The new summary account forfeiture provisions introduced by the Criminal Finances Act 2017 have yielded a significant dividend for the National Crime Agency (“NCA”) in the Javadov case which was settled a few weeks ago.
The proceeds of environmental crime are laundered far more than most realise. This is the message of a recent report of the Financial Action Task Force ‘Money Laundering from Environmental Crime’, published July 2021.
The UK government has committed to introducing a global corruptions sanctions framework later this year. It is likely that persons wherever located can be designated on the basis that there is a ‘reasonable suspicion’ they are involved in corruption.
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.