On the second anniversary of the start of the war in Ukraine and in response to the death of activist Aleksey Navalny in a Russian prison, the United States, European Union, and United Kingdom, along with Australia and...more
3/4/2024
/ Asset Freeze ,
Australia ,
Bureau of Industry and Security (BIS) ,
Canada ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Services Industry ,
India ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transportation Industry ,
Turkey ,
UK ,
Ukraine ,
United Arab Emirates (UAE) ,
US State Departments
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges.
The new...more
1/11/2024
/ Compliance ,
Economic Sanctions ,
EU ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Imports ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Russia ,
SDN List ,
Software ,
U.S. Treasury ,
UK
In a recent judgment, the English High Court for the first time ruled on a sanctions de-listing case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). Following the UK’s departure from the EU,...more
In 2022, the US, UK and EU all escalated their sanctions enforcement rhetoric. For example, senior US enforcement officials went so far as to describe sanctions as “the new FCPA” (referring to the US. Foreign Corrupt...more
2/17/2023
/ Civil Sanctions ,
Compliance ,
Economic Sanctions ,
Enforcement ,
EU ,
Liability ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Russia ,
UK ,
Ukraine
Key Takeaways -
The FCA has recently fined JLT Specialty Limited and Ghana International Bank for limitations in their financial crime systems and controls, specifically weaknesses relating to anti-money laundering (AML)...more
7/14/2022
/ AML/CFT ,
Anti-Money Laundering ,
Bribery ,
Corruption ,
Cryptoassets ,
Enforcement Actions ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Money Laundering ,
UK ,
White Collar Crimes
Introduction
In April 2022, the UK Financial Conduct Authority ("FCA") finalized new rules to encourage the disclosure of diversity data by listed companies, whether based in the UK or abroad. Across the pond, the U.S....more
7/1/2022
/ Corporate Governance ,
Diversity and Inclusion Standards (D&I) ,
Environmental Social & Governance (ESG) ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Services Industry ,
LGBTQ ,
Listing Rules ,
Nasdaq ,
Publicly-Traded Companies ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
UK
In the early hours of 15 March 2022, following a wait of almost five years, the UK Parliament introduced into law the Economic Crime (Transparency and Enforcement) Act (the "Act"). The Act was fast-tracked at an...more
3/22/2022
/ Anti-Corruption ,
Anti-Money Laundering ,
Corruption ,
Financial Crimes ,
Foreign Investment ,
Money Laundering ,
Pending Legislation ,
Regulatory Reform ,
Regulatory Standards ,
UK ,
Unexplained Wealth Orders (UWOs) ,
White Collar Crimes
Background As noted in our prior update, the United States, European Union and United Kingdom imposed a number of sanctions in connection with Russia’s recognition of the Donetsk and Luhansk regions of Ukraine. ...more
2/28/2022
/ Asset Freeze ,
Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin
Russia's Actions -
On February 21, 2022, Russian President Vladimir Putin signed two executive orders recognizing the DNR/LNR Regions as “sovereign and independent states.”...more
2/23/2022
/ Biden Administration ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
Vladimir Putin
Amid the uncertainty brought about by the end of the Brexit transition period and the ongoing COVID-19 pandemic, firms should be aware that the FCA will retain an active approach to financial crime and regulatory enforcement...more
2/16/2021
/ Asset Management ,
BSA/AML ,
Economic Sanctions ,
Enforcement Actions ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Financial Markets ,
Market Abuse ,
Senior Managers ,
Short Selling ,
UK
The Director-General of OLAF, Ville Itälä, has indicated in a recent interview that OLAF is seeking to coordinate more with authorities in EU Member States to increase the number of prosecutions brought for EU budget fraud....more
5/5/2020
/ Asset Management ,
Coronavirus/COVID-19 ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
EU ,
European Anti-Fraud Office (OLAF) ,
Financial Assistance Policies ,
Fraud ,
Health Care Providers ,
Publicly-Traded Companies ,
UK
The criminal justice system in England and Wales, as in other nations, is severely impacted by Covid-19, and is under immense pressure. This extends beyond the investigation and prosecution of criminal activity surrounding...more
4/26/2020
/ Coronavirus/COVID-19 ,
Corporate Misconduct ,
Criminal Investigations ,
Criminal Prosecution ,
Financial Crimes ,
Fraud ,
Interim Charging Protocol ,
National Crime Agency (NCA) ,
Popular ,
Risk Assessment ,
Risk Mitigation ,
Serious Fraud Office (SFO) ,
State of Emergency ,
UK
On 6 August 2019, the UK Serious Fraud Office (SFO), the prosecuting authority responsible for tackling serious or complex fraud and bribery in the UK, published updated guidance on corporate cooperation (the Guidance)....more