The UK Financial Conduct Authority (FCA) is entering the final year of its 2022-2025 strategy, which features a commitment to be more innovative, assertive and adaptable. Its 2024/25 Business Plan outlines how the regulator...more
3/29/2024
/ Anti-Money Laundering ,
Consultation ,
Enforcement ,
Enforcement Priorities ,
Environmental Social & Governance (ESG) ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
HM Treasury ,
Market Abuse ,
Strategic Planning ,
Supervision ,
UK
Almost six years have passed since the introduction of the UK Sanctions and Money Laundering Act, and two years since Russia's invasion of Ukraine, which was a watershed moment for the UK sanctions regime.
Against the...more
3/8/2024
/ Economic Sanctions ,
EU ,
Financial Crimes ,
Information Reports ,
Judicial Intervention ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Russia ,
Supply Chain ,
UK ,
UN Security Council ,
United Nations
“Stopping financial crime requires a collective effort...we will be more proactive in our supervision. Where we detect harm or UK-wide financial crime vulnerabilities, we will continue to share intelligence with our partners...more
On Friday, 6 October 2023 the Court of Appeal handed down judgment in the case of Mints v PJSC National Bank Trust & Anr [2023] EWCA Civ 1132. This judgment is significant and is a key, albeit non-binding, indicator of the UK...more
10/11/2023
/ Banks ,
Belarus ,
Belarus Sanctions ,
Control Test ,
Economic Sanctions ,
EU ,
Final Judgment ,
Russia ,
State-Owned Enterprises ,
UK ,
Vladimir Putin
The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more
3/23/2023
/ Business Ownership ,
Change of Ownership ,
Compliance ,
Control Test ,
Due Diligence ,
Economic Sanctions ,
Enforcement ,
Financial Conduct Authority (FCA) ,
Guidance Update ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Strict Liability ,
UK
Effective February 5, 2023, the Price Cap Coalition (the Coalition), consisting of the G7 nations, the European Union (EU) and Australia, set a price cap of $45 per barrel for “Discount to Crude” petroleum products of Russian...more
2/10/2023
/ Australia ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
General Licenses ,
New Guidance ,
Oil & Gas ,
Oil Prices ,
Russia ,
Ukraine
Recovering criminal assets is difficult. A good recent example of this difficulty came in October this year, when the Treasury estimated that it could recover just £1.2 billion of the £4.5 billion lost to Covid...more
A ban on services related to the maritime transport of Russian-origin crude oil sold above a pre-determined price cap of $60 per barrel began on December 5, 2022, with a similar price cap ban related to other Russian-origin...more
12/7/2022
/ Australia ,
Commodities ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
Global Market ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
Ukraine
Sustainability has risen to the top of the agenda for businesses around the world. Governments, investors and the public demand that organisations play a part in the global push to eliminate, or at least limit, the...more
9/29/2022
/ Analytics ,
Biden Administration ,
Climate Change ,
Corporate Governance ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
EU ,
Greenhouse Gas Emissions ,
International Criminal Court ,
New Legislation ,
Reputation Management ,
Risk Assessment ,
Risk Management ,
Supply Chain ,
Sustainability ,
Sustainable Business Practices ,
Transparency ,
UK
On 10 June 2022, the Law Commission published its long-awaited options paper on Corporate Criminal Liability (“the Paper”). The Paper discussed a “failure to prevent money laundering offence” (the “FTPML Offence”), but did...more
We wanted to share an update on Russia sanctions developments in the United States, United Kingdom, and European Union that occurred between March 24 and April 8, 2022. Following new reports of atrocities committed by the...more
We wanted to share an update on Russia sanctions developments in the United Kingdom, European Union, and the United States that occurred between March 16 and 24. As summarized below, key global jurisdictions have continued to...more
The climate crisis, a problem that once took the form of abstract temperature charts and projections, is now a dizzying parade of broken meteorological records and natural disasters. It therefore seemed like apt timing when,...more
Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more
5/25/2021
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Corporate Misconduct ,
Criminal Convictions ,
Criminal Liability ,
Criminal Prosecution ,
Cross-Border ,
Deferred Prosecution Agreements ,
Enforcement ,
FOIA ,
Internal Controls ,
Jurisdiction ,
Law Enforcement ,
OECD ,
Serious Fraud Office (SFO) ,
UK ,
UK Bribery Act
In January 2018 the Criminal Finances Act 2017 (“the Act”) came into force. The Act brought in a number of important legal developments, including Asset Freezing and Forfeiture Orders (“AFFOs”) and the offence of failure to...more
On February 5, 2021 the Supreme Court handed down judgment in the case of R (on the application of KBR, Inc) v Director of the Serious Fraud Office, finding in favor of the Appellant, KBR, Inc (KBR). This high-profile case...more
On February 5, 2021 the Supreme Court handed down judgment in the case of R (on the application of KBR, Inc) v Director of the Serious Fraud Office, finding in favor of the Appellant, KBR, Inc (KBR). This high-profile case...more
In 2016, Professor Philippe Sands QC published East West Street, which recounts the development of the concepts of genocide and crimes against humanity and their application in the Nuremberg Trials. In November 2020, 75 years...more
On 13 October 2020 Transparency International (TI) published its annual report on enforcement of foreign bribery (the Report). The Report analyses foreign bribery enforcement in 43 of the 44 signatories to the Organisation on...more
On 21 July 2020 the National Crime Agency (“NCA”) released its Annual Report and Accounts 2019-20 (“the Report”). The Report outlines financial information and other data, and provides a snapshot of the NCA’s performance and...more
On 12 May 2020 the UK belatedly published its statement on cross-border information-sharing within corporate groups (the Statement). This one-page document primarily consists of general acknowledgements of the importance of...more