On 21 October 2021, the UK Financial Conduct Authority (“FCA”) announced that it had fined Credit Suisse (the “Bank”) £147,190,200 for “serious financial crime due diligence failings” in connection with loans that the Bank...more
On 14 October 2021, the Office of Financial Sanctions Implementation (“OFSI”) published its annual review for the financial year 2020-2021 (the “Annual Review”). Under the leadership of its new Director, Giles Thomson,...more
In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more
10/7/2021
/ CAATSA ,
Foreign Entities ,
Germany ,
Joe Biden ,
National Interest Waiver ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
Trump Administration ,
US State Departments
During the course of the last three months, there has been a significant focus on the activity of the Serious Fraud Office (SFO). The SFO has achieved its objectives in some instances; see, for example, our article below...more
This alert considers the recent updates and guidance published by the UK’s Department for Business, Energy and Industrial Strategy (BEIS) regarding the UK’s National Security and Investment Act 2021 (the “Act”).
These...more
As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more
7/15/2021
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Exchanges ,
ITSR ,
Moneygram ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Treasury
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
6/28/2021
/ Anti-Corruption ,
Autonomy ,
Bribery ,
Coronavirus/COVID-19 ,
Financial Crimes ,
Financial Services Act ,
Financial Services Industry ,
Ministry of Justice ,
Money Laundering ,
National Crime Agency (NCA) ,
Popular ,
Regulatory Agenda ,
Sanctions ,
Serious Fraud Office (SFO) ,
UK ,
UK Brexit
On 26 April 2021, the UK’s first sanctions under the Global Anti-Corruption Sanctions Regulations 2021 (SI 2021/488) (“the Regulations”) came into force. The Regulations are made under the Sanctions and Anti-Money Laundering...more
5/21/2021
/ Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Corporate Counsel ,
Drug Trafficking ,
Foreign Policy ,
Human Rights ,
Latin America ,
Misappropriation ,
Proceeds of Crime Act 2002 (POCA) ,
Sanctions ,
South Africa ,
Sudan ,
Terrorist Acts ,
UK
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations, and regulatory enforcement from the last three months.
As the UK gets used to life outside the EU and implements...more
3/29/2021
/ Asset Freeze ,
Civil Monetary Penalty ,
Corporate Crimes ,
Corruption ,
Criminal Justice Act ,
EU ,
Financial Conduct Authority (FCA) ,
Foreign Corporations ,
HMRC ,
Human Rights ,
Money Laundering ,
NCAs ,
Popular ,
Sanctions ,
Serious Fraud Office (SFO) ,
Travel Ban ,
UK ,
UK Brexit ,
Unexplained Wealth Orders (UWOs)
The FCA has announced its first criminal prosecution under the UK’s Money Laundering Regulations. This is undoubtedly a very significant development for the FCA and should be seen as a warning to firms within scope of the...more
On 5 February 2021, the UK Supreme Court handed down its judgment in the case of SFO v KBR, in which it unanimously held that the Serious Fraud Office (SFO) cannot use its statutory power to gather information under section...more
A new report concludes that employees and organisations in the financial services industry do not see the crimes and human rights breaches described in the UK Modern Slavery Act 2015 as something they can prevent. The report...more
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations, and regulatory enforcement from the last three months. Please contact us if you would like to discuss any of these...more
12/15/2020
/ Anti-Corruption ,
Bribery ,
British Airways ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Financial Conduct Authority (FCA) ,
FSCS ,
General Data Protection Regulation (GDPR) ,
Life Sciences ,
Medicines and Healthcare Products Regulatory Agency (MHRA) ,
Memorandum of Understanding ,
Modern Slavery Act ,
National Crime Agency (NCA) ,
Office of Financial Sanctions Implementation (OFSI) ,
Popular ,
Serious Fraud Office (SFO) ,
Task Force on Climate-related Financial Disclosures (TCFD) ,
Trafficking ,
UK ,
UK Bribery Act
Over the past four years in the United States, there has been an increasing disconnect between public and private action on climate. The current administration de-prioritized (and many believe sabotaged) any efforts to...more
11/19/2020
/ Auditors ,
Carbon Emissions ,
Climate Change ,
Corporate Counsel ,
Corporate Governance ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Financial Reporting Council (FRC) ,
Greenhouse Gas Emissions ,
Paris Agreement ,
Reporting Requirements ,
Task Force on Climate-related Financial Disclosures (TCFD)
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations and regulatory enforcement from the last three months.
We commented last month that the scale of the impact of the...more
9/24/2020
/ Airbus ,
Bribery ,
Corruption ,
DPA ,
Enforcement ,
Espionage ,
Financial Conduct Authority (FCA) ,
Fraud ,
Global Human Rights Sanctions Regime ,
HMRC ,
Investigations ,
Money Laundering ,
National Economic Crime Center (NECC) ,
Popular ,
Regulatory Standards ,
Sanctions ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
Serious Fraud Office (SFO) ,
UK
Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more
8/7/2020
/ Charter ,
Coast Guard ,
Compliance ,
Cryptocurrency ,
Customs and Border Protection ,
Cyber Attacks ,
Due Diligence ,
Economic Sanctions ,
Exports ,
Imports ,
Insurance Industry ,
Maritime Transport ,
New Guidance ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Ports ,
Risk Assessment ,
Risk Management ,
Risk Mitigation ,
Sanction Violations ,
Shipping ,
U.S. Treasury ,
UK ,
Unions ,
Vessels
In our Quarterly Review, we bring you important UK developments relating to Business Crime, Investigations and Regulatory Enforcement from the last three months. Please contact us if you would like to discuss any of these...more
6/23/2020
/ Bring Your Own Device (BYOD) ,
Coronavirus/COVID-19 ,
Corporate Crimes ,
Cybersecurity ,
EU ,
Financial Conduct Authority (FCA) ,
NCAs ,
NCSC ,
Office of Financial Sanctions Implementation (OFSI) ,
Popular ,
Serious Fraud Office (SFO) ,
UK ,
Unexplained Wealth Orders (UWOs)
Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA) and the Payment Systems Regulator (PSR) published their 2020/21 business plans for on 7 April 2020, 9 April 2020 and 31 March 2020, respectively. This...more