Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
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
Report Offers Weak Insight on Causation but Lists Steps that Treasury Can and Should Take - The Department of Treasury (“DOT”) recently released its first ever strategy report (the “Strategy”) on the topic of de-risking,...more
In a recent judgment, the English High Court for the first time ruled on a sanctions de-listing case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). Following the UK’s departure from the EU,...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
- As of 1:00 p.m. BST July 6, 2020, the GHR Regulation came into force, representing the introduction of the U.K.’s long awaited GHR Regime. - The GHR Regime is the first standalone U.K. sanctions regime to be in current...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
Customer due diligence is a familiar phrase for many. But at a time when money laundering is estimated to represent between 2 - 5% of GDP globally, customer due diligence is set to change and the UK Government is at the...more