The Serious Fraud Office (SFO) recently published its new five-year strategy for 2024-2029 (the Strategy), setting out its ambitious aspirations to become a “pre-eminent specialist, innovative and collaborative agency which...more
7/23/2024
/ Anti-Fraud Provisions ,
Bribery ,
Corporate Counsel ,
Corruption ,
Criminal Prosecution ,
Financial Crimes ,
Fraud ,
Incentives ,
Serious Fraud Office (SFO) ,
UK ,
Whistleblowers ,
White Collar Crimes
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
The following alert provides an update on recent sanctions developments, including: The publication of the UK government’s first sanctions strategy. The announcement of over 50 new sanctions. Measures to strengthen the Oil...more
4/12/2024
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Imports ,
New Regulations ,
Oil & Gas ,
Regulatory Oversight ,
Russia ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
Trade Relations ,
UK
In October, the Court of Appeal suggested all companies operating in Russia could be considered to be sanctioned under UK law because they are potentially controlled by President Putin. This caused understandable alarm to...more
Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more
11/21/2023
/ Bribery ,
Compliance ,
Corporate Liability ,
Corporate Transparency Act ,
Criminal Liability ,
Criminal Prosecution ,
Due Diligence ,
Fraud ,
Money Laundering ,
Risk Assessment ,
Senior Managers ,
UK ,
White Collar Crimes
A non-binding passage in a recent Court of Appeal judgment has suggested that any company based in or incorporated in Russia could be subject to the same UK sanctions as Vladimir Putin. The UK Foreign, Commonwealth and...more
Introduction - Since the Russian invasion of Ukraine in February 2022 the UK has introduced an unprecedented number and variety of sanctions. The FCA has recently assessed the sanctions controls of over 90 financial service...more
On 2 August 2023, the Register of Overseas Entities (ROE) update process went live. UK Companies House issued guidance on the requirements overseas entities will have to adhere to in their annual update of the ROE. Our...more
It is no great secret that criminal enforcement in the United Kingdom against corporations has lagged behind our counterparts in the United States and other jurisdictions. In recent years the UK government has introduced a...more
July was another busy month for sanctions in the United Kingdom. We have prepared a briefing on the key recent developments and suggested practical steps for companies and legal professionals to assist in understanding the...more
The United Kingdom export control authorities continue escalating sanctions and export controls in relation to Russia and Belarus. We have summarised below the key points from some of the most recent developments and provided...more
On 4 May 2023, the Bank of England (BOE) and the Prudential Regulation Authority (PRA) published a consultation paper on the proposed changes to their enforcement procedures and policies. The consultation is due to close on 4...more
In a set of actions in coordination with G7 allies, US and UK export control authorities recently announced significant escalations of sanctions and export controls against Russia and Belarus. These actions indicate continued...more
Introduction - On Wednesday, 1 February 2023, HM Treasury announced its intention to regulate a variety of crypto-asset activities under the UK financial services regulatory regime. The announcement arrived in the form of a...more
A recent judgment by London’s Commercial Court has shed light on the effect of Russian sanctions on ongoing litigation in the United Kingdom (UK). The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) provides the main...more
The following alert provides an update on recent sanctions developments including: 1. A £30,000 fine imposed for breaches of UK sanctions; 2. The expansion of the prohibition on providing professional services to persons...more
On Thursday 10 November 2022, the UK Office of Financial Sanctions Implementation (OFSI), published its 2021-2022 annual review, highlighting its shift towards a more proactive rather than reactive compliance and enforcement...more
The ability to maintain effective and accurate recordkeeping, a key method of ensuring market integrity, has been tested in recent years. The widespread use of personal mobile devices, instant messaging services, and general...more
The Financial Conduct Authority’s (FCA) expectations for challenger banks provide lessons for all in the financial service industry. Challenger banks, offering updated consumer experiences and disrupting standard practice...more
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
On 17 May 2022 the UK Financial Conduct Authority (FCA) made an appeal for people to report to it regarding firms on the Financial Services Register or other FCA registers, or companies with UK listed securities that have...more
On Wednesday 4 May, Foreign Secretary Liz Truss announced a ban on the export of services by UK persons or entities to businesses in Russia. Prohibited services include accountancy, management consultancy, and public...more
Russia’s invasion of Ukraine and subsequent revelations of alleged atrocities in territories previously controlled by Russia have had a global impact. Dozens of foreign countries (States) have imposed a wide variety of...more
4/20/2022
/ Blocking Sanctions ,
Economic Sanctions ,
EU ,
Financial Transactions ,
Foreign Investment ,
Foreign Policy ,
Popular ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
What is it? On 15 March 2022 the Economic Crime (Transparency and Enforcement) Act 2022 (the Act) received royal assent, having been expedited through parliament as part of the United Kingdom’s response to Russia’s invasion...more
As the Financial Conduct Authority (FCA) attempted to mitigate the effect of COVID-19 on consumers and the market, enforcement investigations and action slowed. ...more