Compliance Tip of the Day: Citibank and Continuous Monitoring
Business Better Podcast Episode: FinCEN’s Notice of Proposed Regulations to Strengthen and Modernize AML/CFT Compliance Programs
Crypto Year in Review 2022: Crypto Enforcement and the U.S. Treasury - The Crypto Exchange Podcast
Senate Judiciary Committee Chairman Chuck Grassley (R-IA) and Senator John Fetterman (D-PA) have introduced the Art Market Integrity Act (AMIA) in Congress....more
In July 2025 HM Treasury and the Home Office issued the UK National Risk Assessment of Money Laundering and Terrorist Financing 2025 ('NRA 2025'), while the European Banking Authority (EBA) published its fifth Opinion on...more
The Wolfsberg Group (the Group) has released a statement reaffirming its commitment to the risk-based approach (RBA) for financial crime risk management. Further to its 2006 RBA guidance, and in line with the Financial Action...more
HM Treasury has published its latest 2025 National Risk Assessment (NRA) of Money Laundering and Terrorist Financing, offering a comprehensive review of the UK's exposure to financial crime. Building on the 2015, 2017, and...more
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more
On 12 February 2025, the UK Supreme Court handed down its decision in El-Khouri v Government of the United States of America (El-Khouri), declining to extradite Joseph El-Khouri to the US. The ruling marks a pivotal moment in...more
On 5 February 2025, Skadden hosted a series of panel discussions looking at the evolving EU, UK and US crypto-asset landscape... The discussion explored how market participants and investors can best anticipate and prepare...more
The Financial Conduct Authority has published a report on assessing and reducing the risk of Money Laundering Through the Markets. Money Laundering Through the Markets is the use of capital markets to launder criminally...more
At present, Cryptoassets are largely unregulated in the UK. However, the growth of crypto cannot be ignored and many argue that regulators need to take action to ensure adequate consumer protections are in place and to...more
The U.K. Financial Conduct Authority has published a policy statement on changes to its financial crime guide, following its consultation in April. The changes cover the following areas: (i) sanctions—to reflect information...more
The Financial Conduct Authority has published finalized guidance for payment service providers that enables a risk-based approach to processing suspected fraudulent payments. Following the publication of the Payment Services...more
The U.K. Financial Conduct Authority has published a speech by Emily Shepperd, FCA Chief Operating Officer, on the FCA's strategy for 2025 to 2030. In the speech, Ms. Shepperd sets out the four main themes of the FCA's...more
Jersey and Guernsey (collectively, the "Channel Islands") remain popular for both private equity buyout structures of UK and international corporate groups across various industries and asset classes, and for leverage...more
The U.K. Financial Conduct Authority has announced that it is revising the market cleanliness statistic used in its annual report to measure insider trading. In future, the FCA will: (i) detect abnormal price movements that...more
HM Treasury has updated its money laundering advisory notice on high-risk third countries. Under the U.K. Money Laundering Regulations, the U.K. regulated sector must apply enhanced customer due diligence in relation to...more
The Financial Action Taskforce has published a consultation paper on revisions to its anti-money laundering and counterterrorism financing standards relating to financial inclusion. The consultation is part of FATF's program...more
The U.K.'s Home Office has published guidance on the new corporate criminal offense of failure to prevent fraud under the Economic Crime and Corporate Transparency Act 2023. Under the offense, large organizations may be held...more
The Economic Crime and Corporate Transparency Act 2023 (Commencement No. 3) Regulations 2024 have been published. The Regulations bring into force certain provisions of the Economic Crime and Corporate Transparency Act 2023....more
The Financial Action Taskforce has published the outcomes from its plenary meeting, which took place between October 23 and 25, 2024. Outcomes include: - the approval of the last two assessment reports in the FATF's...more
The FCA has announced that it is interviewing 20 'finfluencers' under caution who may be touting financial services products illegally. 'Finfluencers' are social media personalities who use their platform to promote financial...more
Jersey is a well-established jurisdiction of choice for issuing debt securities in international finance transactions. Recently, we have seen a steady increase in interest in Jersey debt securities issuers either for a...more
The Joint Money Laundering Steering Group has published the amended version to Part II Sector 18 (wholesale markets) of its AML/CTF guidance for the financial services sector...more
In July 2024, the UK’s Financial Conduct Authority (“FCA”) published its “Quarterly Consultation Paper No. 44” (“Consultation”), which proposed introducing a requirement to provide criminal background checks on owners and...more
The Office of Financial Sanctions Implementation has published a financial sanctions notice reminding firms of their annual frozen assets reporting requirement. Every year HM Treasury carries out a review to update its...more
The Personal Information Protection Act ("PIPA") comes into full force on 1 January 2025. All organisations in Bermuda are expected to be in compliance with it by that date – time is running out! The Privacy Commissioner...more