Anita Clifford

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A UK Eye on US AML Reform
Recent reform of anti-money laundering law in the US has implications for the UK. Foreign bank account subpoenas and cross-border SAR sharing is permitted.
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Anita Clifford Bright Line Law
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Anita Clifford in Insurance Day on Sanctions
On 4 February Anita Clifford, Barrister and Principal Associate, was published in Insurance Day commenting on the post-Brexit UK sanctions regime and likelihood of more assertive enforcement action.
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Anita Clifford
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Anita Clifford on furlough fraud in BBC News and BBC Radio 5 Live
Barrister and Principal Associate Anita Clifford commented on how furlough fraud can be committed and what companies can do to avoid enforcement action on BBC Radio 5 Live ‘Wake up to Money’ on 13 January 2020.
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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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