Anna Bradshaw and Alistair Jones publish in-depth analysis of the current state of play of the UK’s ownership and control test in leading industry publication WorldECR, the Journal of Export Controls and Sanctions (see issue #125). They assess the combined impact of the Court of Appeal’s comments in Mints on 6 October, the High Court’s […]
Have you ever clicked on a link in an email that appeared genuine only to find out you had just failed a phishing attempt test set out by your IT department? These tests may look like they are meant to embarrass the unwary, but they are really a crucial element of a wider cyber protection […]
Last month, the UK’s Foreign, Commonwealth and Development Office, together with the Office of Financial Sanctions Implementation (OFSI), issued joint guidance on their approach to the ‘ownership and control test’, which determines the scope of UK asset freeze sanctions. Guidance alone is, however, unlikely to address the problems caused by the UK’s ownership and control […]
Between 2022 to 2023, civil forfeiture and recovery powers under Part 5 of the Proceeds of Crime Act 2002 (POCA) contributed £160.1 million to the public purse. With criminal confiscation powers bringing in £179 million, the amount recouped using civil rather than criminal asset recovery powers equates to just under half of the total asset […]
Earlier this month, the UK government announced the creation of a new agency to crack down on companies dodging trade sanctions. The Office of Trade Sanctions Implementation (OTSI) will be responsible for the civil enforcement of trade sanctions, including those that have been imposed on Russia since the war in Ukraine started. The new unit […]
Last month, the Financial Conduct Authority banned Jes Staley, former chief executive of Barclays, from holding senior position in financial services, also fining him a £1.8 million fine, for misleading it over a personal relationship, namely with Jeffrey Epstein. In this article for FT Adviser, Joseph Duggin discusses the case and how it is a […]
From the most significant trends in his practice currently to the reasons behind his favourite holiday destination, Nick Vamos answered a series of questions on work and life for TL4 HNW Divorce Magazine – HNW Divorce Litigation Conference edition. Imagine you no longer have to work. How would you spend your weekdays? I would move […]
On Monday 20 November, Michael O’Kane and Maya Lester KC, from Brick Court Chambers, (for their newly relaunched site globalsanctions.co.uk) spoke at a webinar with the UK government on the test for ‘ownership and control’ by designated persons in UK sanctions law. Discussion included the government’s recent guidance on ownership and control, the Court of […]
I’ll start with something for the meme lovers. Does anyone remember Brenda from Bristol, who in response to a BBC interviewer’s question, asking her what she thought about Theresa May’s decision to call an early general election in 2017 only two years after the previous one in 2015, cried “You’re joking – not another one!”. […]
The Financial Conduct Authority has trumpeted its interventions work as a key factor in how it identifies and prevents harm in the marketplace. However, the impact of Enforcement investigations should not be discounted. In this article for Banking Risk & Regulation, James Tyler explores, among others, what the regulator’s plans are in respect of interventions, […]
