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From ‘enabler’ to ‘game changer’: fighting financial crime with technology

Financial crime is big business. Serious organised crime facilitated by money laundering costs the UK £37 billion every year. The estimated annual cost of fraud is £190 billion. This is the current scale of the problem according to Megan Butler, Executive Director of Supervision at the UK Financial Conduct Authority (FCA). And rapid advances in Read More

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The UK FCA shines a light on personal account dealing

In its latest Market Watch newsletter, the FCA has reported on the ‘varied’ quality of firms’ personal account dealing (PAD) controls and set out points that it says all firms should consider when reviewing their PAD controls. The requirement for firms to have PAD controls The FCA requires firms to establish adequate PAD controls in Read More

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Employee interviews in internal investigations

Recent developments in the U.S., UK and Germany have cast a spotlight on the interplay between corporate internal investigation interviews and investigations by, and cooperation with, the authorities. Interviewing company employees is often a key part of an internal investigation. Despite most employees having little choice but to agree to give internal interviews, they are Read More

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The End of SEC Disgorgement?

In Kokesh v. SEC, 137 S. Ct. 1635 (2017), the U.S. Supreme Court held that disgorgement in SEC enforcement actions constitutes a penalty rather than equitable relief. Disgorgement requires a defendant to return the ill-gotten gains obtained as a result of his wrongdoing. The Supreme Court’s decision meant that SEC disgorgement now is subject to Read More

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U.S. DOJ Antitrust Division launches Procurement Collusion Strike Force

The U.S. Department of Justice’s Antitrust Division announced on 5 November 2019 that it has established the Procurement Collusion Strike Force (PCSF), a new task force designed to detect criminal anticompetitive behavior in government procurements. This comes off the back of recent statements from senior DOJ officials that the Division had plans to be more Read More

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