The international Financial Action Task Force (FATF) recently issued two announcements updating the list of countries and jurisdictions at high risk of money laundering, terrorist financing, and proliferation financing, and...more
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
The consultation sets out four potential models for reform, and also considers reform to sanctions supervision. On 30 June 2023, HM Treasury published a consultation on reforms to anti-money laundering (AML) and...more
Welcome to the Corporate Briefing, where we review the latest developments in corporate law that you need to know about. In this month’s issue, we discuss...more
On 2 September 2022, HM Government – through the Treasury – exercised its power to request information by issuing a financial sanctions notice requesting that all persons that hold or control funds or economic resources...more
The U.K. Office of Financial Sanctions Implementation has published a revised General License under the Russia (Sanctions) (EU Exit) Regulations 2019. The License was first published on February 25, 2022, and allows...more
Key developments of interest over the last month include: United Kingdom: HM Treasury responds to Payments Landscape Review call for evidence Hong Kong: HKMA publishes white paper exploring the idea of a CBDC Italy: Bank of...more
Of particular note this week, HM Treasury published a policy paper on ‘Greening Finance: A Roadmap to Sustainable Investing’ which sets out the UK government’s ambition to support the financial services sector to align with...more
Recent publications come in light of UK’s “greater autonomy” in setting AML and CTF regulations following Brexit. Background to the review - On 22 July 2021, HM Treasury published both a Call for Evidence on a review...more
MLRs 2017: Money Laundering and Terrorist Financing (Amendment) (No 2) (High-Risk Countries) Regulations 2021 The Money Laundering and Terrorist Financing (Amendment) (No 2) (High-Risk Countries) Regulations 2021 (SI...more
Jacqueline Cook, Senior Knowledge Development Lawyer at Sullivan's London office, broke ground on our first Trade & Export Finance Webinar of 2021, held on 21 January, and the EU-UK Trade and Cooperation Agreement (the TCA)...more
HM Treasury has published the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations and the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations, amending certain aspects of the U.K. sanctions regime. The...more
On 7 May 2020, the European Commission (Commission) issued a comprehensive and ambitious Action Plan and public consultation designed to strengthen the European Union's (EU) legal framework to fight against money laundering...more
HM Treasury and HM Revenue and Customs have launched a consultation on the implementation of rules governing the registration of trusts under the EU Fifth Anti Money Laundering Directive. Responses to the consultation should...more
UK regulations implementing the EU 5th Money Laundering Directive (“5MLD”) came into force on 10 January 2020: the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (“MLR 2019”). The regulations make a...more
The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 have been published, amending the existing Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The...more
New regulatory requirements, including registration and customer disclosure requirements, apply to regulated and unregulated persons carrying on relevant cryptoasset business. On 20 December 2019, the UK government published...more
U.K. revisions to its anti-money laundering and counter terrorist financing regime come into force on 10 January 2020. The U.K.’s revisions implement the European Union’s Fifth Anti-Money Laundering Directive, commonly...more
The U.K. Financial Conduct Authority will be appointed as the supervisor of U.K. cryptoasset businesses under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as a...more
HM Treasury has published a report on the activities undertaken by the U.K.'s anti-money laundering and counter-terrorist financing supervisory bodies in 2017-2018. The report follows the publication of the Financial Action...more
Partners Julia Smithers Excell and Stuart Willey, and associate Laura Kitchen of global law firm White & Case take a deep dive on the latest publications from EU and UK regulators aimed at providing supervisory clarity on the...more
“My message to facilitators is this: we’ve had a lot of focus on banks; now my investigators are going to be focusing on you.” This was the warning delivered by the Minister for State and Security to the so-called...more
Commons Treasury Committee report on crypto-assets - The House of Commons Treasury Committee published its report on crypto-assets. The report relates to the digital currencies inquiry the Committee launched earlier this...more
The Law Commission has published a substantial consultation paper entitled "Anti-Money Laundering: the SARs Regime," seeking views on proposals to reform the law of England and Wales governing anti-money laundering. In...more
The UK’s Joint Money Laundering Steering Group has confirmed that it has received approval from HM Treasury for the final revised guidance it published in December 2017 on anti-money laundering and counter-terrorist financing...more