CMA: Business Appointment Rules advice, April to June 2025
Published 25 September 2025
Jessica Radke
Title of Former Civil Service Role
Deputy General Counsel
Date Left/Retired from the Civil Service
2 May 2025
New Employer
Linklaters
New Appointment/Employment (including when taken up)
Senior Counsel. Start date: 6 May 2025
Department’s Decision on Application (including details of any waiting period or other conditions or restrictions applied)
Approved subject to the following conditions:
-
that unless the CMA otherwise consents, she shall not undertake, for a period of two years from her last day in the Civil Service, any work on any matter she was involved in whilst working at the CMA, including any work closely related to, or arising from, such matters, on behalf of her new employer (or on behalf of any clients of her new employer). This includes (but is not limited to) specified C98 cases; specified damages/follow-on claims; specified Markets, Mergers and Consumer cases; specified regulatory appeals and specified digital/digital markets cases
-
that unless the CMA otherwise consents, she shall not undertake, for a period of six months from her last day in the Civil Service, any work involving Microsoft
-
that, unless the CMA otherwise consents, she shall not undertake, for a period of two years from the last day in the Civil Service: a) any work on matters launched, or that may be launched, by the CMA under the Digital Markets, Competition and Consumer Act (the “Act”) that relates to, or arises from, any work she was involved in whilst working for the CMA; b) any work on matters she was involved in that closely relate to, or arise from, preparations for operational readiness with respect to the powers under the Act
-
that, unless the CMA otherwise consents, she will not advise on a) any matter concerning the CMA’s practice, policy, procedures and approach to the implementation of the consumer law enforcement regime under the Act, to the extent that matter relates to information that is not in the public domain, until such time as the consumer law enforcement regime under the Act takes effect; b) any matter concerning CMA 207 (CMA’s consumer law draft guidance concerning unfair trading provisions in the Act), until such time as the guidance is published in final version
-
that unless the CMA otherwise consents, for a period of 6 months from her last day in the Civil Service, she may not appear on any matter before the CMA, or be directly in contact with the CMA on any matter, on behalf of her new employer (or on behalf of any clients of her new employer)
She has also been reminded of her on-going obligations of non-disclosure of information received during her time at the CMA, namely that she must:
-
continue to comply with the duty of confidentiality and other obligations as provided for in the Civil Service Code/Civil Service Management Code, the Official Secrets Act 1989, and under the terms of her appointment with the CMA
-
not disclose any information acquired during the applicant’s employment with the CMA which is protected by Part 9 of the Enterprise Act 2002
-
not use or in any way disclose information acquired during the applicant’s employment with the CMA which is subject to legal professional privilege, including both legal advice privilege and litigation privilege
-
not use or disclose, any other confidential information obtained while working at the CMA
Furthermore, the BARs apply for 2 years from her last day of service and during this time, if she intends to take on other paid or unpaid roles, she will need to contact HRQueries@cma.gov.uk to make a new application under BARs regarding the new role/s.
George Lusty
Title of Former Civil Service Role
Interim Executive Director, Consumer Protection and Markets
Date Left/Retired from the Civil Service
26 May 2025
New Employer
Ofcom
New Appointment/Employment (including when taken up)
Director of Enforcement. Start date: 2 June 2025
Department’s Decision on Application (including details of any waiting period or other conditions or restrictions applied)
Approved, subject to a number of limited conditions, as set out below.
He will not work on the following matters whilst at Ofcom:
-
the market investigation into Cloud Services, or any matter related to that investigation (for example, any SMS designation work under the Digital Markets, Competition and Consumer Act which relates to the investigation)
-
consumer policy work concerning drip pricing in the Communications sector (including in relation to mid-contract price rises)
-
work undertaken by Ofcom in response to the CMA’s recommendations in 2018 concerning loyalty pricing and subscription traps in the communications sector
He has been reminded of the following:
-
that the BARs apply for 2 years from his last day of service and he will need to inform HR Queries if he intends to take any paid or unpaid roles where the circumstances set out in the BARs apply
-
that he is subject to these obligations
-
not to disclose information acquired during his employment with the CMA, which is protected by Part 9 of the Enterprise Act
-
to continue to comply with the duty of confidentiality and other obligations provided for in the Civil service Code, the Official Secrets Act 1989 and under the terms of his employment with the CMA
-
to continue to comply with the Solicitors Regulation Authority Rules of Conduct and in particular Rule 6 (conflicts of interest)
Francesca Sala
Title of Former Civil Service Role
Director of Economics
Date Left/Retired from the Civil Service
17 June 2025
New Employer
Oxera Consulting LLP
New Appointment/Employment (including when taken up)
Partner. Start date: September 2025
Department’s Decision on Application (including details of any waiting period or other conditions or restrictions applied)
Approved subject to the following conditions:
That unless the CMA otherwise consents, she shall not undertake, for a period of two years from her last day in the Civil Service, any work on any matter she was involved in whilst working at the CMA, including any work closely related to, or arising from, such matters, on behalf of her new employer (or on behalf of any clients of her new employer). This includes (but is not limited to):
-
Mergers Remedies Review
-
Mergers Cases: SES/Intelsat and Aviva/Direct Line
-
CMA intervention in the CAT on Gormsen vs Meta
-
Funeral Market Review
She has been reminded of her on-going obligations of non-disclosure of information, namely that she will:
-
not use or disclose any confidential information obtained while working for the CMA, in particular in relation to any case or project which the applicant supported while working for the CMA
-
continue to comply with the duty of confidentiality and other obligations as provided for in the Civil Service Code, the Official Secrets Act 1989, and under the terms of her appointment with the CMA
-
not disclose any information acquired during the applicant’s employment with the CMA which is protected by Part 9 of the Enterprise Act 2002
-
not use or in any way disclose information acquired during the applicant’s employment with the CMA which is subject to legal professional privilege, including both legal advice privilege and litigation privilege
Furthermore, the BARs apply for 2 years from his last day of service and during this time, if the applicant intends to take on other paid or unpaid roles, he will need to contact the CMA to make a new application under BARs regarding the new role/s.