Continued compliance with Bermuda’s anti-money laundering (AML) and anti-terrorist financing (ATF) legislation, including regulations, policies and guidance notes issued by the Bermuda Monetary Authority (the BMA or the...more
The UK’s National Crime Agency (NCA) recently secured its first forfeiture of sanctioned funds. This was a landmark achievement for the NCA’s Combatting Kleptocracy Cell, which has only existed since 2022 and aims to...more
Welcome to the second instalment of 2024 of the Regulatory & Risk Advisory Review. In this edition we cover several Cayman Islands regulatory updates including updates to the Beneficial Ownership Transparency Act, the...more
The UK Financial Conduct Authority (FCA) has reminded firms supporting and facilitating unregistered cryptoasset firms of their obligations under the Proceeds of Crime Act 2002 (POCA), specifically highlighting how they may...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
Recent publications come in light of UK’s “greater autonomy” in setting AML and CTF regulations following Brexit. Background to the review - On 22 July 2021, HM Treasury published both a Call for Evidence on a review...more
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
In January 2018, UK law enforcement agencies were granted new powers to pursue the forfeiture of assets. Unexplained wealth orders ("UWOs") initially grabbed the media's attention, but the relative ease with which UK law...more
A new law, which came into force on 10 January, has ushered in material changes to the regulation of the art market, extending the application of the UK’s anti-money laundering legislation to the sector. The new law,...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
Canada legalised recreational cannabis in October 2018 and it may be that other countries follow suit. UK and US investors, and those who facilitate investments in legal recreational cannabis businesses overseas, need to be...more
The myriad—and conflicting—state, federal and international laws governing the burgeoning marijuana industry have created a complicated legal landscape for financial institutions. In the United States, most states have...more
The Law Commission has published a substantial consultation paper entitled "Anti-Money Laundering: the SARs Regime," seeking views on proposals to reform the law of England and Wales governing anti-money laundering. In...more
Following the use of a nerve agent in Salisbury earlier this year, there were calls for the UK to adopt a British equivalent to the US Global Magnitsky Act, enabling the state to sanction gross human rights violations...more