The Bribery Act: To Disclose or Not To Disclose?
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 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 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
Firms that act as financial gate-keepers have obligations to report suspicions or knowledge of money laundering via Suspicious Activity Reports to the National Crime Agency ("NCA"). SARs have been filed for almost 20 years...more
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations, and regulatory enforcement from the last three months. With this month marking half a year since the UK left the EU,...more
In a landmark case last month, a businessman linked to notorious criminals surrendered £10 million in property, land, cash and other assets at the conclusion of an unexplained wealth order (UWO). This was the first successful...more
On 8 April 2020, the High Court discharged three Unexplained Wealth Orders (“UWOs”) relating to multi-million pound London homes allegedly purchased with the proceeds of crime. In its judgment, the High Court criticised the...more
The criminal justice system in England and Wales, as in other nations, is severely impacted by Covid-19, and is under immense pressure. This extends beyond the investigation and prosecution of criminal activity surrounding...more
Organization Excels at Niche Branding but Stumbles in Avoiding Enforcement - The first paragraph of the press release sums it up: Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action...more