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Welcome to Allen & Overy’s Investigations Insight blog, sharing with you our views and insights into the latest trends, risks and developments in business crime and financial services investigations

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

Anti-Money Laundering: HMRC raises its game

The UK’s fight against money laundering is not breaking news. In particular, the regulatory spotlight has increasingly been focused on anti-money laundering (AML) compliance. In light of HM Revenue & Customs’ (HMRC) largest ever fine against the money transmitter Touma Foreign Exchange Ltd (Touma), the question arises of whether the enforcement spotlight is shifting away Read More

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

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

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