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On September 21, 2021, the Office of Foreign Assets Control (“OFAC”) of the Treasury Department issued an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (“Updated Advisory”), which warns of the sanctions risks of making or facilitating ransomware payments and provides expanded guidance on steps that companies may take to mitigate ransomware risk. Read more
The latest edition of our Regulation in Focus podcast series features Karen Anderson and Andrew Procter, both partners in our FSR practice and both former regulators, in conversation about the FCA's plans to streamline regulatory decision-making, which - if the FCA proceeds as proposed - will be a significant change to how authorisation, supervision and enforcement are delivered. Read more
The option to participate in collective assurance activities is welcome, but this article which was originally published in the September 2021 edition of Butterworths Journal of International Banking and Financial Law makes the case for more guidance. Read more
Welcome to the Summer 2021 edition of our corporate crime update – our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters. Our update now covers a number of jurisdictions. Read more
This briefing looks as the proposed creation of an EU-wide Anti-Money Laundering Authority ("AMLA" or the "Authority"), as set out in the EU's recent AML reform package. Read more
The FCA has published Consultation Paper 21/28: New cancellation and variation power: Changes to the Handbook and Enforcement Guide (CP21/28). The proposals in CP21/28 relate to and provide guidance on the new power which the regulator was given under the Financial Services Act 2021 (FS Act) to allow it to act more quickly where an FCA-authorised firm is not – or does not appear to be – carrying on FCA-regulated activities. Read more
On 31 August 2021, the European Commission closed the initial feedback period for this impact assessment and, as a next step, has now launched a public consultation process seeking further feedback on the Blocking Statute. Read more
With just four months to go until the start of the Investment Firms Prudential Regime (IFPR) on 1 January 2022, the FCA has recently published policy statements to its first two consultations on the IFPR. The FCA also published its (third and) final consultation paper on the IFPR, CP21/26. Read more
