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Course correction: The Supreme Court’s decision in El-Khouri and its impact on extraterritoriality in money laundering cases

The UK Supreme Court has handed down its decision in El-Khouri (Appellant) v Government of the United States of America (Respondent). Amongst other things, the judgement has overturned the often-criticised Court of Appeal...more

A call to arms: The FCA highlights the ongoing risk of money laundering through the capital markets

The UK's capital markets are a vital economic driver, and also a significant source of money laundering risk. This is a difficult area of risk for regulators and law enforcement to understand and tackle, but progress is being...more

The Economic Impact of FATF Grey-Listing

The Financial Action Task Force ("FATF") is the global standard-setter on anti-money laundering ("AML"), countering terrorist financing ("CFT") and counter proliferation financing. FATF's standards, also referred to as...more

The Upcoming Expansion of Corporate Criminal Liability in the UK

After several years of discussion and consultation, the UK Government now appears to be close to reforming the law on corporate criminal liability via the Economic Crime and Corporate Transparency Bill. These changes, if...more

Money Laundering Issues in the Art Market

In February 2023, the Financial Action Task Force (“FATF”), the global standard-setter on Anti-Money Laundering policy, issued a report describing the financial crime risks in the art and antiquities market, as well as good...more

UK Money Laundering: Crossing the Million SAR Threshold

Firms that act as financial gate-keepers have obligations to report suspicions or knowledge of money laundering via Suspicious Activity Reports to the National Crime Agency ("NCA"). SARs have been filed for almost 20 years...more

Corporate Liability for Terrorist Financing

Terrorist financing comes at a price – and in the case of a global building supplies manufacturer that has pleaded guilty in a US court to making payments to terrorist organisations, that price is USD 778 million in fines and...more

Dealing with Account Freezing and Account Forfeiture Orders

In January 2018, UK law enforcement agencies were granted new powers to pursue the forfeiture of assets. Unexplained wealth orders ("UWOs") initially grabbed the media's attention, but the relative ease with which UK law...more

SAR Reform: Law Commission publishes report

The Law Commission has published its much anticipated report on reform of the UK's anti-money laundering and terrorism financing regime, and in particular of the system of suspicious activity reports ("SARs"). The proposed...more

Proposed reform of UK corporate criminal liability – a failure to grasp the nettle?

Following mounting calls for reform of the UK's corporate criminal liability regime, the Government is expected to consult later this year on potential reforms, which are likely to include a new corporate offence of failing...more

AML Information Sharing in a Technology-Enabled and Privacy-Conscious World

Financial firms play an integral role in preventing, identifying, investigating and reporting criminal activity, including terrorist financing, money laundering, and many other finance-related crimes. It is a critical role...more

SAR Reform: The Case of Causey and its Effect

The UK Government kicked off the New Year with a reminder that tackling economic crime remains top of its agenda. The Home Secretary and Chancellor announced last week that they will chair the new "Economic Crime Strategic...more

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