---
name: regulatory-checklist
description: >
  Generate transaction-specific regulatory compliance checklists by jurisdiction.
  Use this skill when a user mentions regulatory requirements, cross-border
  transaction, regulatory compliance checklist, multi-jurisdiction, foreign
  investment review, merger clearance, data protection requirements, licensing
  requirements by country, regulatory approval, or compliance requirements for
  a deal. Also trigger when users are doing cross-border M&A, establishing
  operations in a new jurisdiction, or need to understand what regulatory
  approvals are needed for a specific transaction. This is transaction-specific
  — what do you need for THIS deal in THIS geography — not framework-specific.
---

# Multi-Jurisdiction Regulatory Checklist

Generate transaction-specific regulatory compliance checklists based on deal
type, sector, and jurisdiction. Unlike framework-specific compliance skills
(which tell you how to implement ISO 27001 or GDPR in general), this skill
answers: "What regulatory approvals and filings do I need for THIS specific
transaction in THESE specific jurisdictions?"

## When to Use

- You are planning a cross-border acquisition or investment
- You need to know what regulatory approvals are required before closing
- You are establishing a subsidiary or branch in a new jurisdiction
- You need a compliance roadmap for a transaction timeline
- You are advising a client on regulatory risk for a proposed deal

## Input Requirements

Ask the user for:

1. **Transaction type** — acquisition (asset/share), merger, joint venture,
   greenfield establishment, licensing, lending, fund formation
2. **Sector** — financial services, technology, healthcare, energy, defense,
   telecommunications, real estate, infrastructure, media
3. **Jurisdiction(s)** — where the target operates, where the acquirer is based,
   where the transaction closes, where the funds flow
4. **Parties** — nationality/jurisdiction of acquirer and target; state-owned
   enterprise involvement; fund vs. corporate buyer
5. **Transaction value** — affects filing thresholds
6. **Target's characteristics** — revenue, employees, assets, market share,
   data it processes, licenses it holds

## Regulatory Categories

For each jurisdiction involved, check these categories:

### 1. Foreign Investment Review

| Jurisdiction | Regime | Threshold | Timeline |
|-------------|--------|-----------|----------|
| Canada | Investment Canada Act | >C$1.141B (WTO), lower for cultural/SOE | 45 days initial + extensions |
| United States | CFIUS (FIRRMA) | No threshold (voluntary, but recommended) | 45+45+15 days |
| United Kingdom | National Security and Investment Act 2021 | No threshold for 17 sensitive sectors | 30 working days + extensions |
| EU member states | National FDI screening (varies) | Varies by member state | Varies |
| Australia | FATA / FIRB | A$0 for sensitive; A$310M general | 30 days + extensions |
| Singapore | No general FDI screening | Sector-specific (banking, media, telecom) | N/A |
| UAE | Varies by emirate and free zone | Up to 49% foreign ownership limit (mainland), 100% in free zones | Varies |

### 2. Competition / Merger Control

| Jurisdiction | Authority | Filing Threshold | Timeline |
|-------------|----------|-----------------|----------|
| EU | European Commission | Combined worldwide turnover >€5B + EU turnover >€250M each | Phase I: 25 WD; Phase II: 90 WD |
| United States | DOJ / FTC (HSR Act) | Transaction value >$119.5M (2024) | 30 days + second request |
| United Kingdom | CMA | >£70M UK turnover or >25% share of supply | Phase 1: 40 WD |
| Singapore | CCCS | Voluntary (no mandatory filing) | Phase 1: 30 WD |
| Canada | Competition Bureau | Size of parties + size of transaction thresholds | 30 days (short form) |

### 3. Sector-Specific Licensing

Identify sector-specific requirements:

- **Financial services**: Banking license, insurance license, securities license,
  payment institution license, change of control approval
- **Telecommunications**: Spectrum license, carrier license, foreign ownership limits
- **Healthcare**: Operating permits, pharmaceutical licenses, medical device approvals
- **Energy**: Generation license, distribution license, environmental permits
- **Defense / dual-use**: Export control licenses, security clearances
- **Real estate**: Foreign ownership restrictions, land acquisition approvals
- **Media**: Broadcasting licenses, foreign ownership limits

### 4. Data Protection and Privacy

| Jurisdiction | Regime | Key Requirements |
|-------------|--------|-----------------|
| EU/EEA | GDPR | DPIA for high-risk processing; DPO appointment; cross-border transfer mechanisms |
| United Kingdom | UK GDPR + DPA 2018 | Similar to EU; UK-specific adequacy decisions |
| Singapore | PDPA | Consent obligations; DPTM designation; notifiable data breaches |
| Canada | PIPEDA / provincial | Consent; accountability; cross-border transfer |
| UAE | Federal Decree-Law No. 45/2021 | Registration; DPO; cross-border transfer restrictions |

### 5. Employment and Labour

- Transfer of employees (TUPE / equivalent in jurisdiction)
- Works council / union consultation requirements
- Employment permit requirements for foreign employees
- Redundancy / retrenchment rules if restructuring post-acquisition

### 6. Tax and Transfer Pricing

- Withholding tax on purchase price payments
- Stamp duty / transfer tax on share or asset transfers
- Transfer pricing documentation requirements
- Tax clearance certificates
- Substance requirements in holding jurisdictions

### 7. Anti-Corruption and Sanctions

- Parties screened against relevant sanctions lists
- Anti-bribery due diligence on target's operations
- Third-party intermediary risk assessment
- Facilitation payment exposure

## Output Format

```markdown
# Regulatory Compliance Checklist

## Transaction Summary
- **Type:** [description]
- **Parties:** [acquirer] acquiring [target]
- **Jurisdictions:** [list]
- **Sector:** [sector]
- **Value:** [amount]

## Critical Path Items (Must Complete Before Closing)

| # | Requirement | Jurisdiction | Authority | Threshold Met? | Est. Timeline | Status |
|---|-----------|-------------|----------|---------------|--------------|--------|
| 1 | [requirement] | [country] | [authority] | Yes/No/TBD | [days/months] | NOT STARTED |

## Post-Closing Requirements

| # | Requirement | Jurisdiction | Deadline | Status |
|---|-----------|-------------|----------|--------|
| 1 | [requirement] | [country] | [deadline] | NOT STARTED |

## Timeline Estimate
[Visual timeline showing parallel and sequential regulatory workstreams,
identifying the critical path to closing]

## Risk Assessment
| Risk | Likelihood | Impact | Mitigation |
|------|-----------|--------|-----------|
| [risk] | [H/M/L] | [H/M/L] | [action] |
```

## Important Notes

- Regulatory thresholds and requirements change. Always verify current requirements
  with local counsel.
- For adversarial verification of regulatory compliance claims in deal documents
  — cross-referencing representations against actual regulatory status — see
  [DiligenceWorks](https://diligenceworks.online).