News & Analysis as of

Politically Exposed Person (PEPs) United Kingdom

A&O Shearman

PEP talk revisited: revised UK guidance on treatment of PEPs

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The UK Financial Conduct Authority (FCA) has issued finalised guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes. There is no significant shift in the FCA’s expectations of...more

Ropes & Gray LLP

Customer due diligence: HM Treasury outlines next steps on money laundering rules and FCA finalises PEPs guidance

Ropes & Gray LLP on

July saw a number of updates regarding the prevention of money laundering in the UK, reflecting the Government’s stated commitment to ensuring that compliance requirements are effective yet not unnecessarily onerous for the...more

Latham & Watkins LLP

FCA Findings on Firms’ Treatment of Politically Exposed Persons

Latham & Watkins LLP on

Regulator finds that firms could improve how they conduct anti-money laundering checks when dealing with UK PEPs. ...more

WilmerHale

The Financial Conduct Authority’s Review of Firms’ Approaches to Politically Exposed Persons

WilmerHale on

The UK Financial Conduct Authority (FCA) launched in September a review of the treatment of domestic politically exposed persons (PEPs) by UK-regulated financial services firms. This review will look at firms’ arrangements...more

Cohen & Gresser LLP

The Economic Crime Act: What will Change for Managers of Offshore Structures

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In the early hours of 15 March 2022, the Economic Crime (Transparency and Enforcement) Act (the “Act”) came into force. The rapid passage of the Act through the UK Parliament, after years of delays, came in response to...more

A&O Shearman

Mistaken breach of UK Financial Sanctions: possible exposure and what to do

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The UK sanctions imposed as a result of Russia’s invasion of Ukraine have undoubtedly put intense pressure on businesses to review existing commercial arrangements and tighten sanctions compliance systems and controls. But...more

King & Spalding

Anti-Money Laundering Implications for the Art Market in the UK

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Introduction - The art market is characterised by high-value, portable items that can be bought and exchanged quickly and often confidentially. These features, which make the market inherently vulnerable to many types of...more

A&O Shearman

UK FCA extends annual financial crime reporting obligation (REP-CRIM) to more firms

A&O Shearman on

The FCA is extending its existing annual financial crime reporting obligation (termed the “REP-CRIM” by the FCA) to a broader range of firm types.  The change is expected to impact approximately 4500 firms who were previously...more

Ballard Spahr LLP

U.K. Court Strikes Down “Unexplained Wealth Orders” By Parsing Facts and Making Value Judgments About Meaning of Corporate...

Ballard Spahr LLP on

A Court Ruling that May Resonate Across the Globe - The High Court in London recently struck down three “Unexplained Wealth Orders” that U.K. law enforcement had hoped would foil an alleged money laundering scheme by...more

K2 Integrity

The Unexplained Wealth Order Imperative: Always Keep Your Financial House in Order

K2 Integrity on

Fact: Many wealthy individuals and families are subject to higher levels of public, governmental, and legal scrutiny. It’s imperative that they keep their financial houses in order because at some point they’ll probably be...more

Orrick, Herrington & Sutcliffe LLP

Unexplained Wealth Orders High Court Dismisses First Legal Challenge

The English High Court has dismissed an application to discharge an "unexplained wealth order" ("UWO") against the wife of the former chairman of the International Bank of Azerbaijan....more

Morrison & Foerster LLP

The Money That Cost Too Much – Unexplained Wealth Orders (Update)

Morrison & Foerster LLP on

The target of the UK’s first unexplained wealth order (UWO) has been made public after reporting restrictions expired last week. Mrs Zamira Hajiyeva will now be required to provide the National Crime Agency with proof of the...more

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