Formation of new anti-corruption alliance in Europe and what it means for international enforcement - On 20 March 2025, the UK Serious Fraud Office (SFO), French Parquet National Financier (PNF) and the Office of the...more
The Economic Crime and Corporate Transparency Act 2023 (the “ECCTA”) introduced a corporate ‘failure to prevent fraud’ offence providing that ‘large’ organisations may be held criminally liable if an ‘associate’ (such as an...more
Guidance clarifies the implementation date, scope, and application of landmark new corporate offence, and provides suggestions for fraud-prevention procedures. On 6 November 2024, the UK Home Office published...more
The UK government is moving towards introducing a new corporate criminal offence: Failure to Prevent Fraud and Money Laundering. The draft offence, contained in the Economic Crime and Corporate Transparency Bill, would hold...more
The UK Government is expanding the scope of the Serious Fraud Office’s (SFO) power to compel individuals and companies to provide information before a formal SFO investigation is commenced. Currently the power can only be...more
After several years of discussion and consultation, the UK Government now appears to be close to reforming the law on corporate criminal liability via the Economic Crime and Corporate Transparency Bill. These changes, if...more
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 January 2018 the Criminal Finances Act 2017 (“the Act”) came into force. The Act brought in a number of important legal developments, including Asset Freezing and Forfeiture Orders (“AFFOs”) and the offence of failure to...more
In a landmark case last month, a businessman linked to notorious criminals surrendered £10 million in property, land, cash and other assets at the conclusion of an unexplained wealth order (UWO). This was the first successful...more
Two Birds, One Stone: Addressing COO and DAC6 Risks in Tandem - UK Criminal Finances Act 2017 (CFA) and the EU Directive on Administrative Cooperation (DAC6) compliance matters are likely to come under increased scrutiny...more
A Court Ruling that May Resonate Across the Globe - The High Court in London recently struck down three “Unexplained Wealth Orders” that U.K. law enforcement had hoped would foil an alleged money laundering scheme by...more
Corporate criminal offences (CCOs) under Part 3 Criminal Finances Act 2017 (CFA) are increasingly coming under the spotlight of the UK tax authorities. In a 10 February 2020 press release published in response to a Freedom of...more
The year 2019 has been something of a mixed bag for the UK’s criminal and regulatory authorities. While the Serious Fraud Office (“SFO”) and Financial Conduct Authority (“FCA”) appear to have taken involuntary sabbaticals...more
The government published in May 2019 its responses to two Committee reports on financial crime. First, the House of Commons Treasury Committee on 8 March 2019, published its report on “Economic Crime – Anti-money laundering...more
Five years ago, in the spring of 2014, Deferred Prosecution Agreements ('DPAs') were first introduced in the UK through the Crime and Courts Act 2013 ('CCA').1 Since then, the Serious Fraud Office ('SFO') has concluded four...more
Corruption Watch UK has claimed that “a company committing economic crime in the US is far more likely to be hit with criminal, civil and regulatory penalties than one in the UK.” In a hard-hitting report published on 5 March...more
The British Parliament has recently published two important post-legislative assessments of the effectiveness of the UK’s financial crime legislative framework, as well as an insight into future areas of focus....more
Following mounting calls for reform of the UK's corporate criminal liability regime, the Government is expected to consult later this year on potential reforms, which are likely to include a new corporate offence of failing...more
Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more
On 6th December 2018, the trial of two Tesco executives accused of false accounting collapsed. The judge concluded that the SFO's evidence, taken at its highest, was such that a jury could not properly convict. The SFO...more
The UK National Crime Agency (“NCA”) has successfully resisted a challenge to the issue of its first Unexplained Wealth Orders (“UWOs”). The victory comes shortly after the agency announced its intention to expand the use of...more
Law enforcement authorities in the U.K. have obtained a new instrument in their fight against crime. Starting Jan. 31, 2018, U.K. enforcement authorities can apply for court orders against individuals suspected of being...more
In recent years, the rise of multi-jurisdictional investigations and corresponding multi-jurisdictional settlements has changed the enforcement landscape. Notable examples include the tri-lateral settlements of Odebrecht and...more
From 31 January 2018, UK enforcement authorities may apply for court orders against persons suspected of being involved in or connected to serious crime or "politically exposed persons" ("PEP") outside the European Economic...more
Featured is a reminder regading action needed on legacy protected rights rules and new briefings on New offences under the Criminal Finances Act 2017; Reducing your PPF levy; VAT and pension schemes; and an updated briefing...more