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New German legislation on corporate sanctions and internal investigations taking shape

The German Federal Ministry of Justice has prepared a draft bill of a Corporate Sanctions Act (Draft Bill). If enacted in its current draft form, it will significantly affect the prosecution of corporate crimes and the legal framework for conducting internal investigations in Germany.  We take a look at the Draft Bill’s most important aspects. Read More

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Things you might have missed from the FCA’s enforcement action against Carphone Warehouse

The UK Financial Conduct Authority’s (FCA) enforcement action against Carphone Warehouse (CPW) featured the second focused resolution agreement that the FCA has entered into. Importantly, this is the first focused resolution agreement that has resulted in a change being made to the financial penalty that the FCA imposed. However, relatively little air time has been Read More

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Financial and economic crime in the UK: what’s on the horizon

The past month has seen the promise of yet more developments to the UK’s ever-evolving financial and economic crime framework. In particular, the FCA has published proposed amendments to its Financial Crime Guide and the influential Treasury Select Committee has announced an inquiry into economic crime. Meanwhile, the UK’s recently enhanced economic crime toolkit is deployed Read More

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Unexplained Wealth Orders (and remainder of the Criminal Finances Act) come into force

  You have the right to remain silent. However – under changes to the Proceeds of Crime Act 2002 – it may cost you. With effect from 31 January 2018, the Criminal Finances Act 2017 introduces an Unexplained Wealth Orders regime in the UK.   What are Unexplained Wealth Orders? An Unexplained Wealth Order (UWO) Read More

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