On 17 May 2023, the FCA published a speech given by Sarah Pritchard (FCA Executive Director of Markets, and Executive Director of International) entitled How to change in response to changing threats. Among other things the speech asks important questions regarding financial crime controls: Ms Pritchard states that these are important questions to ask – … Continue Reading
On 8 September 2022, the FCA published a new webpage on side pockets. The new webpage follows the FCA’s July 2022 Policy Statement on side pockets and discusses at a high level how they work and what investors can expect.… Continue Reading
On 28 July 2022, the Office of Financial Sanctions Implementation (OFSI) updated its general guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018. The guidance outlines firms’ obligations under financial sanctions, as well as OFSI’s approach to licensing and compliance issues. It takes into account relevant case law and guidance at the … Continue Reading
The sixth instalment of our Beyond Sanctions podcast series is now available to stream and download on Apple Podcasts and Spotify. In this episode, David Harris, Co-Head of our Contentious Financial Services Group in London, discusses some recent developments in the sanctions landscape for regulated firms, including key points from the: Red Alert on Financial Sanctions … Continue Reading
The Economic Crime (Transparency and Enforcement) Act 2022 (the Act), which came into force in March 2022, aimed amongst other things, to give UK sanctions authorities greater power to take enforcement action and impose penalties on persons that breach sanctions restrictions, through the introduction of a “strict liability” test. These new powers of the UK’s … Continue Reading
Whilst historically there have been relatively low levels of sanctions enforcement in the UK, in light of recent developments, in the coming months we expect to see more scrutiny in this area and increased enforcement activity in relation to sanctions breaches. In our latest briefing, first published on Thomson Reuters Regulatory Intelligence on 24th June … Continue Reading
