On 21 July 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published a sector-specific Cryptoassets Threat Assessment (“the Report”), shedding light on the evolving risks and vulnerabilities in the crypto...more
8/6/2025
/ Anti-Money Laundering ,
Compliance Monitoring ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Economic Sanctions ,
Financial Conduct Authority (FCA) ,
FinTech ,
Office of Financial Sanctions Implementation (OFSI) ,
Risk Assessment ,
Risk Mitigation ,
UK
On 15 May 2025, the UK Government published the conclusions of its cross-government review of UK sanctions implementation and enforcement (the Review)....more
6/19/2025
/ Customs ,
Economic Sanctions ,
Enforcement ,
Enforcement Authority ,
Financial Institutions ,
FinCEN ,
HMRC ,
Information Reports ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Prudential Regulation Authority (PRA) ,
Reporting Requirements ,
UK ,
Whistleblowers
On April 24, 2025, the UK Serious Fraud Office (SFO) released new guidance to encourage companies to self-report suspected corporate wrongdoing. The guidance emphasises that prompt self-reporting combined with full...more
On 24 April 2025, the UK Serious Fraud Office (SFO) issued new guidance to encourage companies to self-report suspected corporate wrongdoing. The guidance states that self-reporting, combined with full cooperation with the...more
The UK Office of Financial Sanctions Implementation (OFSI) has imposed a penalty of £465,000 on the Moscow subsidiary of Herbert Smith Freehills (HSF) for breaches of UK financial sanctions imposed on Russia following the...more
Nick Ephgrave QPM, the Director of the Serious Fraud Office (“SFO”), recently marked the end of his first year in office. Ephgrave has brought a renewed energy, sense of purpose and proactive approach to the SFO, opening six...more
10/9/2024
/ Bribery ,
Corporate Crimes ,
Criminal Investigations ,
Criminal Liability ,
Federal Funding ,
Financial Crimes ,
Serious Fraud Office (SFO) ,
UK ,
UK Bribery Act ,
Whistleblower Protection Policies ,
Whistleblowers
Serious Fraud Office (SFO) Director Nick Ephgrave has consistently touted the benefits of offering financial rewards to whistleblowers. With the FCA also considering its position on financial incentivisation, and a supportive...more
8/8/2024
/ Cartels ,
CFTC ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Financial Conduct Authority (FCA) ,
HMRC ,
IRS ,
Regulatory Reform ,
Retaliation ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
UK ,
UK Competition and Markets Authority (CMA) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On 15 January 2024, legislation came into force that enhances the Serious Fraud Office’s (SFO) compulsory information-gathering powers and streamlines the investigative process whilst imposing fresh obligations on companies...more
The new SFO Director, Nick Ephgrave QPM, marks his first 100 days in post this month after succeeding Lisa Osofsky in September 2023. Ephgrave has overseen a dynamic start to his tenure with the announcement of three new...more
2023 has been a year of change at the SFO with a new Director, enhanced investigatory powers and new statutory regime that will make it easier to prosecute corporate criminal offenders. Dropped investigations and acquittals...more
On 20 July 2023, the UK Financial Conduct Authority (FCA) published its Annual Report and Accounts for the year ending March 2023 (the “Report”). The Report represents the first opportunity to assess progress made in the...more
On 4 November 2022, in the case of FCA v Papadimitrakopoulos & Gryparis1 , the UK High Court reaffirmed the principle that information obtained via Mutual Legal Assistance (MLA) requests can only be used for the purpose for...more
12/7/2022
/ Admissible Evidence ,
Consent ,
Criminal Investigations ,
Criminal Prosecution ,
Evidence ,
False Statements ,
Financial Conduct Authority (FCA) ,
Investigations ,
Law Enforcement ,
Mutual Legal Assistance Treaties (MLAT) ,
UK
On 25 March 2022, the European Commission and United States announced an agreement in principle on a new Trans-Atlantic Data Privacy Framework. If passed into law, the framework will facilitate the transfer of personal data...more
5/10/2022
/ Data Privacy ,
EU ,
EU-US Privacy Shield ,
European Commission ,
General Data Protection Regulation (GDPR) ,
Government Investigations ,
International Data Transfers ,
Schrems I & Schrems II ,
Standard Contractual Clauses ,
Surveillance ,
UK
On 9 December, to mark International Anti-Corruption Day, the OECD launched the snappily-named 2021 Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions (“the...more
12/21/2021
/ Anti-Corruption ,
Bribery ,
Corruption ,
Criminal Investigations ,
Enforcement ,
Foreign Official ,
Government Investigations ,
International Standards ,
OECD ,
Public Procurement Policies ,
Supply Chain ,
UK ,
White Collar Crimes
Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more
5/25/2021
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Corporate Misconduct ,
Criminal Convictions ,
Criminal Liability ,
Criminal Prosecution ,
Cross-Border ,
Deferred Prosecution Agreements ,
Enforcement ,
FOIA ,
Internal Controls ,
Jurisdiction ,
Law Enforcement ,
OECD ,
Serious Fraud Office (SFO) ,
UK ,
UK Bribery Act
While debate rumbles on over the extension of ‘failure to prevent’ offences into the broad spectrum of financial crime, including fraud and money laundering, some have called for their introduction into an altogether...more
The year 2019 has been something of a mixed bag for the UK’s criminal and regulatory authorities. While the Serious Fraud Office (“SFO”) and Financial Conduct Authority (“FCA”) appear to have taken involuntary sabbaticals...more
12/23/2019
/ Alstom ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Enforcement Statistics ,
Financial Conduct Authority (FCA) ,
Forfeiture ,
Freezing Order ,
GlaxoSmithKline ,
Insider Trading ,
Rolls-Royce ,
Serious Fraud Office (SFO) ,
Tesco ,
UK ,
UK Criminal Finances Act 2017 ,
Unexplained Wealth Orders (UWOs) ,
White Collar Crimes
Director of the Serious Fraud Office Lisa Osofsky used her annual Cambridge Symposium speech to emphasise the importance of international and corporate co-operation, to issue a call to arms for greater legislative assistance...more
The UK Law Commission has published a report criticising existing anti-money laundering legislation and providing recommendations to improve the quality of Suspicious Activity Reports (SARs). What should we make of these...more
The Director of the UK Serious Fraud Office (SFO), Lisa Osofsky, has promised to provide companies with concrete guidance on cooperation with the SFO. Based on her recent comments, this guidance is likely to encourage...more
What is the background to this DPA and why is it only now being published?
On 29 October 2014, the SFO opened an investigation into Tesco Stores Ltd in relation to a suspected offence of false accounting, contrary to...more
The UK National Crime Agency (“NCA”) has successfully resisted a challenge to the issue of its first Unexplained Wealth Orders (“UWOs”). The victory comes shortly after the agency announced its intention to expand the use of...more
On 31 July 2018, the Administrative Division of the High Court of England and Wales blocked the extradition of Stuart Scott to the United States. As the second case this year in which the High Court has blocked extradition to...more
On 9 May 2018, the UK House of Lords appointed a Select Committee, chaired by Lord Saville of Newdigate, to scrutinise the implementation and enforcement of the UK Bribery Act 2010 (“the Act”).
On 4 June 2018, the Ministry...more
On 5 February 2017, the UK High Court issued judgment in the case of Love v USA [2018] EWHC 172 (Admin) (“the Judgment”). This was an appeal against the decision at Westminster Magistrates’ Court on 16 September 2016....more