Transparency data

CMA: Business Appointment Rules advice, October to December 2024

Published 27 March 2025

© Crown copyright 2025

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This publication is available at https://www.gov.uk/government/publications/cma-business-appointment-rules-advice-october-to-december-2024/cma-business-appointment-rules-advice-october-to-december-2024

Adam Cooper

Title of former Civil Service role

Director

Date left/retired from the Civil Service

19 November 2024

New employer

Fingleton Associates

New appointment/employment (including when taken up)

Director, Start date: 20 November 2024

Department’s decision on application (including details of any waiting period or other conditions or restrictions applied)

Approved with the following conditions:

  1. He shall not undertake work on any matter he was involved in whilst at the CMA, including any work closely related to such matters. This includes, but is not limited to: Microsoft / OpenAI; Topps Tiles / CTD tiles; Safran / Collins; RedBirdIMI / Telegraph; Hitachi / Thales; Cerelia / JusRol; Lindab / HAS-Vent; Spreadex / Sporting Index; Mobile Browsers and Cloud Gaming; Global Business Travel Group, Inc / CWT Holdings, LLC; and Alphabet Inc. (Google LLC) / Anthropic 2.
  2. He shall continue to comply with the ongoing duty of confidentiality and other obligations as provided for in the Civil Service Code, the Official Secrets Act 1989, and under the terms of his appointment with the CMA.
  3. He shall continue to comply with the ongoing duty not to disclose any information acquired during his employment with the CMA which is protected by Part 9 of the Enterprise Act 2002.
  4. He shall not use or in any way disclose information acquired during his employment with the CMA which is subject to legal professional privilege, including both legal advice privilege and litigation privilege.
  5. He shall not use or disclose any confidential information obtained while working for the CMA.

Furthermore, the BARs apply for 2 years from his last day of service and during this time, if he 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.

Cho Man Gordon Wai

Title of former Civil Service role

Director of Technology Insight

Date left/retired from the Civil Service

12 November 2024

New employer

Keystone Strategy LLC

New appointment/employment (including when taken up)

Senior Engagement Manager, Start date: 18 November 2024

Department’s decision on application (including details of any waiting period or other conditions or restrictions applied)

Approved with the following conditions:

  1. Unless the CMA consents, he shall not undertake, for a period of 6 months from his last day in the Civil Service, any work involving Microsoft.

  2. Unless the CMA consents, he shall not undertake, for a period of 2 years from his last day in the Civil Service, any work on any matter he was involved in whilst working at the CMA, including any work closely related to, or arising from, such matters, on behalf of his new employer (or on behalf of any clients of his new employer). This includes but is not limited to the CMA’s: market investigation into Cloud Services; market investigation into Mobile Browers and Cloud Gaming; investigation into Google’s Privacy Sandbox; review into AI Foundation Models (and any merger matters relating to AI Foundation Models); Microsoft / Open AI, Google / Anthropic, Amazon / Anthropic, SpreadEx / Sporting Index and IBM / Hashicorp merger matters.

  3. Unless the CMA consents, he shall not undertake, for a period of 2 years from the last day in the Civil Service, any work launched, or that may be launched, by the CMA under the Digital Markets, Competition and Consumers Act that relates to, or arises from, any work he was involved in whilst working for the CMA.

  4. Unless the CMA consents, he will not work on any matter concerning the CMA’s practice, policy, procedures and approach to the implementation of the Digital Markets, Competition and Consumers Act regime, in circumstances where that matter relates to information that is not in the public domain, until such time as the Act comes into force.

  5. For a period of 6 months from his last day in the Civil Service, he may not appear on any matter before the CMA or be directly in contact with the CMA on any matter, on behalf of his new employer (or on behalf of any clients of his new employer).

He must:

  • 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 his appointment with the CMA
  • not disclose any information acquired during his 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 confidential information obtained while working at the CMA, including any information obtained in relation to work referred to at points 2 to 4 above

Furthermore, the BARs apply for 2 years from his last day of service and during this time, if he intends to take on other paid or unpaid roles, he will need to contact the CMA  and make a new application under BARs regarding the new role/s.

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