The UK Financial Conduct Authority’s (FCA) recent announcements indicate that private equity firms (PE Firms) will see increased regulatory scrutiny over their anti-money laundering (AML) systems and controls.
Earlier this year, the FCA issued a “Dear CEO” letter outlining its Alternatives Supervision Strategy, including its view of the key
Many companies have made significant donations of funds, goods and services as part of international relief efforts.
These efforts are of course to be applauded, but it is important to be mindful of the bribery and corruption risks presented by charitable donations, particularly in emerging markets, and to take proactive steps to manage legal and
On 1 June 2020, the US Department of Justice (DOJ) released the latest update to its ‘Evaluation of Corporate Compliance Programs’ policy, which was first released in 2017 (DOJ Guidance).
The DOJ Guidance provides companies with detailed guidance on how the DOJ will review the adequacy and effectiveness of
On 28 October 2019, the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, announced a £146,341 fine against Telia Carrier UK Limited (Telia) for indirectly facilitating international telephone calls to SyriaTel in violation of EU asset freeze sanctions against Syria (implemented in the UK under the Syria (European Union
On 21 January 2019, the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, issued a £5,000 fine against R. Raphael Bank & Sons plc, trading as Raphaels Bank, for dealing with £200 belonging to an unidentified designated person in violation of EU sanctions against Egypt (implemented in the UK under the Egypt (Asset-Freezing)
A US-based cosmetics company, e.l.f. Cosmetics, Inc. (ELF), has reached a USD 996,080 settlement with the US Office of Foreign Assets Control (OFAC) for importing 156 shipments of false eyelash kits containing materials sourced from North Korea in apparent violation of the North Korea Sanctions Regulations.
The materials were supplied by two of ELF’s China-based
We have published a briefing analysing the key proposals in the Law Commission’s consultation on the SARs regime. The link can be found here: