BLL Bulletin

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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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Benefitting from Criminal Conduct
Speed read: Jonathan Fisher QC considers the Law Commission’s Part 2 POCA reform proposal and implications for the SAR reporting.
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Financial Sanctions, Criminal Liability and POCA 2002
Circumvention offences establish criminal liability for breaches of financial sanctions. The potential engagement of the circumvention offences invites a review into whether the offences interact with the Proceeds of Crime Act 2002.
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Library Books
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Restoring confidence in the pre-pack?
Rachel Clark considers whether draft new regulations requiring scrutiny of pre-pack sales to connected parties will be enough to prevent fraud and restore confidence in the process.
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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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Cryptoasset_service_provider
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Cryptoasset service providers should plan, not panic
Speed read: The recent Financial Conduct Authority (FCA) ban on crypto-derivatives trading to retail consumers sent waves of commentary through the crypto world.
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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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Tax reporting
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Tax reporting under DAC 6 – will it make a difference?
Speed read: As the UK reporting deadlines fast approach, Rachel Clark examines the new obligations to report arrangements under ‘DAC 6’, and what this means for taxpayers and their advisers.
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Game of Chess
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To train, and to train well – that is the question
Speed read: Training is a requirement under the UK Money Laundering Regulations but the wording leaves wide scope for interpretation.
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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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