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Reform

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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Australia looks to simplify and broaden its approach on corporate and executive criminal responsibility

The Australian Law Reform Commission (ALRC) has authored a discussion paper into criminal responsibility in Australia. Amongst other things, the paper proposes reforms to how liability is attributed to corporations and their senior executives. The discussion paper follows several inquiries into corporate behaviour and regulation, including the recent Royal Commission into Misconduct in the Banking, 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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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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Pressure mounting for new failure to prevent economic crime corporate criminal offence

“Multi-national firms appear beyond the scope of legislation designed to counter economic crime.” This was the damning conclusion of a House of Commons Treasury Committee report on Economic Crime published last week. Those hoping that the UK government has forgotten about its manifesto commitment to reform corporate liability for economic crime will be disappointed. Recent Read More

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