Anita Clifford

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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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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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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Data sharing server unit
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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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Cannabis
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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 library
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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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British Flag
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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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