The Bribery Act: To Disclose or Not To Disclose?
The National Crime Agency (NCA) and the UK Financial Conduct Authority (FCA) have jointly published a set of nine system priorities to combat economic crime in the UK, in line with the UK's second Economic Crime Plan and the...more
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduces two new "pay away" exemptions to the principal money laundering offences in sections 327, 328 and 329 of the Proceeds of Crime Act 2002 (POCA)....more
This Note is the second part of our look at regulatory expectations for sanctions compliance in the U.K. The first part of our review looked at Financial Conduct Authority (“FCA”) systems and controls requirements. The focus...more
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
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations, and regulatory enforcement from the last three months. With this month marking half a year since the UK left the EU,...more
On 8 April 2020, the High Court discharged three Unexplained Wealth Orders (“UWOs”) relating to multi-million pound London homes allegedly purchased with the proceeds of crime. In its judgment, the High Court criticised the...more
Organization Excels at Niche Branding but Stumbles in Avoiding Enforcement - The first paragraph of the press release sums it up: Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action...more