BLL Bulletin

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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Anti-money-laundering-regime-requires-urgent-reform
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Anti-money laundering regime requires urgent reform
Speed read: Jonathan Fisher QC analyses the suspicious reporting regime and the inundation of the National Crime Agency with reports which are often of little use in the anti-money laundering effort.
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Confidential-Whistleblower
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Tax whistleblowers
Speed read: Rachel Clark analyses the whistleblowing regime in the context of tax whistleblowers, considering the unique position of reporting to HMRC and proposing specific protections needed to protect the flow of important information on tax offences.
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Account forfeiture
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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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The-EU’s-latest-money-laundering-directive
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The European sanctions regime and fair trial principles
Speed read: The General Court of the European Union recently decided Klyuyev v Council of the European Union Case T‑305/18 (19.07.2019) regarding European sanctions designated against high-profile individuals in Ukraine. The case provides an opportunity to consider the regulation of...
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Data Sharing
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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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Confiscating_From_Corporations
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Confiscating from corporates
Speed read: In Crown Prosecution Service v Aquila Advisory Limited [2019] EWCA Civ 588, the Court of Appeal held that the CPS could not confiscate illicit funds from a company without having brought charges against it. The Crown had included...
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Economic Crime Plan money note
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The Government’s Economic Crime Plan 2019–22
Speed read: Jonathan Fisher QC examines the Government’s recent Economic Crime Plan and its reliance on the private sector for investigating and enforcing financial crime. The implications of increased information sharing between the private and public sectors require careful consideration....
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the weed in the garden of CBD & cannabis investment
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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 Commission Report
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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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