Chloe Fryer

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UK Supreme Court grants KBR Inc. leave to appeal against controversial decision on extraterritorial effect of Section 2 Notices

On 8 April 2019, the UK Supreme Court granted KBR Inc. leave to appeal against a decision that allows the SFO to compel certain foreign companies to hand over documents held overseas. The Supreme Court’s decision was published on 23 May 2019 (see here). KBR Inc. is appealing the judgment in R (on the application … Continue Reading

Mark Steward indicates it may be time for criminal prosecutions under the Money Laundering Regulations

In a recent speech, FCA Director of Enforcement and Market Oversight Mark Steward again made clear that the FCA is prepared to use its power to bring criminal proceedings for breaches of anti-money laundering (AML) obligations set out under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs … Continue Reading

Extra-territorial effect of Serious Fraud Office document requests

Introduction The judgment in R (on the application of KBR Inc) v The Director of the Serious Fraud Office [2018] EWHC 2012 (Admin) came out on Thursday, 6 September 2018. In summary, the Administrative Court held that section 2(3) of the Criminal Justice Act 1987 (CJA), which (broadly) gives the SFO power to require a … Continue Reading