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Art, sanctions and suspicion: What the Ojiri case tells us about risk and responsibility in the regulated sector

The recent conviction of London-based art dealer Oghenochuko Ojiri marks a watershed moment for financial crime enforcement in the UK's regulated sector. For the first time, a conviction has been secured under section 21A of...more

PEP talk: The UK FCA issues final guidance on the treatment of politically exposed persons

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

Litigation activism confirms the risks of money laundering liability in supply chains

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

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

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

FCA sets out approach to AML crypto supervision

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

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