A Freedom of Information response has confirmed what the UK’s speech regulator would probably have preferred to keep quiet. Ofcom fired off 197 information demands to American tech companies under the Online Safety Act, and not a single one went through the US-UK Mutual Legal Assistance Treaty, the formal diplomatic process that exists for exactly this kind of cross-border legal enforcement. Every one of those 197 notices was sent directly, by email or post, to companies operating entirely on American soil.
The number comes from a FOI request filed by Daniel Lü, who asked Ofcom a series of pointed questions about how it enforces the Online Safety Act against non-UK targets.
Ofcom confirmed that as of February 26, 2026, it had issued 197 Section 100 notices to US businesses. Zero through MLAT. The treaty between the US and UK that governs how one country’s legal process gets enforced in the other’s jurisdiction was treated as optional. Ofcom decided it didn’t apply.
That admission drew an immediate response from Preston Byrne, the American lawyer who represents 4chan and other US companies targeted by Ofcom.
Byrne called the 197 notices a “breathtaking” “attack on the First Amendment” and pointed out the uncomfortable math.
Only two US companies, 4chan and Kiwi Farms, have publicly refused to comply with Ofcom’s demands. If Byrne’s assessment is right, that leaves Ofcom enjoying “a 98% compliance rate with foreign censorship orders that violate the First Amendment.”
A British regulator sent nearly 200 demands to American companies, bypassed every established legal channel, and almost all of them appear to have simply done what they were told. The chilling effect is already here.
Hellbound and Down 