There was little fanfare when the agreement was reached, however, an understanding between the SEC and UK Information Commissioner's Office has unlocked a solution which enables UK-based financial services firms to share personal data more freely in the context of U.S.-based compliance requirements.
This article on Law360 explains how the U.S. Securities and Exchange Commission worked with the ICO on an approach which will permit UK companies to transfer personal data of UK-based individuals to the SEC to facilitate investigations in the absence of formal legal instruments.
More thoughts on this and analysis between myself and Phil Beckett can be found here.
The U.S. Securities and Exchange Commission recently announced that U.K. authorities will permit U.K.-based companies to transfer personal data of U.K. data subjects to the SEC to facilitate its investigations even in the absence of a subpoena or other legal obligation.
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