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UK, French, and Swiss Enforcement Authorities Announce New Alliance

Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more

Recent Developments in UK Sanctions

After a relatively quiet period, UK sanctions updates have picked up pace in recent weeks. We have seen the announcement of an enhanced partnership between US and UK sanctions agencies, updates to reporting requirements, the...more

UK Sanctions - Autumn Roundup

In recent months there have been a number of significant developments in the UK sanctions space. This blog post summarises a few of them....more

Asset freezing and asset seizing under the UK sanctions regime

The UK’s National Crime Agency (NCA) recently secured its first forfeiture of sanctioned funds. This was a landmark achievement for the NCA’s Combatting Kleptocracy Cell, which has only existed since 2022 and aims to...more

Will Companies House powers clean up the register?

Companies House has been granted new powers to crack down on fraud, but whether it has the resources to take advantage of these and properly clean up the register of companies is questionable. Originally published by...more

FCA Highlights Risks Posed to Firms by Organised Crime Groups (OCG) and How Firms Can Mitigate These

Combatting financial crime continues to be a key supervisory and enforcement priority for the FCA. The importance of this area was reiterated by the FCA’s February 2024 newsletter - Market Watch 77 - which sets out...more

OTSI - the UK’s Specialist New Trade Sanctions Agency

On 11 December 2023, the UK’s Industry and Economic Security Minister announced the creation of a new UK agency dedicated to implementing and enforcing trade sanctions. The Office of Trade Sanctions Implementation (OTSI) will...more

The Financial Conduct Authority’s Review of Firms’ Approaches to Politically Exposed Persons

The UK Financial Conduct Authority (FCA) launched in September a review of the treatment of domestic politically exposed persons (PEPs) by UK-regulated financial services firms. This review will look at firms’ arrangements...more

OFSI Encourages Self-Reporting of Sanctions Breaches

Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more

Call for Reform of Regulatory Supervision of Auditors

Chartered accountants are accustomed to continuous oversight of their work by regulators. While regulatory supervision can often be a collaborative process, it does sometimes culminate in individual accountants and firms...more

Money Laundering In The UK Art Market: Key Risks, AML Rules

We have been writing a lot recently about trends in the global market for fine art. One specific area that deserves attention is steps taken to stamp out laundering illicit funds via the art market, such as through auctions...more

Failure to Prevent Fraud for UK Corporates

The UK Government yesterday introduced a new corporate “failure to prevent fraud” offence into draft legislation, the Economic Crime and Corporate Transparency Bill (“the Bill”). This is a significant development in UK...more

UK FCA Regulatory Business Plan for 2023 and 2024

The Financial Conduct Authority’s (FCA) 2023/24 Business Plan (Business Plan) sets out the FCA’s aim to be viewed as a proactive, assertive and robust regulator, especially in its protection of retail consumers. Released...more

Online Safety Bill - Update on Senior Manager Liability

The Online Safety Bill (the “OSB”) is back on the UK Government’s legislative agenda, this time with an important update relating to criminal liability of senior managers. Following some political wrangling, back-bench MPs...more

UK GDPR Restrictions on Personal Data Transfers to South Korea are Lifted

In November 2022, the UK Government announced that it had put in place UK GDPR ‘adequacy regulations’ in respect of South Korea (the Republic of Korea (“ROK”)). These new regulations will allow UK based organisations to...more

Online Safety Bill Update: civil sanctions prioritized over criminal

The U.K. Government recently introduced an updated draft of the Online Safety Bill (the “OSB”) to Parliament. The OSB is the U.K.’s first significant piece of legislation regulating online behavior. ...more

The new Economic Crime Bill: can it deliver on its promises?

On March 1, 2022, the UK Government put forward the Economic Crime (Enforcement and Transparency) Bill. The stated aim of the legislation is to “crack down on dirty money in the UK and corrupt elites”, and it is designed to...more

The UK Government’s Bounce Back Loan Scheme - are there lessons to be learned?

The UK’s National Audit Office (the “NAO”) has reported that an estimated 11% - a total of £4.9 billion out of £47 billion issued - of the 1.5 million loans granted under the Government’s COVID-19 Bounce Back Loan Scheme (the...more

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