Anita Clifford

Typing on laptop
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Wrongful trading — a civil contravention with a money laundering implication?
Speed read: The wrongful trading suspension ended on 30 September 2020 and it is important that company directors keep in mind the offence in section 214 of the Insolvency Act 1986.
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American Flag
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The impact of a person’s OFAC designation in the UK
Speed read: Anita Clifford considers the scope for enforcement of OFAC designation against UK persons.
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Furlough-Fraud
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Furlough Fraud and Professional Advisers
Speed read: Fraud on employee support schemes is a focus for enforcement authorities in the United Kingdom, Australia and Canada.
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Grey book and pen
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Developments in POCA disclosure orders
Speed read: Anita Clifford considers the recent case of Faerman v SFO [2020] EWHC 1849 (Admin) which reinforced the jurisdictional limits of disclosure orders and need for careful scrutiny of orders made.
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AML and COVID-19
In the first webinar of the series Anita Clifford discusses the impact of the COVID-19 crisis on money laundering compliance, paying particular attention to the practical challenges to performing customer due diligence and the outer remit of the regulations in...
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Covid-19 & consequences for anti-money laundering
Speedread: Anita Clifford considers the implications for anti-money laundering and Customer Due Diligence following the shift towards virtual client relationships in response to the global health emergency.
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The vulnerability-of-management-consultants-to-an-offence-of-money-laundering
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The vulnerability of management consultants to an offence of money laundering
Speedread: Recent events suggest that management consultants are vulnerable to interacting with criminal property, thereby triggering a money laundering exposure under UK criminal law.
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The revamped Money Laundering Regulations 2017 in 2020: Five key changes
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The revamped Money Laundering Regulations 2017 in 2020: five key changes
Speed read: Amendments to the Money Laundering Regulations 2017, introduced by the Money Laundering Regulations 2019, entered into force on 10 January 2020.
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Account freezing orders — recent developments and challenges
Anita Clifford discusses recent trends in the UK account freezing regime. Anita analyses the legal framework to assess the ways an individual might challenge an account freezing or forfeiture order and draws on developments in the Jersey proceeds of crime...
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Bank Card
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Banking on account forfeiture — dramatic developments in the UK & Jersey
Speed read: The National Crime Agency’s recent success in the first major appeal of an account forfeiture order, coupled with the government’s 2019 Asset Recovery Plan, indicates that even greater use of Account Freezing / Forfeiture Orders ('AFOs') is on...
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