On 22 September 2022, the House of Commons published the Economic Crime and Corporate Transparency Bill (the Bill). Background The Bill is effectively the second part of a legislative package to prevent the abuse of UK corporate structures and tackle economic crime. It follows on from the Economic Crime (Transparency and Enforcement) Act 2022, which … Continue Reading
On 16 September 2022, the Joint Money Laundering Steering Group (JMLSG) published proposed amendments to part 1 of its guidance. The proposed revisions take account The Money Laundering and Terrorist Financing (Amendment)(High-risk Countries) Regulations 2022 and The Money laundering and Terrorist Financing (Amendment)(No.2) Regulations 2022. The following text will be affected: Paragraph 5.5.11 and Annex … Continue Reading
Ahead of the anticipated FCA policy statement and final rules on the changes to the Appointed Representatives regime, which were expected to be published in H1 2022, in this briefing paper we consider some of the steps that firms should be taking to prepare for the anticipated changes in the FCA’s final policy.… Continue Reading
On July 12, 2022 our financial services and risk advisory teams will be holding a panel discussion event on the key financial crime issues facing financial services firms. The event, held at our offices in 3 More London Riverside, will include a keynote speech by Louise Stanway, chair of the Joint Money Laundering Steering Group. … Continue Reading
On 12 July 2022, at 5pm to 7:30pm we are holding a financial crime panel event at our offices in 3 More London Riverside. Our financial regulation and risk advisory team will be joined by senior individuals from across the sector to discuss themes including anti-money laundering, sanctions, and market abuse, as well as the … Continue Reading
On July 12, 2022 our financial services and risk advisory teams will be holding a panel discussion event on the key financial crime issues facing financial services firms. The event, held at our offices in 3 More London Riverside, will include a keynote speech by Louise Stanway, chair of the Joint Money Laundering Steering Group. … Continue Reading
It has been reported that, in 2021, the FCA experienced a 52% increase in reports of “material” cyber security incidents and we expect this upward trend to continue into 2022. The rise in ransomware in particular was highlighted in the very recent paper published by UK Finance, which called on UK authorities to focus on … Continue Reading
Our latest 20 minute webinar will be taking place on 4 May at 9:00am and will explore the FCA’s Business Plan and future strategy. In particular, we will discuss the FCA’s newly-defined approach to: Reducing and preventing serious harm Setting and testing higher standards Promoting competition and positive change To attend this webinar, please click … Continue Reading
In this episode of our Beyond Sanctions series, Steve Hadwin (Director, Head of Operations – Information Governance, Privacy and Cybersecurity) and Haney Saadah (Head of Risk Consulting, EMEA) discuss the FCA’s recent announcement concerning cyber security in light of the events in Ukraine and what boards should be thinking about. The podcast is available to … Continue Reading
As a result of recent events in Ukraine, and the economic sanctions imposed on Russia, there are a number of potential issues facing financial institutions. Firms have, understandably, concentrated on the immediate sanctions issues facing their organisations but will increasingly need to focus on the broader governance and compliance issues and plan accordingly, with their … Continue Reading
Beyond Sanctions: Practical guidance for financial services firms series Introduction On 15 March 2022, the Economic Crime (Transparency and Enforcement) Bill (the Bill) received Royal Assent becoming the Economic Crime (Transparency and Enforcement) Act 2022 (the Act). The Act has been some time in the making and can be traced back to 2016 when … Continue Reading
On 14 March 2022, there was published on the FCA’s website a joint statement from the UK regulatory authorities on sanctions and the cryptoasset sector. In the statement the UK financial regulatory authorities reiterate that all UK financial services firms, including the cryptoasset sector, are expected to play their part in ensuring that sanctions are … Continue Reading
In the first instalment of our ‘Beyond Sanctions’, Jonathan Herbst and Haney Saadah consider market conduct issues in light of the developments in Ukraine and the UK’s Economic Crime Bill. The podcast is available to stream and download from the Norton Rose Fulbright website, Apple Podcasts and Spotify.… Continue Reading
We recently published a blog reporting on governance considerations for regulated firms in relation to Russian sanctions. As the sanctions landscape continues to evolve, impacted firms operating in different jurisdictions are grappling with overlapping and differing requirements, and global firms will need to ensure a coordinated approach across their operations. We have set out below … Continue Reading
Earlier this week we published a blog reporting on the FCA’s statement regarding the new financial sanctions that the UK has imposed on Russia. As the FCA identified in its statement, the imposition of sanctions creates a regulatory risk for firms and their staff (particularly senior managers) in the sense that, where the regulator identifies … Continue Reading
