The publication of the Independent Review of the Criminal Courts in June 2025 marks a significant attempt to reshape the structure, governance and workload of England and Wales' criminal justice system. The Review has clear...more
The Financial Conduct Authority (“the FCA”) has published final guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes, which updates its Guidance issued in 2017 (“the 2017...more
In our first article in this series, we explored the expanded mandatory and discretionary exclusion grounds under the Procurement Act 2023 (the "Act"). The Act doesn't just expand the grounds for exclusion. It also changes...more
On 9 June 2025, the U.S. Department of Justice (DOJ) published revised guidance for the enforcement of the Foreign Corrupt Practices Act (FCPA). Much attention has been paid to the apparent “unpausing” of enforcement...more
The Serious Fraud Office’s evolving approach to corporate engagement took another step forward this month. On 12 June 2025, speaking at a London conference, the SFO’s Chief Investigator Michael Gallagher provided the...more
The Procurement Act 2023 (the "Act") introduces a more expansive and centralised exclusion regime. For compliance professionals, the implications are significant: exclusion can now arise from a broader range of conduct –...more
On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more
4/25/2025
/ Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Fraud ,
Regulatory Reform ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
On 16 December 2024, the FCA published a discussion paper (DP24/4) (the “Discussion Paper”) on admissions and disclosures and market abuse regimes for cryptoassets. This is part of a series of publications by the FCA (and the...more
The FCA has published its expectations on registered or regulated firms partnering with unregistered cryptoasset firms, which may be illegally promoting to UK consumers....more
On 1 September 2025, the corporate criminal offence of ‘failure to prevent fraud’ (“the Offence”), created by the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”), will come into force. On 6 November 2024, the...more
On 27 June 2024, the Court of Appeal handed down judgment in World Uyghur Congress v National Crime Agency [2024] EWCA Civ 715. The challenge of a 2023 decision by the High Court was brought by World Uyghur Congress ("WUC")...more
The UK Financial Conduct Authority (FCA) has brought criminal charges against nine individuals in relation to an unauthorised foreign exchange trading scheme promoted on social media....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
It’s certainly true that the UK criminal authorities have been crying out for a shot in the arm in the form of legislative reform, but will changing the law really help the Serious Fraud Office ("SFO") achieve more corporate...more
Companies operating in the UK – whether incorporated in the UK or simply carrying on a business in the UK are entering into a period of significant change in the way corporate crime is going to be investigated and prosecuted....more
On 11 April 2023, the UK Government announced the introduction of a new corporate “failure to prevent fraud” offence, which will be brought into legislation through the Economic Crime and Corporate Transparency Bill (the...more
In a debate in the House of Commons on Wednesday 26 January 2023, MP Tom Tugendhat indicated that a major reform to corporate criminal liability is imminent. In this article, we take a look at why this reform has been called...more
Identifying and reporting instances of potential market abuse is required under the Market Abuse Regulation ('MAR'). A firm must have effective arrangements, systems and procedures in place to detect and report suspicious...more
Undertaking screening for negative news, also known as adverse news or adverse media, assists financial institutions to understand the risks posed by existing and prospective customers....more
In March of this year, Parliament fast-tracked the Economic Crime (Transparency and Enforcement) Act in response to Russia’s invasion of Ukraine. The Act received royal assent on 15 March 2022 and sets out measures to tackle...more
In recent years, the financial services industry has seen an exponential growth in the popularity of challenger banks in the UK. Digitally-driven, technologically innovative and efficient onboarding processes are some of the...more
A Director of Enforcement at the Financial Conduct Authority (FCA) has set out some of the key challenges the regulator expects in its new role as AML/CTF (anti-money laundering/counter terrorist financing) supervisor for...more
3/10/2020
/ AML/CFT ,
Anti-Money Laundering ,
CFTC ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
FATF ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Financial Markets ,
Financial Services Industry ,
Money Laundering ,
Popular ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Supervisory Guidance ,
Terrorist Financing Regulations ,
UK