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 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'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
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
On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in...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
The UK Government issued new guidance in July 2021 on how it considers companies and individuals should approach the question of disclosure of suspicious activity reports (SARs) in English civil litigation. The guidance...more
Economic crime reform is firmly on the UK government’s agenda. What can we expect to see in the short to medium term which may impact businesses? A recent update provides some clues....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 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
Lonsdale v National Westminster Bank [2018] EWHC 1843 (QB) (18 July 2018) - A bank was ordered to disclose, to a customer, suspicious activity reports (SARs) that the bank had sent to the National Crime Agency (NCA) at the...more
The UK Government kicked off the New Year with a reminder that tackling economic crime remains top of its agenda. The Home Secretary and Chancellor announced last week that they will chair the new "Economic Crime Strategic...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 law and practice relating to financial crime and investigations is evolving fast. In the past 18 months we have seen two new Acts aimed at combatting financial crime (including the creation of two new corporate criminal...more
Two new corporate criminal offences come into force on 30 September 2017. The new offences can make a company criminally liable if it fails to prevent the facilitation of UK or non-UK tax evasion by an employee, agent or...more
In December 2016 we considered the changes proposed by the Criminal Finances Bill (the Bill) in "All change for money laundering regulation? - Impact for the private equity industry." On 27 April 2017, the Criminal Finances...more
The Criminal Finances Act 2017, which received Royal Assent last week, contains the largest expansion of UK corporate criminal liability since the Bribery Act 2010 and one of the most significant overhauls of money laundering...more
A number of very significant changes are being made to the UK anti-money laundering regime. Of particular interest to the private equity industry will be the proposed new criminal offence of failure to prevent 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
With the publication of the draft Criminal Finances Bill 2016-2017 on 13 October 2016, businesses have been put on notice of what stands to be the largest expansion of UK corporate criminal liability since the Bribery Act...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
The House of Commons Home Affairs Committee has published a report entitled ‘Proceeds of Crime’ in which it is highly critical of the efforts being made and systems in place in the UK to prevent money laundering and to...more
The insider trading trial of former SAC Capital official Matthew Martoma opened this week in Manhattan with jury selection. The SEC announced the resignation of George Canellos, Co-director of the Division of Enforcement....more