News & Analysis as of

Proceeds of Crime Act 2002 (POCA) Financial Crimes

Skadden, Arps, Slate, Meagher & Flom LLP

UK Crime and Policing Bill: New Measures To Facilitate Prosecution of Companies and High-Net-Worth Individuals

Key Points - If the Crime and Policing Bill (CPB) is enacted in current form, it will make it significantly easier for companies to be held liable for criminal offences committed by their senior managers. Coupled with the...more

Walkers

Understanding the changes to the Proceeds of Crime Act: Insights from our conversation with the FRA

Walkers on

Businesses must be aware of the three core money laundering offences: concealing, arranging and acquiring (use and possession) criminal property. The FRA has issued a seven-day working period to consider all defence...more

Latham & Watkins LLP

UK Supreme Court Ruling in El-Khouri: Defining the Territorial Boundaries of the Proceeds of Crime Act 2002

Latham & Watkins LLP on

The ruling, which narrows the UK’s jurisdiction over money laundering offences, will impact how cross-border money laundering offences are prosecuted going forward....more

White & Case LLP

Course correction: The Supreme Court’s decision in El-Khouri and its impact on extraterritoriality in money laundering cases

White & Case LLP on

The UK Supreme Court has handed down its decision in El-Khouri (Appellant) v Government of the United States of America (Respondent). Amongst other things, the judgement has overturned the often-criticised Court of Appeal...more

Walkers

Update to the Cayman Islands Proceeds of Crime Act – Changes to the suspicious activity reporting provisions

Walkers on

Amendments to the Cayman Islands Proceeds of Crime Act came into effect on 2 January 2025 and include revisions to the suspicious activity report (SAR) process to the Financial Reporting Authority (FRA). In addition to a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Significant UK Court of Appeal Decision Confirms the Applicability of the UK’s Proceeds of Crime Legislation to Illegality in...

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

Hogan Lovells

No DAML, no trouble: Two new “pay away” exemptions under the UK Proceeds of Crime Act 2002

Hogan Lovells on

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

Jenner & Block

Client Alert: World Uyghur Congress v Secretary of State for the Home Department: Can Forced Labour Goods Cause UK Money...

Jenner & Block on

On 20 January 2023, the High Court in London issued a historic judgment in relation to the World Uyghur Congress’ (WUC) challenge to the UK government’s failure to investigate the importation of cotton produced in China’s...more

Latham & Watkins LLP

UK Economic Crime Bill to Reform Companies House

Latham & Watkins LLP on

The UK government is taking further measures to tackle economic crime in the UK, reforming its corporate register, and giving extra powers to the Serious Fraud Office. The UK has published the new Economic Crime and...more

A&O Shearman

Disclosure of Suspicious Activity Reports (SARs) in civil litigation

A&O Shearman on

The UK Government issued new guidance in July 2021 on how it considers companies and individuals should approach the question of disclosure of suspicious activity reports (SARs) in English civil litigation. The guidance...more

White & Case LLP

Dealing with Account Freezing and Account Forfeiture Orders

White & Case LLP on

In January 2018, UK law enforcement agencies were granted new powers to pursue the forfeiture of assets. Unexplained wealth orders ("UWOs") initially grabbed the media's attention, but the relative ease with which UK law...more

WilmerHale

UWOs three years on: Underused and overpriced

WilmerHale on

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

WilmerHale

Can Kicking and Buck Passing: Reform of Corporate Criminal Liability

WilmerHale on

In January 2017, the UK Government issued a consultation paper calling for evidence on reforming corporate criminal liability for economic crime. Nearly four years later, on 3 November 2020, the Government’s response was...more

White & Case LLP

SAR Reform: The Case of Causey and its Effect

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The UK Government kicked off the New Year with a reminder that tackling economic crime remains top of its agenda. The Home Secretary and Chancellor announced last week that they will chair the new "Economic Crime Strategic...more

Latham & Watkins LLP

UK To Provide Compensation for Overseas Victims of Economic Crimes

Latham & Watkins LLP on

A new UK policy establishes a commitment to providing victims of overseas bribery with compensation; however, important questions remain that will impact implementation. The UK’s Serious Fraud Office (SFO), the Crown...more

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