The Bribery Act: To Disclose or Not To Disclose?
The Supreme Court has ruled that the Proceeds of Crime Act 2002 (POCA) only catches substantive money laundering acts committed in the UK. This simplifies the assessment for companies when considering whether to file a report...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more
In this article, we examine the potential impact on organisations managing global supply chains of the recent Court of Appeal judgement in the case against the National Crime Agency (NCA) brought by the World Uyghur Congress...more
New UK enforcement body goes live and new powers granted to existing body, regulating those doing business in the UK. UK trade sanctions enforcement risks are set to increase on October 10, 2024, as two government agencies...more
Quicker and easier sharing of customer information relating to economic crime concerns between firms in the UK financial sector has been encouraged by provisions in the Economic Crime and Corporate Transparency Act 2023...more
In the wake of Russia's invasion of Ukraine in February 2022, a broad and unprecedented range of sanctions were imposed on Russia by various countries and international bodies to target the Russian economy and prevent further...more
In a landmark ruling, the Court of Appeal in a case brought by the World Uyghur Congress (WUC) has clarified that the provision of “adequate consideration” at some point in the supply chain does not prevent goods imported...more
On 5 September 2024, the UK’s data privacy regulator, the Information Commissioner’s Office (ICO), and the UK National Crime Agency (NCA) signed a Memorandum of Understanding (MoU) outlining how they will further collaborate...more
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
The recent ruling by the U.K. Court of Appeal declared that the U.K. National Crime Agency’s decision not to investigate the importation of cotton produced through the use of Uyghur forced labor in China was unlawful. This...more
In this week’s edition we discuss the implications of a decision against the National Crime Agency, which the UK’s Court of Appeal held had misinterpreted the law when it refused to investigate whether imported cotton was...more
On 27 June 2024, the Court of Appeal handed down judgment in World Uyghur Congress v National Crime Agency [2024] EWCA Civ 715. The challenge of a 2023 decision by the High Court was brought by World Uyghur Congress ("WUC")...more
Why is this case important? The case challenged a decision by the National Crime Agency (“NCA”) not to carry out investigations into whether consignments of cotton goods were the product of alleged forced labour and/or other...more
The ruling propels UK law enforcement to increase its investigative powers under POCA, and businesses to enhance their supply chain due diligence. On 27 June 2024, the UK Court of Appeal found that the National Crime...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
On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more
Recent weeks have seen several notable developments in the UK criminal enforcement landscape...more
The UK’s Serious Fraud Office (SFO) published its strategy for 2024–2029 on 18 April 2024, outlining its ambitious plans to become the “pre-eminent specialist, innovative and collaborative agency” in the fight against serious...more
2023 was another significant year for UK sanctions. The UK government has continued to implement new sanctions against Russia in response to its illegal war in Ukraine, including through new designations, broadened financial...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
On 13 February 2024, Nick Ephgrave gave his inaugural public speech as the new Director of the UK’s Serious Fraud Office (SFO). With a background in law enforcement, including as assistant commissioner of the Metropolitan...more
The National Crime Agency fought back against Lockbit this week, affecting the groups administrative environment. Coordinating with the FBI and international partners, the National Crime Agency (NCA) took control of...more
U.S. Companies Announce Crypto Cashback and NFT Ticketing Initiatives - According to recent reports, a major U.S. credit card company has partnered with Swoo, a mobile wallet blending traditional and crypto payments, to...more
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduces two new "pay away" exemptions to the principal money laundering offences in sections 327, 328 and 329 of the Proceeds of Crime Act 2002 (POCA)....more
This Note is the second part of our look at regulatory expectations for sanctions compliance in the U.K. The first part of our review looked at Financial Conduct Authority (“FCA”) systems and controls requirements. The focus...more