Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Recent Developments in Anti-Money Laundering - The Consumer Finance Podcast
Investment Management Update – Exit Strategies
The recent conviction of London-based art dealer Oghenochuko Ojiri marks a watershed moment for financial crime enforcement in the UK's regulated sector. For the first time, a conviction has been secured under section 21A of...more
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more
The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...more
The UK's capital markets are a vital economic driver, and also a significant source of money laundering risk. This is a difficult area of risk for regulators and law enforcement to understand and tackle, but progress is being...more
On 6 October 2023, the Financial Conduct Authority (“FCA”) updated its anti-money laundering (“AML”) and counter terrorist financing (“CTF”) regime webpage (“Webpage”) with useful feedback on good and poor quality...more
Key considerations for banks engaging with governments and peer institutions to improve financial crime compliance systems - Every year, banks spend billions of dollars on core financial crime compliance systems and are...more
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
FCA consults on updated mortgages tailored support guidance – Covid-19 On 5 March, the FCA published updated draft mortgages tailored support guidance for firms, to apply from 1 April at the expiration of the current...more
On 12 May 2020 the UK belatedly published its statement on cross-border information-sharing within corporate groups (the Statement). This one-page document primarily consists of general acknowledgements of the importance of...more
UK government encourages regulated firms to share customer information within corporate groups, highlighting interaction with firms’ obligations under the Proceeds of Crime Act 2002 and GDPR. The UK government has...more
On 10 January 2020, The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 came into force. As a result, letting agents are now supervised by HMRC for anti-money laundering and counter-terrorist financing...more
The UK Law Commission has published a report criticising existing anti-money laundering legislation and providing recommendations to improve the quality of Suspicious Activity Reports (SARs). What should we make of these...more
The U.K.'s Law Commission has published a report, entitled "Anti-money Laundering: the SARS Regime", setting out recommendations to improve the prevention, detection and prosecution of money laundering and terrorism financing...more
The Law Commission has published its much anticipated report on reform of the UK's anti-money laundering and terrorism financing regime, and in particular of the system of suspicious activity reports ("SARs"). The proposed...more
Canada legalised recreational cannabis in October 2018 and it may be that other countries follow suit. UK and US investors, and those who facilitate investments in legal recreational cannabis businesses overseas, need to be...more
The Financial Action Task Force (FATF) has awarded the UK its highest ranking globally for anti-money laundering (AML) and counter-terrorist financing (CTF) measures. In a report published in December 2018, FATF praised the...more
FATF has published its highly anticipated report on the effectiveness of the UK’s anti-money laundering and counter-terrorist financing measures. On 7 December 2018, the Financial Action Task Force (FATF) published its...more
“My message to facilitators is this: we’ve had a lot of focus on banks; now my investigators are going to be focusing on you.” This was the warning delivered by the Minister for State and Security to the so-called...more
The Law Commission has published a substantial consultation paper entitled "Anti-Money Laundering: the SARs Regime," seeking views on proposals to reform the law of England and Wales governing anti-money laundering. In...more
The UK Financial Conduct Authority (“FCA”) recently released its 2018/19 Business Plan. The Plan sets out the FCA’s priorities for the year ahead across multiple areas, including financial crime....more
On 30 September 2017, Part 3 of the UK Criminal Finances Act 2017 (the “CF Act”) came into force creating new corporate offences for failing to prevent the facilitation of UK or overseas tax evasion. Similar to the standard...more
“The UK has made significant improvements to its ability to detect foreign bribery, but could still do more by reforming out-of-date legislation and better utilizing existing resources.” On 23 March 2017, the...more
In this decision report we review the FCA’s action against Sonali Bank (UK) Ltd (Sonali Bank) and its money laundering reporting officer (MLRO), Steven Smith, in connection with failings identified in relation to Sonali...more
In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more
The UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law. The Government hopes that...more