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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

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

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

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

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

SARS extended moratorium period used sparingly, reveals NCA report

The NCA Suspicious Activity Reports Annual Report 2019 reports that the NCA received a record number of SARs, including over 50% more requests for a Defence Against Money Laundering (DAML). While the number of DAML SARs that are granted remains high, the use of a new power to extend the moratorium period to up to Read More