Welcome to the November 2020 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.

For the full update on each jurisdiction, please click on the name of the jurisdiction below. Below we provide a brief overview of what is covered in each update.



United Kingdom

  • SFO: Three former Unaoil executives sentenced for bribery
  • SFO charges individuals with fraud in relation to activities of steel group
  • SFO charges former executives of global security company with fraud against taxpayer
  • SFO charges three individuals in fund investigation
  • SFO secures £5.45 million confiscation order against former executives of Afren Plc
  • SFO charges company and three individuals following corruption investigation
  • SFO secures third DPA of 2020
  • New DPA guidance in the SFO’s Operational Handbook
  • Ministry of Justice publishes its response to the call for evidence on corporate liability for economic crime
  • SFO Annual Report and Accounts 2019 – 2020
  • SFO: Director Osofsky speech on future challenges in economic crime
  • SFO: Director Osofsky re-examines priorities of SFO at Cambridge Symposium on Economic Crime
  • HMCPSI inspection of SFO’s response to Covid-19
  • FCA consultation on extension of annual financial crime reporting obligation
  • FCA: Changes to FCG now in force
  • FCA: £1.6 million confiscation order against Richard Baldwin
  • FCA: Criminal proceedings brought against three individuals
  • FCA final notice to trader following insider dealing conviction
  • NCA Annual Report and Accounts 2019/20
  • NCA: Businessman with links to serious crime settles £10 million UWO case
  • NCA recovers more than £1 million of assets
  • HMT annual report on AML/CFT
  • HMT consultation on economic crime levy
  • FinCEN papers: Treasury Committee seeks answers from Ministers, HMRC and FCA
  • OFSI updated guidance on financial sanctions in UK
  • OFSI Annual Review 2019 – 2020
  • OFSI quarterly report to Parliament on TAFA 2010
  • HMRC releases details of breaches of 2017 MLR in 2019/2020
  • BEIS response to consultation on Companies House reform
  • BEIS CfE – UK approach for international regulatory cooperation
  • The Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020
  • Draft Sanctions (EU Exit) (Consequential Provisions) (Amendment) Regulations 2020
  • Draft SI: Closing the bearer certificate loophole for collective investment schemes



  • EBA calls on Commission to establish single rulebook on AML/CTF
  • European Commission: Speech on EU’s AML/CTF plans
  • 4MLD/5MLD: Commission report on trusts and similar arrangements governed under Member States’ laws
  • Commission Communication on EU’s AML/CTF framework
  • EU ‘Magnitsky Act’ proposal to be announced soon
  • CJEU: Russian oil company loses Crimea sanctions challenge
  • EU High Representative: Declaration on international security and stability in cyberspace
  • EU imposes sanctions on individuals for repression and election falsification in Belarus
  • Europol highlights relationship between banks and sports corruption
  • OLAF Director-General welcomes EPPO as a ‘game changer’
  • EPPO: Chief Prosecutor and 22 Prosecutors take oath before CJEU



  • FATF Annual Report 2019 – 2020
  • FATF President speech at counter-terrorism conference
  • FATF: Updated consolidated assessment ratings
  • FATF report: ‘Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing’
  • FATF President addresses GAFILAT Virtual Plenary Meeting
  • OECD: Public-private efforts against corruption ‘must continue’ after Covid-19
  • Wolfsberg Group statement on effective AML/CTF programmes
  • Wolfsberg Group FAQs on Source of Wealth and Source of Funds



  • Updated AFA recommendations
  • Publication of the GRECO assessment report for France
  • Publication of the Tracfin annual report
  • Publication of the French Anticorruption Agency’s annual report
  • Publication by the AFA of a practical guide on gifts and entertainment
  • Signing of a cooperation protocol between the AMF and the AFA



  • Human rights compliance in Germany: Current steps towards a mandatory Human Rights Due Diligence Law



  • Spain’s National Court (Audiencia Nacional) acquits 34 defendants in the Bankia IPO



