Enforcement action

Set out below are thoughts from Allen & Overy’s market leading investigations team on issues relating to enforcement action taken by the FCA, as well as other regulators in the UK and overseas.

A steady hand on the tiller: how to build operational resilience

In a financial services sector heavily reliant on technology and subject to increasing numbers of cyber-attacks, how can firms hope to avoid operational disruption? This is the focus of a suite of consultation papers published on 5 December by the Prudential Regulation Authority (PRA), the Financial Conduct Authority (FCA), and the Bank of England. Although Read More

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Anti-Money Laundering: HMRC raises its game

The UK’s fight against money laundering is not breaking news. In particular, the regulatory spotlight has increasingly been focused on anti-money laundering (AML) compliance. In light of HM Revenue & Customs’ (HMRC) largest ever fine against the money transmitter Touma Foreign Exchange Ltd (Touma), the question arises of whether the enforcement spotlight is shifting away Read More

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The FCA confirms the number of open enforcement investigations into ‘non-financial misconduct’

It is now just over a year since Megan Butler wrote her letter to the UK Women and Equalities Committee which coined the (now common) phrase ‘non-financial misconduct’. Even before Megan Butler’s letter was published, many regulated firms were already looking at personal misconduct (especially sexual misconduct) committed by their employees through both employment and Read More

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International tier one telecoms carrier fined for sanctions breach

The UK financial sanctions enforcer, the Office of Financial Sanctions Implementation (OFSI), announced on 28 October a fine of a UK subsidiary of an international tier 1 telecoms carrier (the Company) for indirectly facilitating international telephone calls to SyriaTel, a designated entity under EU financial sanctions on Syria, implemented by the Syria (European Union Financial Sanctions) Read More

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New guidance about what to expect if self-reporting to the SFO

The Director of the SFO, Lisa Osofsky, confirmed back in April of this year that she would “soon be issuing guidance for corporates and their legal advisers to provide them with added transparency about what they might expect if they decide to self-report fraud or corruption to my office.” This Guidance was published as an Read More

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