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UK Options for Whistleblower Financial Incentive Programmes in Economic Crime Investigations

On 13th February 2024, in a wide-ranging speech, the Director of the UK Serious Fraud Office (SFO), Nick Ephgrave, publicly stated his provisional support for financial incentives to whistleblowers in allegations of...more

Failure to Prevent Fraud: Cohen & Gresser Assesses the Consequences of Imminent UK Corporate Fraud Liability Reform

What is happening? The Economic Crime and Corporate Transparency Bill (the “Bill”) is currently going through the UK Parliament. On 11 April 2023, the Government introduced a draft amendment that will create a new...more

The UK’s Insolvency Service Reports on Recent Director Disqualification Enforcement Activity

Introduction - On 18 April 2023, the UK’s Insolvency Service (“TIS”) published statistics on its enforcement activities and outcomes during the last financial year (the “Report”). The Report describes TIS’s enforcement...more

Non-Financial Misconduct reassessed in light of Frensham v The Financial Conduct Authority. If in doubt, disclose!

Introduction - The UK Financial Conduct Authority (the “FCA”) issued a prohibition order against Mr Frensham based on his conviction for an offence which did not involve financial fraud or dishonesty and was unrelated to...more

Firm Chat Application Policy: The Consequences of the UK FCA’s 2020 Prosecution of Konstantin Vishnyak

The need for tighter control on employees’ use of chat applications when conducting or discussing company business. What we learned from the FCA’s 2020 Vishnyak prosecution and the FCA’s reminder about the need to record...more

The FCA Final Notice on Redcentric PLC – Does it Signal the Enforcement Zeitgeist of the COVID-19 Period?

At the end of June 2020, the Financial Conduct Authority (the “FCA”) issued a public censure to Redcentric PLC for market abuse resulting from significant accounting errors. The resolution is particularly eye-catching because...more

Legal Risks and Practical Considerations for Company Directors During the COVID-19 Crisis

Introduction - The COVID-19 pandemic presents directors of all business entities with a profound and unprecedented set of challenges. Now more than ever, key decision-takers in businesses appreciate that their actions will...more

The New UK Anti-Money Laundering Regulations: How Will The Art World Be Impacted?

On 10 January 2020 the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (the “2019 Regulations”) came into force in the UK, implementing the EU’s fifth Money Laundering Directive (“MLD5”) and amending the...more

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