The UK’s Serious Fraud Office (SFO) published its strategy for 2024–2029 on 18 April 2024, outlining its ambitious plans to become the “pre-eminent specialist, innovative and collaborative agency” in the fight against serious...more
On 13 February 2024, Nick Ephgrave gave his inaugural public speech as the new Director of the UK’s Serious Fraud Office (SFO). With a background in law enforcement, including as assistant commissioner of the Metropolitan...more
On January 30, 2024, Transparency International (TI) published its annual Corruption Perceptions Index (CPI) for 2023. The 2023 CPI suggests there has been limited progress in the global fight against corruption, with TI...more
2/8/2024
/ Anti-Corruption ,
Bribery ,
China ,
Corruption ,
Foreign Corrupt Practices Act (FCPA) ,
Indonesia ,
Malaysia ,
Money Laundering ,
Supply Chain ,
Transparency International ,
White Collar Crimes
Headlines-
• The Economic Crime and Corporate Transparency Act (the “Act”) is part of a wide legislative package to prevent abuse of UK corporate structures and tackle economic crime and received Royal Assent on 26 October...more
10/30/2023
/ CEOs ,
Corporate Crimes ,
Corporate Transparency Act ,
Criminal Liability ,
Failure to Prevent ,
Financial Crimes ,
Financial Markets ,
Fraud ,
Impact Assessments ,
Ministry of Justice ,
Senior Managers ,
Serious Fraud Office (SFO) ,
UK ,
UK Bribery Act
In recent weeks, the use of encrypted messaging applications for business purposes has returned to the spotlight. In July 2023, legal challenges surrounding the disclosure of messages on devices used by former Prime Minister...more
9/5/2023
/ Capital Requirements Regulation (CRR) ,
Confidential Information ,
Data Recording ,
Disclosure ,
Encryption ,
Financial Conduct Authority (FCA) ,
Information Commissioner's Office (ICO) ,
Instant Messaging Apps ,
Integrity Policies ,
Money Laundering ,
Prudential Regulation Authority (PRA) ,
Terrorist Financing Regulations ,
UK
The UK government has tabled an amendment to the Economic Crime and Corporate Transparency Bill so as to introduce a “failure to prevent” fraud offence. Details in the amended bill provide the greatest clarity to date of the...more
In a recent decision, the English High Court has demonstrated its willingness to interpret contractual provisions broadly so as to enable performance in circumstances where the imposition of sanctions on a counterparty...more
The Singapore High Court recently ruled that a party to a Singapore law-governed contract was justified in relying on a sanctions clause in the contract to refuse payment to the counterparty in an effort to avoid breaching...more
On January 31, 2023, Transparency International (TI) published its annual Corruption Perceptions Index (CPI) for 2022. As in recent years, the 2022 CPI demonstrates that more must be done to combat corruption globally – with...more
The UK government has proposed new registration requirements for foreign influence activities in the UK as part of its attempts to strengthen the resilience of the UK’s political system and democratic institutions against...more
On 13 July 2022, the National Economic Crime Centre, a multi-agency unit in the National Crime Agency (NCA), and the Office of Financial Sanctions Implementation, working in conjunction with law enforcement and financial...more
On 25 April 2022, in collaboration with the UK Independent Anti-Slavery Commissioner, the Financial Reporting Council (“FRC”) published a report on Modern Slavery Reporting Practices in the UK (the “Report”). ...more
As the world watches in horror as the Russian invasion of Ukraine continues to unfold, the UK, as well as its allies and partners, has introduced a number of sanctions and trade restrictions in response. In this Quarterly...more
4/28/2022
/ Bribery ,
Central Bank of Russia ,
Criminal Convictions ,
Cyber Attacks ,
Financial Conduct Authority (FCA) ,
Memorandum of Understanding ,
NCSC ,
Popular ,
Russia ,
Sanctions ,
Serious Fraud Office (SFO) ,
UK ,
Ukraine
At a time when sanctions are very much in the spotlight, the UK government has proposed amendments to its sanctions regime in order to introduce a ‘strict civil liability’ test for sanctions breaches....more
In the wake of Russia’s invasion of Ukraine, the UK government has brought forward legislation that aims to crack down on foreign owners laundering dirty money through UK property and make it easier for law enforcement...more
The UK government has widened the scope of its Russia sanctions regulations in anticipation of a Russian invasion of Ukraine. The amendments to the existing Russia sanctions regulations significantly broaden the definition of...more
On January 25, 2022, Transparency International (TI) published its annual Corruption Perceptions Index (CPI) for 2021.[1] Similar to previous years’ indices, the CPI 2021 demonstrates that corruption levels, including in the...more
In the final Quarterly Review of 2021, we reflect on a year that has seen the UK acclimatise to life outside of the EU, whilst, like the rest of the world, contending with the difficulties brought on by the global coronavirus...more
12/15/2021
/ Anti-Bribery ,
Bribery ,
Coronavirus/COVID-19 ,
Credit Suisse ,
Deferred Prosecution Agreements ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Fraud ,
Office of Financial Sanctions Implementation (OFSI) ,
Sanctions ,
Serious Fraud Office (SFO) ,
UK ,
UK Brexit
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
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)
As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more
2/18/2021
/ Audits ,
Citizenship ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Foreign Subsidiaries ,
Information Technology ,
Licenses ,
Nexus ,
Office of Foreign Assets Control (OFAC) ,
Remediation ,
Sanctions