The United Kingdom’s Global Travel Taskforce has set out plans to safely resume international travel, including plans for a new traffic light ranking system, a “green watch list” and the introduction of a new travel certification system.

The Global Travel Taskforce’s report on the safe return of international travel suggests travel could resume as soon as May 17, 2021. While testing and quarantine measures would remain in place, passengers would no longer need to prove they have a valid reason to leave the country. Currently, international travel is only permitted where you have a reasonable excuse to leave the U.K., such as essential work or business reasons where it is not reasonably possible to complete that work within the U.K.

The permission to travel form would be eliminated, but other measures would be taken to mitigate the spread of the COVID-19 virus.

Traffic Light System.

The traffic light system would categorize countries as “green,” “amber” or “red” based on their risk for spreading COVID-19. Officials would consider factors such as (1) the percentage of the country’s population that has been vaccinated, (2) the country’s rate of infection, (3) the prevalence of variants of concern in the country and (4) the country’s access to reliable scientific data and genomic sequencing.

Quarantine and testing measures would remain in place for all travelers entering the United Kingdom, but would apply differently as follows:

  • Green. Arrivals from green countries would need to take a COVID-19 test before departing for the U.K. and a PCR test on or before their second day in the U.K. They would not need to quarantine unless they receive a positive test result.
  • Amber. Arrivals from amber countries would need to quarantine for 10 days upon arrival. They would also be required to take a pre-departure test and PCR tests on their second and eighth days in the U.K. They would be eligible for the Test to Release program and could cut their quarantine period short by testing negative on their fifth day in the U.K.
  • Red. Arrivals from red countries would have to follow restrictions currently in place for “red list” countries, including a 10-day hotel quarantine, pre-departure testing and PCR testing on the second and eighth day in the U.K.

“Green Watchlist.” U.K. officials plan to introduce a “green watchlist” of countries that are at risk of moving from “green” to “amber.” This would give passengers more predictability about which protocol they would be subject to upon returning to the U.K. Officials stress, however, that while the watchlist would help warn travelers of potential changes, they would not hesitate to move countries into different categories immediately if necessary. The watchlist nonetheless aims to provide “greater assurance” for those wishing to travel abroad.

Travel Certification. Officials said the U.K. would play a leading role in developing international standards for a digital travel certification program. Such a program could facilitate both inbound travel and outbound travel to countries that have their own travel certification programs in place.

Analysis & Comments: The resumption of international travel and the elimination of the requirement that people provide a valid reason to leave the U.K. are certainly welcome developments, not just for business travelers but also for those wishing to travel internationally for leisure purposes. Travelers should note, however, that May 17 remains an ambitious target date, and officials stress that this is the earliest possible date for international travel to resume. Restrictions will also be formally reviewed on June 28, taking into account the international COVID-19 health picture at that point in time. Measures may be relaxed or tightened at that point in time. Further formal reviews will also take place over the course of the next six months. Additional information is expected in the coming weeks and Deloitte will provide further updates in due course.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States, which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

Italian authorities have eased restrictions on travel from Austria, Israel and the United Kingdom and implemented new quarantine procedures for travel from within the European Union.

Key Points:

  • Authorities have moved Austria, Israel and the United Kingdom to “List C,” meaning travel is permitted for non-essential reasons, but travelers must satisfy testing and quarantine requirements.
  • Under procedures implemented last week, travelers from List C countries must take a COVID-19 molecular or antigenic test within the 48 hours before arriving in Italy and must quarantine in Italy for five days upon arrival in Italy, regardless of the test result. A second molecular or antigenic test must be taken at the end of the five-day quarantine.
  • Travelers from the Tyrol region of Austria must quarantine for 14 days rather than five.
  • The quarantine measures were first implemented as a way to mitigate the spread of the COVID-19 over the Easter holiday period; however, authorities extended them this week until at least April 30.
  • The current restrictions on travel from Brazil will also remain in place until at least April 30.

Analysis & Comments: While authorities have eased restrictions on travel from Austria, Israel and the United Kingdom, testing and quarantine requirements from these and other “List C” countries will remain in place at least until the end of the month. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States, which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

The U.K. government has announced that beginning at 4 a.m. on Friday, April 9, Bangladesh, Kenya, Pakistan and the Philippines will be added to England’s COVID-19 “red list.”

Key Points:

  • Travel bans remain in place for visitors to England from the existing “red list” countries. Beginning April 9, the list will also include Bangladesh, Kenya, Pakistan and the Philippines.
  • The travel ban applies to travelers who are either traveling from the “red list” countries or have been in those countries (including in transit) in the previous 10 days.
  • U.K. nationals, Irish nationals and U.K. residents (including Skilled Worker visa holders) are allowed to enter England from the red list countries. However, they will be required to enter a government-approved hotel quarantine facility for 10 days upon arrival.

Additional Information: The new measures mark a tightening of restrictions in light of reported new variants of COVID-19.

