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Europe: UK FCA Confirms the Circumstances in Which it May Make Public Announcements About Live Investigations

We discussed in an earlier blog that the United Kingdom’s Financial Conduct Authority has axed proposed “name and shame” rules, retaining only an ability to make a public announcement about an investigation in “exceptional...more

European Union Adopts 18th Sanctions Package Against Russia

On 18 July 2025, the Council of the European Union adopted additional measures which have been introduced in its 18th sanctions package in response to the ongoing conflict in Ukraine (the Package)....more

OFSI's Enforcement Playbook is Being Redrafted: What This Potential Reform Means for You

On 22 July 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) launched a major consultation proposing wide-ranging enhancements to its civil enforcement framework (the Consultation). The Consultation is open...more

Key Takeaways: Secondary Sanctions—United Kingdom Issues Sanctions Guidance for Non-UK Businesses

On 14 July 2025, the United Kingdom’s Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on...more

The FCA's Developing Approach to Nonfinancial Misconduct by Individuals in the Financial Services Sector

On 2 July 2025, the United Kingdom (UK) Financial Conduct Authority (FCA) published a Consultation Paper and Policy Statement (CP25/18) on tackling non-financial misconduct in financial services....more

What You Need to Know About the United Kingdom Issuing Sanctions Guidance for Non-UK Businesses

The United Kingdom’s Foreign, Commonwealth and Development Office has published guidance on United Kingdom’s Russia sanctions compliance for non-UK businesses operating outside the United Kingdom (the Guidance). It also...more

Key Takeaways From the UK Financial Conduct Authority's Revised Enforcement Guide

Following a two-part consultation, which began in February 2024 (i.e., CP 24/2 and CP 24/2: Part 2) and was accompanied by a Policy Statement (PS25/5) setting out the UK Financial Conduct Authority’s (FCA) consultation...more

Key Compliance Tips on How to Respond to Information Requests From OFSI

On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more

FCA Backpedals: "Name and Shame" and Diversity and Inclusion Requirements Axed, and Non-financial Misconduct Rules Delayed

The United Kingdom’s Financial Conduct Authority (FCA) has announced significant changes to its regulatory approach, including dropping the obligation to “name and shame” firms under investigation, dropping the proposed...more

EU Sanctions—Article 8a “Best Efforts” Explained

On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. A notable addition was made to Article 8a of Council Regulation (EU) No...more

Europe: Are the UK FCA’s Revised “Name and Shame” Proposals an Improvement?

In November 2024, the UK FCA released a Consultation which seeks to clarify its proposed approach to publicising ongoing enforcement action—dubbed the “name and shame” plan—and to assure the wider market of the plan’s...more

The FCA's Part 2 of Its "Name and Shame" Proposals: What You Need to Know

On 27 February 2024, the Financial Conduct Authority (FCA) published its Consultation Paper CP24/2, which revealed the FCA’s new intended approach to publicised enforcement action. This was quickly dubbed the “name and shame”...more

Article 8a "Best Efforts" Explained

On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. The package introduced new anti-circumvention measures to strengthen...more

Lessons on Effective Financial Crime Controls: The Starling Bank Example

The Financial Conduct Authority (FCA) recently levied a jaw-dropping £29 million fine against Starling Bank (Starling). The fine follows an investigation by the regulator, which exposed the bank's "shockingly lax" sanctions...more

UK Office of Trade Sanctions Implementation New Enforcement Powers and Increased Reporting Obligations

On 12 September 2024, the UK government released the new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), which will come into force on 10 October 2024. The Regulations grant the...more

EU and UK Sanctions Briefing: The Luxury Goods Sector

The Impact of the EU and UK Russian Sanctions Regime on the Luxury Goods Sector - As the EU and UK Russian sanctions regimes continue to evolve, export controls are now affecting industries previously not often subject to...more

The Year Ahead: The Financial Conduct Authority's Ambitious Enforcement Plans for 2024/2025

In 2022, for the first time, the Financial Conduct Authority (FCA) published a three-year strategy setting out three key themes for promoting positive change, namely: (1) reducing and preventing serious financial harm and...more

Lessons to be Learned – FCA Fines JLT Specialty Limited £7.8 Million for Financial Crime Control Failings

In June of this year, the Financial Conduct Authority (FCA) took enforcement action against JLT Specialty Limited (JLT) for the second time in the space of a decade. The fine of approximately £7.8 million is in response to...more

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