The same former U.K. intelligence figure quoted earlier said that managing to get two permanent members of the United Nations Security Council to host a major event on the issue is “better than nothing,” but it has proven “very hard to get any country anywhere to act against malicious cyber actors on their own territory.”
James Shires said the optics of having major players in cyber espionage dictating what other countries can do has likely limited participation in the initiative. “You have these major states that not only have their own domestic capabilities, but also have a commercial industry, and they want to control access to that industry around the world.”
One major signatory, the United States, has also used its economic and diplomatic muscle to go much further than a non-binding declaration of allies.
In 2021 the U.S. blacklisted NSO’s Pegasus alongside other Israeli, Russian and Singaporean spyware companies. In 2023, then-President Joe Biden signed an executive order to ban federal agencies from using spyware which could pose a risk to American security. The U.S. government followed this up a year later by threatening to impose visa restrictions on individuals involved in commercial spyware misuse and sanctions against the Intellexa Consortium.
“These are all pretty blunt, effective actions,” Shires said. “The U.K. could have done all of that, but hasn’t. The U.S. is such a big market, so it can move on its own and have a big impact where the U.K. perhaps can’t.”
However, the new administration under Donald Trump has rowed back some of these moves, amid a renewed appetite for domestic surveillance tools. Agents with the U.S. Immigration and Customs Enforcement will have access to technology from Israeli company Paragon Solutions, after its contract was halted to comply with U.S. spyware rules. Paragon has previously come under scrutiny by the Italian government.
The Atlantic Council’s Jen Roberts said: “Right now, the U.K. and the French are being looked at as the leaders in the future, as the new U.S. administration figures out its stance on this policy issue, though we’ve seen some positive signaling, like the U.S. being a signatory on the Pall Mall Process Code of Conduct.”
GHCQ and NCSC were contacted to contribute to this piece. The U.K. government has a long-standing policy of not commenting on intelligence matters.