corporations will now be held directly liable for the foreign bribery activities of their employees, external contractors, agents and subsidiaries, unless the company can demonstrate it had adequate procedures in place to prevent bribery.

The Guidance on adequate procedures to prevent the commission of foreign bribery is principles-based, rather than a checklist, and is designed to be used by corporations of all sizes and in all sectors.

The Guidance reflects current international best practice and incorporates feedback received by the Attorney-General’s Department in the recent public consultation process.

The contribution and engagement of industry partners was vital in the development of the Guidance to ensure that it is robust, fit-for-purpose and practical, thereby reducing the burden on corporations as they develop their anti-bribery and corruption compliance frameworks.

G+T articles

G+T Insight - Climate-related financial disclosure: passed by the Senate and one step away from enactment – sets out the amendments made by the Senate and provides a comprehensive overview of the key elements of the Bill as passed by the Senate while also sets out other related developments in Australia and internationally, and what businesses can start doing to prepare for developing reporting requirements - Ilona Millar and Lily Morton (30 August 2024).

G+T Insight - Australia's whole-of-ecosystem approach to combatting the scourge of scams – outlines the ‘ecosystem approach’ and discusses the developing legal and regulatory issues and requirements for banks and payments businesses - Antonia Garling, Silvana Wood, Chris Whittaker and Madeleine Butler (30 August 2024).

G+T Insight - Boardroom Brief Week commencing 26 August 2024 – Justin Mannolini and Cassandra Lee (27 August 2024).

G+T Insight - When humans repeat what AI makes up? – discusses the risks of relying on AI-generated content that may be inaccurate or speculative, termed "botshit," and emphasises the importance of managing and verifying AI outputs, as users are often misled by the human-like trustworthiness of AI responses – Peter Waters (26 August 2024).

G+T Insight - Boardroom Brief Week commencing 19 August 2024 – Justin Mannolini and Cassandra Lee (20 August 2024).

G+T Insight - White House on Open Source AI: keep your hands off regulators – discusses the US National Telecommunications and Information Administration’s cautious yet optimistic view on open-source AI, highlighting its potential to foster innovation and disrupt monopolistic AI markets while weighing the associated risks, particularly regarding public safety, competition, and global security – Peter Waters and Andrew Low (19 August 2024).

G+T Insight - AI and Patents: Key Considerations – discusses key issues and best practices regarding patents and AI-related technology, including recent AI patenting trends in Australia; key issues and best practices concerning AI-related technology and patents in Australia, including patent-eligible subject matter; sufficiency, enablement, best method, claim clarity, and support; AI inventorship; novelty and inventive step; and potential infringement issues – John Lee and Chris Williams (19 August 2024).

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