Analysis & Comments: The new requirement is essential to note for travelers from Bangladesh, Kenya, Pakistan and the Philippines. Eligible travelers from these countries will need to factor in additional costs of the hotel stay.

Travelers to England are reminded that the existing requirements remain in place for COVID-19 testing 72 hours before travel and on day two and day eight after arrival. The existing requirement to self-isolate for 10 days after arrival (either in the traveler’s accommodation or a hotel if arriving from a red list country) also remains in place. Employers who intend to send employees to the U.K. may wish to consult with Deloitte about their travel plans.

The response to COVID-19 continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States, which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche To.hmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

The United Kingdom has resumed priority processing in most U.K. immigration categories for applications submitted from within the U.K.

Key Points:

  • For an additional fee, applicants can apply for faster decisions on certain U.K. visa or settlement applications, including Skilled Worker and ICT applications. Depending on the visa or immigration category, processing may be possible within five working days or by the end of the next working day.
  • The U.K. suspended priority processing for most applications early in the COVID-19 pandemic; however, priority services are now available for most categories. The full list is available here.

Analysis & Comments: The resumption of the priority service routes is certainly good news for visa applicants applying from within the U.K. However, applicants need to be mindful there is currently a lead time of around four weeks to secure an appointment, and that the issuance of the Biometric Residence Permit (BRP) could take up to a further seven to 10 working days following the approval of the application. Applicants for U.K. visas or settlement are welcome to discuss possible expedited processing options with Deloitte.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States, which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

The United Kingdom will open the new Graduate route on July 1 for international students who want to live and work in the U.K. after completing their studies.

Key Points:

  • The route is for international students who have earned a bachelor’s degree or higher in the U.K. Successful applicants will be able to work or look for work for up to two years, or three years for Doctoral students.
  • The Graduate route will be unsponsored; applicants will not need a job to apply. Applicants will be able to switch jobs, and there will be no minimum salary requirements above the National Minimum Wage. The U.K. will not cap the number of students eligible for the route.
  • Applicants who began their studies in the U.K. in fall 2020 have until June 21, 2021, to enter the U.K. in order to be eligible for the route. This date was pushed back from April 6, 2021, because of travel restrictions related to the COVID-19 pandemic.
  • A Graduate in this route may switch into the Skilled Worker visa category.

Additional Information: The U.K. is introducing the Graduate route as part of its switch to a points-based immigration system following the end of free movement between the U.K. and EU on Jan. 1, 2021. The new route is also part of the government’s efforts to increase the number of international higher education students to 600,000 by 2030.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States, which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

The German government has removed Ireland and the United Kingdom from Germany’s list of COVID-19 “virus variant” areas, lifting travel bans had been in place since January. Officials reclassified both Ireland and the United Kingdom as “risk areas.”

Key Points:

  • Residents of Ireland can travel to Germany without providing a specific reason, provided they follow travel rules on testing and quarantine. Residents of the U.K. must generally travel to Germany under the rules applicable to third countries, though different rules may apply for EU nationals who live in the U.K.
  • Travelers from Ireland, the United Kingdom and other risk areas must:
    • Register at www.einreiseanmeldung.de before arriving in Germany and carry proof of registration when entering the country.
    • Present results (1) upon arrival of a negative COVID-19 PCR test taken within the 48 hours prior to their travel to Germany or (2) within the first 48 hours after arriving in Germany.
    • Self-isolate for 10 days upon arrival. The isolation period can be cut short after five days upon presenting a negative COVID-19 test.
    • The final decision on entry to Germany is made at the discretion of the Federal Police; however, airlines may also check to ensure that travel requirements are met. Travelers are advised to check with their airline before travel.
  • Brazil, the Czech Republic, South Africa and 10 other countries and regions remain on Germany’s “virus variant” list. Travel remains suspended to anyone who has been in these countries in the past 10 days, except for a few narrow exceptions, e.g., for German nationals and their immediate family or those with a registered domicile in Germany.

Analysis & Comments: The removal of Ireland and the United Kingdom from the “virus variant” list will ease travel for some, but a number of restrictions and health protocols remain in place.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

Italian authorities have extended restrictions on travel from Brazil and the United Kingdom and tightened rules on travel from Japan. The changes will remain in effect until at least April 6.

Key Points:

  • Brazil. Brazil remains on List E. This means that most air travel from Brazil is suspended, though exemptions introduced last month will remain in place. Additional exemptions are now available to those traveling from Brazil in order to reach the domicile, home or residence of their minor children and to those whose entry is authorized by the Italian Ministry of Health, for reasons of necessity, regardless of their residence.
  • United Kingdom. The United Kingdom also remains on List E. Travel from the United Kingdom is only permitted for people with registered residence in Italy from before Dec. 23, 2020, or who can demonstrate proven reasons of necessity to return to Italy.
  • Japan. Officials recently moved Japan from List D to List E, meaning travel from Japan is also only permitted for essential reasons, such as work, health, study, absolute urgency or to return to own home, domicile or residency.
  • Other travel restrictions. All other current travel restrictions will remain in place until at least April 6.

