Welcome to the March 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.

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: Fourth former oil executive sentenced for paying bribes in post-occupation Iraq
  • SFO, FCA, CMA and other public authorities granted powers under Covert Human Intelligence Sources (Criminal Conduct) Act 2021
  • Supreme Court hands down judgment in SFO’s case concerning the extraterritoriality of section 2 powers – appeal of KBR is allowed
  • OFSI: Introduction from new Director Giles Thomson
  • Home Office consultation on changes to bodies granted powers under POCA
  • LSAG issues AML guidance for legal sector
  • OFSI releases Quarterly TAFA 2010 reports
  • SFO closes investigation into listed British company
  • EU Exit: JMLSG note on implications of end of transition period on its Guidance
  • SFO: Former senior executive pleads guilty to further bribery offences
  • Parliamentary vote to introduce failure to prevent economic crime offence in the Financial Services Bill abandoned, pending Law Commission review
  • Implementation of UK sanctions regime following end of Brexit transition period
  • Covid-19: FCA statement on firms’ financial crime systems and controls expired on 7 February 2021
  • HMT/Home Office: ML/TF National Risk Assessment 2020
  • BEIS publishes three consultations on corporate transparency
  • NECC: Amber alert on illicit finance risks faced by independent schools
  • FCA charges individual with one offence of money laundering
  • FCA: Individual pleads not guilty to conspiracy to pervert the course of justice
  • High Court considers entitlement of investment firm to terminate Bitcoin trading account due to alleged money laundering concerns
  • SFO signs MoUs with CMA and FSCS
  • NCA: SARs Annual Report 2020
  • SFO secures £1.2 million following investigation into property linked to Brazilian bribery investigation
  • Covid-19: FCA advises on managing financial crime in relation to Bounce Back Loan Scheme
  • SFO confirms investigation into aerospace and transportation company
  • FCA prohibitions highlight increasing focus on non-financial misconduct
  • FCA criminal prosecution for destruction of documents
  • Treasury Committee launches new economic crime inquiry
  • UK Annual Report on Modern Slavery 2020
  • FCA updates webpage on MLRs and BAP
  • NCA: Payment platform operator for cyber criminals arrested in UK and sentenced in US
  • ICO publishes SEC data sharing guidance for UK companies



  • EBA Opinion on ML/TF risks affecting EU financial sector
  • EBA issues final revised ML/TF risk factor guidelines
  • European Commission Communication on the EU’s economic and financial system
  • EBA: Methodology for carrying out risk assessments under EBA Regulation
  • EBA: Report on functioning of AML/CTF colleges
  • EBA: Opinion on strengthening connection between EU AML/CTF legal frameworks and deposit protection
  • European Commission adopts new Delegated Regulation removing Mongolia from list of high-risk third countries under MLD4
  • EU introduces global human rights sanctions regime
  • EPC payment threats and fraud trends report 2020
  • EBA: Opinion on how to take into account ML/TF risks in Supervisory Review and Evaluation Process
  • EU Commission: Speech by Valdis Dombrovskis at ECOFIN press conference
  • European Commission: AML package legislative proposal expected in Q1 2020



  • FATF launches public consultation on Guidance on Proliferation Financing Risk Assessment and Mitigation
  • FATF: Executive Secretary speech at Chatham House Illicit Financial Flows Conference
  • FATF statement on jurisdictions under increased monitoring, high-risk jurisdictions subject to a call for action
  • FATF: Outcomes of Plenaries, 21 – 23 October 2020 and 22 – 25 February 2021
  • FATF: Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up
  • FATF releases latest consolidated assessment ratings
  • Covid-19: FATF Executive Secretary on ML/TF landscape and RegTech
  • Covid-19: FATF update on ML/TF risks
  • FATF/Egmont Group report: ‘Trade-based Money Laundering: Trends and Developments’
  • FATF: Survey on enhancing cross-border payments
  • FATF: President Pleyer speech at IMPA
  • FATF: Joint Experts’ Meeting 23 – 26 November 2020
  • FATF: President Pleyer remarks at G20 Finance Ministers and Central Bank Governors meeting, G20 leaders reiterate support
  • FATF updates standards to reflect counter-proliferation financing amendments
  • FATF: President Pleyer Statement on AML/CTF regimes during the Covid-19