  • Fraud of CEO of private jet firm against Dubai-based gift company
  • Fraud and embezzlement by an employee of a law firm
  • CEO of companies and his father sentences to prison in Dubai for AED 8 million scam
  • AML developments in Dubai



Hong Kong

  • Director and clerk charged with defrauding four banks
  • Largest money laundering case uncovered
  • Investigations into the surge in share price of Next Digital



  • Chinese real estate tycoon jailed for 18 years




  • Former Cabinet minister’s senior private secretary charged with accepting and soliciting bribes
  • Two Sabah company owners arrested for falsifying information to obtain supply contracts



  • Former sports minister sentenced to seven years for a bribery case



  • Central Bank to review anti-money laundering compliance of banks



  • NACC and Democrat Party to look into alleged bribes



  • Capital markets services licence of Apical Asset Management revoked



  • Chairman of the People’s Committee of Hanoi arrested



  • New proposed provisions to deal with money laundering in trust agreements



  • Corporate Criminal Responsibility Inquiry Final Report released
  • ASIC enforcement update for January to July 2020
  • Modern Slavery Developments at the Commonwealth level
  • Modern slavery developments at NSW level
  • The Australian Combatting Corporate Crime Bill: What does it mean for companies?



  • SEC amends whistleblower award program
  • SEC whistleblower awards
  • SEC Chair and Co-Director of Enforcement remark on Enforcement program
  • SEC, FINRA and CFTC charge brokerage firm with AML and supervision failures
  • SEC, CFTC and DoJ: Settlements reached in investment bank spoofing cases
  • SEC charges prominent businessman and computer programmer with fraudulently promoting ICOs
  • SEC charges consumer loan company with FCPA violations
  • SEC and CFTC help victims of Ponzi scheme recover over $1 billion
  • Further SEC enforcement actions
  • CFTC Division of Enforcement announces record-breaking year
  • CFTC whistleblower awards
  • CFTC charges trading platform owners with illegally operating a cryptocurrency derivatives trading platform and AML violations
  • CFTC Bank Secrecy Act Task Force case: Settlement in SARs and supervision failures
  • CFTC orders firm and trader to pay $585,000 for spoofing
  • CFTC: Firm vicariously liable for spoofing of trader
  • CFTC charges individuals and company with spoofing in crude oil futures markets
  • CFTC charges several individuals and companies in $165 million global binary options fraud scheme
  • CFTC orders swap dealer to pay $127.4 million for spoofing, false statements, compliance and supervision violations
  • Federal banking agencies issue joint statement on enforcement of BSA/AML requirements
  • Agencies issue joint statement on BSA/AML due diligence requirements for PEPs
  • FINRA podcast: Money laundering in the securities industry
  • DoJ: Two former traders convicted of engaging in deceptive and manipulative trading practices in US commodities markets
  • DoJ: Lawyer charged with fraud related to investment scheme
  • DoJ: Florida company fined $16.6 million for violating FCPA anti-bribery provisions
  • OFAC: Large bank to pay $583,100 to end Ukraine sanctions probe
  • DoJ: Global nutrition company agrees to pay over $122 million to resolve FCPA case
  • DoJ issues first FCPA advisory opinion in six years
  • DoJ: Former forex trader sentenced to prison for price fixing and bid rigging
  • DoJ: Largest ever seizure of cryptocurrency in the terrorism context
  • OFAC designates eight Belarusian officials under sanctions regime


Susannah Cogman
Susannah Cogman
+44 20 7466 2580
Daniel Hudson
Daniel Hudson
+44 20 7466 2470
Kate Meakin
Kate Meakin
+44 20 7466 2169
Brian Spiro
Brian Spiro
+44 20 7466 2381


Herbert Smith Freehills LLP is licensed to operate as a foreign law practice in Singapore. Where advice on Singapore law is required, we will refer the matter to and work with licensed Singapore law practices where necessary.