On 24 April 2025, the Serious Fraud Office (SFO) released new guidance on corporate self-reporting, cooperation and deferred prosecution agreements (DPAs)....more
On 1 April 2025, the UK government confirmed that the Foreign Influence Registration Scheme (FIRS) — which was established under the National Security Act 2023 — will come into force from 1 July 2025. The UK government has...more
Key Points -
If the Crime and Policing Bill (CPB) is enacted in current form, it will make it significantly easier for companies to be held liable for criminal offences committed by their senior managers. Coupled with the...more
We are pleased to present the premiere episode of “An Ounce of Prevention,” a podcast focused on compliance and white collar crime trends. Our first episode — hosted by London white collar defense and investigations partner...more
On 20 March 2025, enforcement authorities in the UK, France and Switzerland announced the creation of the International Anti-Corruption Prosecutorial Taskforce. The taskforce is comprised of:
- The UK’s Serious Fraud...more
On 12 February 2025, the UK Supreme Court handed down its decision in El-Khouri v Government of the United States of America (El-Khouri), declining to extradite Joseph El-Khouri to the US. The ruling marks a pivotal moment in...more
3/3/2025
/ AML/CFT ,
Anti-Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Enforcement Actions ,
Extradition ,
Financial Conduct Authority (FCA) ,
Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Litigation ,
UK ,
White Collar Crimes
The future of international sanctions on Russia is not settled. Whilst the representatives of the US and Russia met in Saudi Arabia on 18 February 2025 to discuss possible avenues to peace in Ukraine, the foreign ministers of...more
2/25/2025
/ Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Enforcement Actions ,
EU ,
Financial Institutions ,
Financial Services Industry ,
Popular ,
Russia ,
Sanctions ,
UK
On 6 November 2024, the UK government published its guidance on the new ‘failure to prevent fraud’ offence, which was introduced in the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).1 We covered the details...more
On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more
On 12 September 2024, the UK government published The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (Regulations) which, among other things, set out the powers of the new Office of Trade...more
9/25/2024
/ Economic Sanctions ,
Enforcement Actions ,
Financial Regulatory Reform ,
International Trade ,
New Legislation ,
New Regulations ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Sanctions ,
Trade Policy ,
UK
The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more
9/12/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Enforcement Actions ,
EU ,
Failure to Prevent ,
Financial Crimes ,
Fraud ,
Strict Liability ,
UK ,
White Collar Crimes
Russia’s invasion of Ukraine has resulted in unprecedent judicial scrutiny of the UK’s sanctions regulations. While the judgments delivered in many cases have provided companies with needed certainty on some topics, the...more
The UK Court of Appeal recently held that the National Crime Agency’s decision not to investigate whether cotton goods manufactured in China and imported to the UK were the product of forced labour was unlawful — a decision...more
7/8/2024
/ Appeals ,
China ,
Corporate Counsel ,
Financial Crimes ,
Financial Institutions ,
Imports ,
International Trade ,
Legislative Agendas ,
National Crime Agency (NCA) ,
Popular ,
Proceeds of Crime Act 2002 (POCA) ,
Supply Chain ,
UK
Historically, multinational companies and those lobbying on their behalf mostly concerned themselves with the U.S. and Canadian legal frameworks for lobbying. But more and more jurisdictions are establishing increasingly...more
Below is a summary of recent developments and enforcement trends in the UK white collar crime space in the first quarter of 2024.
I. New Legislation -
The Economic Crime and Corporate Transparency Act 2023 (ECCTA)...more
On 22 February 2024, shortly before the second anniversary of Russia’s invasion of Ukraine, the UK government published its first sanctions strategy (the Strategy). The Strategy explains the UK’s use and implementation of...more
3/12/2024
/ Belarus ,
Economic Sanctions ,
EU ,
Foreign Policy ,
International Trade ,
Licensing Rules ,
Office of Financial Sanctions Implementation (OFSI) ,
Reporting Requirements ,
Russia ,
Sanctions ,
UK ,
Ukraine
On 26 October 2023, the Economic Crime and Corporate Transparency Act 2023 (the Act) became law in the UK. The Act represents a major overhaul of the UK government’s framework for tackling financial crime and has brought into...more
2/26/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Governance ,
Corporate Transparency Act ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
EU ,
Financial Crimes ,
Investigations ,
Regulatory Agenda ,
UK ,
White Collar Crimes
With Russia’s invasion of Ukraine nearing the end of its second year, the United Kingdom has continued to introduce sanctions measures against Russia, with the latest round announced on 14 December 2023....more
1/22/2024
/ Economic Sanctions ,
EU ,
Financial Institutions ,
General Licenses ,
Oil & Gas ,
Oil Prices ,
Reporting Requirements ,
Russia ,
Sanctions ,
Trade Restrictions ,
UK ,
Ukraine
On 6 October 2023, the UK Court of Appeal (the Court of Appeal) delivered its judgment in Mints v. PJSC National Bank Trust and PJSC Bank Otkritie.1 In its decision, the Court of Appeal confirmed that English courts can enter...more
When the UK legal services ban was introduced in June 2023, concerns were raised that the exception outlined in the legislation relating to the provision of sanctions compliance advice was limited in scope. In particular, as...more
In response to the continued invasion of Ukraine, the United Kingdom has added to its measures targeting Russia by introducing a ban on the provision of certain legal advisory services.
While the UK government press...more
On 20 January 2023, the UK High Court of Justice (the High Court) delivered its judgment in R. (on the application of World Uyghur Congress) v Secretary of State for the Home Department. The case concerned a judicial review...more
On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in...more
12/9/2022
/ Cryptoassets ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Fraud ,
Foreign Entities ,
Investigations ,
Money Laundering ,
New Legislation ,
Proposed Legislation ,
Regulatory Oversight ,
Regulatory Requirements ,
Suspicious Activity Reports (SARs) ,
UK
Regulatory scrutiny of the use and management of cryptocurrency and other digital assets such as utility tokens and non-fungible tokens (NFTs) (collectively, cryptoassets) is rapidly growing on both sides of the Atlantic....more
9/13/2022
/ Blockchain ,
Criminal Investigations ,
Cryptoassets ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Financial Regulatory Agencies ,
FinCEN ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC)
The UK has long implemented sanctions imposed by the United Nations and, before Brexit, the European Union (EU). Since the UK’s departure from the EU, the UK government has sought to both preserve the policy objectives of...more