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Financial crime

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

“Strong and prompt enforcement” under Nikhil Rathi, new Chief Executive of the FCA

Nikhil Rathi[1] gave evidence last week to the Treasury Committee following the announcement on 22 June that he will be the new permanent Chief Executive of the UK Financial Conduct Authority (FCA) in Autumn 2020. Commentators have noted that likely priorities for Mr Rathi will be the Covid-19 debt burden, post-Brexit regulation, consumer protection and Read More

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The French anti-corruption policy: more settlements with corporations and harsher prosecutions against individuals

Recent guidelines from the French Minister of Justice reveal a heightened willingness of French authorities to combat corruption-related offences and to prosecute more individuals. The guidance, contained in a Circular, also strongly encourages corporations to voluntarily self-disclose internal suspicions of corrupt practices. A call for self-reporting The Circular calls for self-reporting by corporations, stressing that Read More

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Active U.S. enforcement of anti-money laundering rules continues unabated

In January 2020, the U.S. Department of the Treasury issued its National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). This document details the key priorities of the U.S. government regarding the enforcement of the Bank Secrecy Act (BSA) and its broader agenda on efforts related to anti-money laundering and the combating the Read More

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Cross-border information sharing within corporate groups

The UK HM Treasury and Home Office have issued a joint statement and guidance on cross-border information-sharing within corporate groups for the purpose of combating economic crime. Echoing the previous sentiments of the Economic Crime Plan 2019, the guidance makes clear that effective and diligent practice in intra-group cross-border data sharing is critical for identifying Read More

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FCA enforcement priorities during and after the pandemic

A number of weeks into the Covid-19 pandemic, the FCA has, as you would expect, produced guidance and information for firms, including warnings in this week’s Market Watch 63 about FCA expectations around market conduct. So have the FCA’s enforcement priorities changed? In short, no. But they have adjusted. The FCA’s Covid-19 webpage updates the Read More

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