Introduction
On 6 November 2024 the UK government published its long-anticipated guidance on the failure to prevent fraud offence (the Guidance).
The new offence will come into force in September 2025. It will apply both to UK and to non-UK organisations, where there is some nexus to the UK. The only defence for an
The resolution of two sanctions-related investigations over the last month by both the Financial Conduct Authority (FCA) and the Office of Financial Sanctions Implementation (OFSI) could signal the start of the anticipated increase in UK enforcement in respect of failings relating to financial sanctions systems and controls (in the case of
The UK failure to prevent fraud offence has been long awaited. We are receiving a number of queries from clients about when the UK government’s “reasonable procedures” guidance is due to be published, when the offence will come into force and what they should be doing now to prepare.
In short:
The SFO has published its 5-year strategy document (the Strategy Document), highlighting a number of areas of focus, from international coordination with counterparts to capitalising on technology and incentivising their workforce.
This follows Director of the SFO, Nick Ephgrave’s, speech in February 2024 setting out key priorities (see our recent Investigations and Enforcement horizon
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:
Summary
There has been a recent trend of greater regulatory enforcement for international companies that “carry on a business (or part of a business) in the UK”. We have set out in this article the relevant UK legislation and authorities that can enforce against international companies, with a particular focus on how these
Summary
As part of a new anti-corruption package announced on 3 May 2023, the European Commission has proposed a new directive (Directive) which, if implemented, would require EU member states (Member States) to meet common standards in their anti-corruption legislation.
More detail on the EU’s anti-corruption package, including the proposed new
On 30 March 2023, the UK Government published its Economic Crime Plan for 2023 – 2026 (the Plan), which sets out a number of measures intended to enhance the UK’s regulatory framework and strengthen its response to the threat of economic crime. The Plan makes clear the Government’s intention to rely increasingly on the