We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more
4/29/2025
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
UK
The Economic Crime and Corporate Transparency Act 2023 (the “ECCTA”) introduced a corporate ‘failure to prevent fraud’ offence providing that ‘large’ organisations may be held criminally liable if an ‘associate’ (such as an...more
On 27 September 2024, the Financial Conduct Authority (“FCA”), imposed a financial penalty of approximately £29 million on the British bank – Starling Bank Limited (“Starling”) – for failings related to its financial crime...more
On 12 September 2024, the UK Government published The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (“the Regulations”), which provide the regulatory framework for the Office of Trade Sanctions...more
9/26/2024
/ Criminal Liability ,
ECJU ,
Economic Sanctions ,
Enforcement ,
HMRC ,
New Regulations ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Prison ,
Russia ,
Security Breach ,
Trade Relations ,
UK
What U.K. Firms Need to Know -
INTRODUCTION -
Over the past decade, the use of messaging applications, such as WhatsApp, for business purposes as an alternative to traditional email has grown exponentially. Ease of use...more
1/23/2024
/ CFTC ,
Data Privacy ,
Data Retention ,
Employee Training ,
Enforcement ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Instant Messaging Apps ,
Mobile Devices ,
Professional Disciplinary Actions ,
Prudential Regulation Authority (PRA) ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Social Media ,
Surveillance ,
Technology Sector ,
UK
Traditionally in UK law, in order to hold a company criminally liable, enforcement authorities must prove wrongdoing by a senior person representing the company’s “controlling mind and will.” Through this “identification...more
Many of our clients are increasingly faced with internal investigations, some with complex compliance or whistleblowing features. Our April client alert looks at some of the key considerations before embarking upon any...more
Non-financial misconduct and the UK Senior Managers and Certification Regimen -
The old adage goes that, “What happens in Vegas, stays in Vegas.” But, does this really hold true in the UK financial services sector?...more
5/21/2019
/ #MeToo ,
Duty to Disclose ,
Employment Tribunals ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
Non-Disclosure Agreement ,
Personal Liability ,
Regulatory Standards ,
Risk Management ,
Senior Management Regime (SMR) ,
Settlement ,
Sexual Harassment ,
UK
In a paper published last month,[i] the UK’s Financial Conduct Authority (“FCA”) set out various cybersecurity insights gleaned from the work of cyber coordination groups (“CCGs”) the regulator established in 2017. The...more
4/4/2019
/ Bank of England ,
Banking Sector ,
Corporate Governance ,
Cyber Threats ,
Cybersecurity ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
Investment Management ,
Popular ,
Prudential Regulation Authority (PRA) ,
UK
Reporting overseas enforcement action against Senior Managers to the Prudential Regulation Authority.
On 7 November 2018, the Prudential Regulation Authority (“PRA”) issued two final notices against two individuals who had...more
In an eagerly awaited judgment, the English Court of Appeal has today overturned an earlier decision narrowing the scope of litigation privilege in criminal investigations in the UK. The Court of Appeal ruled that interview...more
Firms should consider the implications for their existing anti-market abuse controls and should consider responding to the consultation either directlyor through a relevant industry body.
On 5 April 2018, we reported in an...more