Reform – UK

UK National Economic Crime Centre: a period of stability for UK economic crime, but is it enough?

Christian Parker

In December 2017, the UK Government announced creation of a new National Economic Crime Centre (NECC) as part of the Government’s Anti-Corruption Strategy (ACS). Amber Rudd’s announcement outlined that the UK will introduce a multi-agency NECC, and formalised the UK’s approach to economic crime, in an attempt to ensure the UK maintains its “reputation as Read More

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OPBAS, the UK’s new anti-money laundering supervisor, becomes operational

Calum Macdonald

A new year, a new role for the Financial Conduct Authority (FCA). On 18 January 2018, the UK’s new Office for Professional Body Anti-Money Laundering Supervision (OPBAS) comes into effect. OPBAS is intended to be a ‘supervisor of supervisors’ with the aim of ensuring that professional body anti-money laundering supervisors comply with the UK’s anti-money Read More

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A slow start to enforcement activity under the UK SMCR

Sarah Hitchins

Attempts made by the UK Financial Conduct Authority (the FCA) to reassure the industry that the UK Senior Managers and Certification Regime (the SMCR) is not ‘all about enforcement’ have been met with some scepticism. However, that scepticism may have been misplaced, in light of the latest figures from the FCA regarding the number of Senior Read More

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Hard lessons from the English court on legal professional privilege

Stacey McEvoy

​Financial institutions engaged in cross-border business are increasingly at risk of being caught in the middle of a complex web of internal, regulatory and criminal investigations as well as civil litigation and employment claims when something has gone wrong. These may be conducted simultaneously or at different times, but they will often arise out of Read More

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A&O SMCR reflections: Don’t overlook these things when considering employee conduct and performance issues

Sarah Hitchins

A lot of time has been spent by some firms managing conduct and performance issues under the UK Senior Managers and Certification Regime (the SMCR) over the past 15 months. In our second blog post looking at these issues (the last one is available here), we highlight key areas that firms should not lose sight Read More

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