Introduction - The art market is characterised by high-value, portable items that can be bought and exchanged quickly and often confidentially. These features, which make the market inherently vulnerable to many types of...more
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
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
Economic crime reform is firmly on the UK government’s agenda. What can we expect to see in the short to medium term which may impact businesses? A recent update provides some clues....more
The Law Commission has published its much anticipated report on reform of the UK's anti-money laundering and terrorism financing regime, and in particular of the system of suspicious activity reports ("SARs"). The proposed...more
Lonsdale v National Westminster Bank [2018] EWHC 1843 (QB) (18 July 2018) - A bank was ordered to disclose, to a customer, suspicious activity reports (SARs) that the bank had sent to the National Crime Agency (NCA) at the...more
Canada legalised recreational cannabis in October 2018 and it may be that other countries follow suit. UK and US investors, and those who facilitate investments in legal recreational cannabis businesses overseas, need to be...more
The myriad—and conflicting—state, federal and international laws governing the burgeoning marijuana industry have created a complicated legal landscape for financial institutions. In the United States, most states have...more
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
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
In December 2016 we considered the changes proposed by the Criminal Finances Bill (the Bill) in "All change for money laundering regulation? - Impact for the private equity industry." On 27 April 2017, the Criminal Finances...more
A number of very significant changes are being made to the UK anti-money laundering regime. Of particular interest to the private equity industry will be the proposed new criminal offence of failure to prevent the...more