Additional Information: Italy has also extended “COVID tested” flights to Italy from the United States. Travel from the United States remains restricted, but those who are permitted to travel to Italy can avoid quarantine upon arrival by taking a “COVID tested” flight and presenting results of a negative COVID-19 test taken no more than 48 hours before departure. Authorities are looking to expand “COVID tested” flights to arrivals from other countries, but for now they are only available for those traveling to Italy from select airports in the U.S. (Atlanta, Newark and New York) and Germany (Frankfurt and Munich).

Analysis & Comments: Business travelers should expect travel to Italy from Brazil, Japan and the United Kingdom to be strictly limited until at least April 6. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

The United Kingdom is now requiring all outbound international travelers to carry a new form that states that their trip is permitted under the country’s COVID-19 lockdown rules.

Key Points:

  • The U.K. remains under stay-at-home rules that were put in place to mitigate the spread of the COVID-19 virus. These rules make it illegal to travel abroad except for a permitted reason, such as for work or education.
  • Under a change that took effect Monday, March 8, anyone leaving the U.K. must download and sign a travel declaration form stating their reason for travel. The form must be printed and carried or downloaded onto a mobile device before travel.
  • Carriers will check that the forms have been completed before boarding, either at check-in or the departure gate. Those who have not completed the form may not be permitted to travel.
  • Police officers will conduct spot checks at airports to ask travelers to produce their completed form. It is an offense to fail to produce a completed form at the port or airport, and individuals could face a £200 fine for failing to do so.
  • Furthermore, travelers who are identified as attempting to travel for reasons that are not permitted will not be allowed to travel and risk receiving a fixed penalty notice starting at £200 rising to a maximum of £6,400.

Additional Information: The new form is one of several travel-related requirements the U.K. government has put in place to slow COVID-19 transmission. Earlier this year, U.K. officials introduced a pre-departure testing requirement for all international arrivals. They have also established a “red list” of countries with high transmission rates; travelers arriving from these countries must isolate at a government-approved facility for 10 days upon arrival. All international arrivals must also take a COVID-19 test 72 hours before departure and on the second and eighth day of their isolation period after arriving in the U.K.

Analysis & Comments: The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

The U.K. government has announced new plans to modernize the country’s immigration system to “attract and retain the most highly-skilled, globally mobile talent.” The plans are detailed in a budget plan submitted to the House of Commons last week and focus on attracting global talent in academia, science, research and technology.

Among other proposals, the budget calls on the government to:

  • Introduce an elite points-based visa. This visa would be introduced by March 2022 and would include a “scale-up” stream that would allow those with job offers from a recognized U.K. scale-up to qualify for a fast-track visa.
  • Reform the Global Talent visa. This reform would include allowing winners of international prizes, scholarships and programs for early promise to automatically qualify for a visa.
  • Review the Innovator visa. This would be done with the goal of making it easier for individuals with skills and experience to start a business and obtain a visa.
  • Launch a new Global Business Mobility visa. This would be done by spring 2022 and would allow for overseas businesses to more easily establish a presence in the U.K. or transfer staff to the U.K.
  • Provide practical support. These efforts would target small firms that are using the visa system for the first time.
  • Modernize the immigration sponsorship program. The government plans to publish a delivery roadmap this summer, detailing plans to make the sponsorship program easier to use.
  • Establish a global outreach strategy. This would be done by expanding the Global Entrepreneur Program, marketing visa offerings and exploring the possibility of building an overseas talent network.

Analysis & Comments: Employers will welcome the steps being taken to ensure that the U.K. can attract and retain the most highly skilled, globally mobile talent from around the world. Employers will also welcome the steps being taken to modernize the immigration sponsorship system and will wait with interest for the roadmap due to be published in the summer. Deloitte will continue to follow developments related to the budget proposal, and will provide additional updates as information becomes available.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

The United Kingdom has launched a smartphone application (App) for the Hong Kong British Nationals Overseas/BN(O) visa.

Key Points:

  • The App allows BN(O) and Hong Kong Special Administrative Region passport holders to submit their biometrics and confirm their identity through their phones. European Economic Area biometric passport holders already have access to this App.
  • Individuals can use the App while in the U.K. or abroad.
  • Applicants with a valid BN(O) passport can use this link for their application. If the application is approved, they can travel to the U.K. using any valid passport.
  • Applicants without a valid BN(O) passport who are BN(O) status holders can apply for a BN(O) passport before submitting an application.
  • Those who encounter trouble scanning documents should complete their applications at a Visa Application Centre if they are in Hong Kong or at a UK Visa and Citizenship Application Services location.
  • BN(O) status holders and BN(O) family members with existing U.K. visas are not required to apply until their current visa or Leave Outside the Rules is close to the expiry date.

Background: The App is being made available to BN(O)s after the U.K. opened a new BN(O) visa category for Hong Kong BN(O) status holders on Jan. 31, 2021.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”)