In this article, we examine the potential impact on organisations managing global supply chains of the recent Court of Appeal judgement in the case against the National Crime Agency (NCA) brought by the World Uyghur Congress...more
In this week’s edition we discuss the implications of a decision against the National Crime Agency, which the UK’s Court of Appeal held had misinterpreted the law when it refused to investigate whether imported cotton was...more
Why is this case important? The case challenged a decision by the National Crime Agency (“NCA”) not to carry out investigations into whether consignments of cotton goods were the product of alleged forced labour and/or other...more
The ruling propels UK law enforcement to increase its investigative powers under POCA, and businesses to enhance their supply chain due diligence. On 27 June 2024, the UK Court of Appeal found that the National Crime...more
Introduction Potential criminal activity in international supply chains can create reputational, civil, and criminal risks. This can be particularly difficult to manage when there are many links in a chain from the source of...more
A recent English court ruling has shed light on the approach of UK enforcement authorities to the question of money laundering risks where there is potential forced labour / modern slavery in a supply chain. The ruling will...more
The National Crime Agency (NCA) in the UK has indicated a willingness to investigate companies that import goods made or assembled by forced labourers on the grounds that those products may constitute the proceeds of crime....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 2017, the UK Government issued a consultation paper calling for evidence on reforming corporate criminal liability for economic crime. Nearly four years later, on 3 November 2020, the Government’s response was...more
- There is increasing regulatory, commercial and media attention in the U.K. and the EU regarding the role of human rights in company supply chains. - The U.K. and the EU are introducing specific measures around human...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
New UK asset forfeiture law empowers prosecutors to seize assets held by companies that have unknowingly benefited from, or assisted, gross human rights abuses—even in the past. The new law creates potential corporate...more
On 15 July 2016, the Home Affairs Committee published a report on the Proceeds of Crime. The report identifies a number of systemic problems with the current confiscation order system and makes several recommendations...more