Financial crime

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

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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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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U.S. continues aggressive sanctions and anti-money laundering enforcement against non-U.S. banks

When assessing anti-money laundering risk and exposure, global financial institutions should be mindful of the complex landscape and assertions of broad authority by U.S. authorities and banking regulators. U.S. banking regulators, in conjunction with U.S. criminal and civil authorities, have traditionally pursued anti-money laundering and sanctions enforcement cases against multinational banks in relation to conduct Read More

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