Following on from the UK Financial Reporting Council (FRC) publishing its plan and budget for 2024-25 earlier this year, the King’s Speech in July signalled that the long-awaited transition of the FRC to a new Audit, Reporting and Governance Authority could now be firmly on the horizon. In an effort to strengthen audit
Indirect Governance and Sanctions Risk Exposure in Decentralised Finance (DeFi)
As the FinTech industry continues to experience increased regulation across multiple jurisdictions, the focus of sanctions authorities is turning to decentralised finance (DeFi) and those operating in the crypto space. In the US we have seen a wave of recent enforcement actions against participants in the crypto sector and strong statements from authorities
Fit for purpose? The UK’s Treasury Committee scrutinises UK sanctions
In March 2022, a year after Russia’s invasion of Ukraine, the Treasury Committee published a report regarding the development, implementation and impact of economic sanctions on Russia (the 2022 Report). In brief, the 2022 Report found that:
New briefing note: FRC enforcement – five key themes for 2024
With a record number of enforcement cases resolved in recent years, the Financial Reporting Council (FRC) is continuing to show its determination to hold firms and individuals to account for serious accounting and audit failures. In our latest briefing, we set out five key themes for relevant firms and individuals to be aware
New UK civil enforcement authority created to investigate violations of trade sanctions
The UK’s Industry and Economic Security Minister, Nusrat Ghani, today announced the creation of a new civil enforcement unit, the Office of Trade Sanctions Implementation (OTSI). OTSI is expected to become operational early next year, and will focus on the civil enforcement of trade sanctions, including in relation to the circumvention or evasion
Horizon Scanning – Investigations and Enforcement – November 2023
Introduction
As anticipated in our previous horizon scan (see here), the end of 2023 has brought about significant developments in financial crime enforcement and a real focus on fraud. Looking ahead to 2024, we predict that developments affecting organisations doing business in the UK will include:
- a focus from organisations on fraud, in particular
Initial steps to take on discovery of a sanctions breach
Introduction
Following the unprecedented levels of sanctions activity in response to Russia’s invasion of Ukraine, which has resulted in companies dealing with the most significant and complex sanctions regimes across multiple jurisdictions, authorities in the US, UK and EU are now turning their attention to enforcement of those sanctions.
Sanctions authorities have indicated that they
UK investigations and financial crime: Horizon Scanning
As anticipated in our previous blog post on predictions for 2023, this year has brought about significant developments in investigations and a real focus on fraud. Looking ahead to the second half of 2023, we predict that developments affecting UK business or those doing business in the UK will include:
- continued reform of corporate criminal
Financial crime investigations in the UK: looking ahead to 2023
As we enter a recession against the backdrop of ongoing geopolitical instability, we expect to see significant financial crime enforcement and investigations in 2023, including a focus on emerging areas such as ESG, cryptocurrencies, and significant developments in financial sanctions. We predict that developments in 2023 will include:
- a renewed focus on fraud, including further