Anita Clifford

Data Sharing
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UK/US data sharing and the impact on financial crime
Speed read: On 3 October 2019 the UK and US signed a new data sharing agreement. So far, its benefits to the fight against terrorism and child exploitation have been in the spotlight. The agreement, however, casts the net widely...
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the weed in the garden of CBD & cannabis investment
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Proceeds of crime — the weed in the garden of CBD & cannabis investment
Speed read: Cannabis-related investment is on the rise. The market for CBD, a compound extracted from the cannabis plant, in the UK is forecast to be worth £16.5 billion over the next decade. CBD is not a controlled drug in...
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Law Commission Report
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Imperfect but here to stay — The SARs regime after the Law Commission Report
Speed read: The Law Commission’s Report on the SARs regime recommends tweaks rather than any substantive change. Two recommendations at least hold some practical potential. The call for statutory guidance presents an opportunity to shed light on the contours of...
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UK_AM_Law_After_Exit_Day
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What’s the deal? UK AML law after exit day
Speed read: Anita Clifford examines the changes to the UK AML regime to come into effect after the UK departs from the EU. The uncertainty surrounding the UK’s departure from the EU has meant myriad contingency plans have been developed...
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NCA National Crime Agency
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Stopping the side hustle: UK freezes foreign student accounts — harder than first thought?
Speed read: Anita Clifford explores the recent targeting of foreign student bank accounts for freezing pursuant to Part 5 of the Proceeds of Crime Act 2002. 95 accounts, totalling an estimated £3.6 million, were frozen in a single day on...
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Anita Clifford comments on recent AML action by European Commission
Speed read: EU officials took the unprecedented step on Thursday of directly ordering a member state’s financial regulator to improve its supervision of banks for anti-money laundering purposes. The European Commission, the executive arm of the European Union, told Malta’s...
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High Court dismisses application to discharge first Unexplained Wealth Order in the United Kingdom
Speed read: Anita Clifford considers the first test of the UWO provisions in the United Kingdom. On 3 October 2018, the High Court handed down judgment in NCA v Mrs A [2018] EWHC 2534 (Admin), the first application to set...
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Anita Clifford quoted on Unexplained Wealth Orders
Speed read: On 3 October 2018, the High Court handed down judgment in the first application to set aside an Unexplained Wealth Order (UWO) in the United Kingdom. The power to make a UWO, an investigative order which compels a...
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Terrorism_Finance
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Suspicion, terrorist funding and money laundering
Speed read: On 11 July 2018, the Supreme Court handed down R v AB and CD [2018] UKSC 36, an appeal of a pre-trial ruling on the test for ‘suspicion’ in the context of anti-terrorist financing. This piece distils the...
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forfeiture of cash high value assets bank accounts
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Closing the gap — forfeiture of cash, high value assets and bank accounts
Speed read: Anita Clifford examines the changes to the Part 5 civil recovery regime under the Proceeds of Crime Act 2002, focusing on the expanded definition of ‘cash’, the ‘listed asset’ regime and the power to freeze money in bank...
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