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DAM(L’d) if you do, DAM(L’d) if you don’t – What should regulated firms be thinking about now the PoCA consent threshold has been...

On 10 July 2025, the UK raised the threshold below which certain regulated firms can perform acts that would otherwise constitute a money laundering offence. The new threshold is £3,000. This is the second rise in the...more

HMRC brings first prosecution under failure to prevent facilitation of tax evasion laws

HMRC has reportedly brought its first-ever corporate prosecution under the failure to prevent the facilitation of tax evasion offence, almost eight years after the legislation was introduced in the Criminal Finances Act 2017....more

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

The SFO’s prevention partnership with UK PLC: Balancing collaboration and enforcement

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

Raising the bar – Changes to mandatory and discretionary exclusions under the Procurement Act 2023

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

SFO's new self-reporting guidance: A new deal or a departure from justice?

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

UK cryptoasset regulation: FCA seeks feedback on admissions & disclosures, and market abuse regime

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

UK FCA on cryptoasset financial promotions and fiat-to-crypto on/off ramp services

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

The clock is ticking - UK Government publishes guidance on new ‘failure to prevent fraud’ offence

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

11/14/2024  /  Bribery , Fraud , Transparency , UK

UK: Finfluencers beware - The FCA is closing in

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

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

Reforming the legal test for Corporate Criminal Liability in England – a panacea or a placebo?

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

Is the UK entering into a new age of corporate crime enforcement?

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

UK Government to Introduce Long-Anticipated “Failure to Prevent Fraud” Offence

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

The UK Economic Crime and Corporate Transparency Bill – imminent reform to corporate criminal liability?

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

Market abuse surveillance: How to get it right

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

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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