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Financial crime

Read thoughts from Allen & Overy on financial crime issues in the context of financial services investigations.

When criminal law affects your obligations to others

Looking back at 2019 there were a number of interesting English civil court rulings which highlighted the difficulties faced by a party trying to balance obligations (e.g. to a contractual counterparty, a customer or to the court) when there is suspected criminality or a clash with foreign criminal law.   Here are four which we found interesting: Read More

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UK AML changes in force today

Changes to the UK anti-money laundering regime come into force today, implementing the EU’s Fifth Anti-Money Laundering Directive (5MLD) and Financial Action Task Force (FAFT) recommendations.  We summarise  the key changes made to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) by the Money Laundering and Terrorist Read More

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Sanctions post-Brexit – avoid traps for the unwary

A new UK sanctions regime in a hard Brexit scenario is expected to broadly mirror that which is in place in the EU. However, there will be some key differences. Businesses should be alert to these differences in order not to breach any post-Brexit new UK sanctions or existing EU sanctions.  There are some real Read More

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SARS extended moratorium period used sparingly, reveals NCA report

The NCA Suspicious Activity Reports Annual Report 2019 reports that the NCA received a record number of SARs, including over 50% more requests for a Defence Against Money Laundering (DAML). While the number of DAML SARs that are granted remains high, the use of a new power to extend the moratorium period to up to 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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