  • Company ordered to pay over AED 470,000
  • Bank collectors embezzle nearly AED 70,000 of public funds
  • 200 law firms in the UAE have been suspended for not following prescribed procedures to combat money laundering
  • Real estate agent sentenced to five years in prison for fraudulent property transaction
  • UAE bank ordered to pay AED 5.5 million in compensation to duped customer
  • Nine individuals and nine companies found guilty in AED 306m money laundering case
  • Three individuals pose as representatives of a Dubai-based law firm in fraudulent transaction



Hong Kong

  • SFC issues anti-terrorism and sanctions update
  • SFC indicates crackdown on online “ramp and dump” scams as one of its enforcement priorities
  • HKMA publishes updated HKAB FAQs on AML/CFT
  • HKMA report: “AML/CFT Regtech: Case Studies and Insights”
  • Hong Kong Police arrests bankers in HK$6.3 billion money laundering case
  • Court sentences company secretary to imprisonment for insider dealing
  • Court upholds jail sentence against former GEM-listed group finance manager for insider dealing
  • ICAC makes available Corruption Prevention Guide for Insurance Companies and online training
  • Covid-19: HKMA reminds industry of pandemic-related ML/TF risks
  • SFC concludes consultation on CDD requirements for OFCs
  • SFC issues circular on anti-bribery obligations
  • Customs and Excise Department uncovers money laundering syndicate
  • SFC makes available materials from AML/CFT webinars
  • Insurance Authority makes available materials from AML/CFT sharing session
  • Hong Kong Government to propose new digital assets regulation, officials say



  • People’s Bank of China strengthens AML enforcement
  • Chengde court sentences banker to life in bribery case
  • Tianjin court sentences former finance executive to death for bribery
  • Beijing court sentences banker to life imprisonment
  • NAFMII widens default inquiry, accusing brokerage firm of manipulation
  • Nanjing court sentences official to imprisonment for accepting bribes




  • MAS publishes Terrorism Financing National Risk Assessment 2020
  • MAS publishes Enforcement Report
  • Singapore jails second individual in construction site graft case


South Korea

  • Seoul High Court sentences Vice Chair of technology company to prison for bribery



  • MACC investigates airline’s RM300 million bank loan



  • Thai Police suspects airline of corruption and mismanagement
  • Court sentences ex-governor of Tourism Authority to 50 years imprisonment for accepting bribes
  • NACC to investigate 112.5 billion baht glove purchase



  • KPK arrests former BPK commissioner



  • Ex-Japan farm minister Yoshikawa indicted for bribery without arrest
  • Medical equipment maker suspected of bribing former professors of Mie University Hospital
  • Three Japanese drug wholesalers indicted over bid-rigging
  • Results of the survey conducted by JFTC on trade practices involving startups



  • Australian Government consulting on establishment of Commonwealth Integrity Commission
  • Commonwealth Government announces enhanced protections for journalists and public sector whistleblowers
  • Parliamentary Committee recommends Australian Government introduce targeted sanctions legislation to address human rights violations and corruption
  • First tranches of Modern Slavery Statements now available



  • DoJ: Airline to Pay $49 Million to Resolve Criminal Fraud Charges and Civil Claims
  • FAQs on SARs and other AML considerations
  • DoJ: Indonesian company agrees to pay over $1.5 million fine
  • DoJ: Former Government contractor sentenced for role in bribery and kickback scheme
  • DoJ: Owner of crypto exchange sentenced to prison for money laundering
  • SEC and DoJ: Bank resolves bribery and fraud case
  • SEC statement on proposed 2011 fraud-detection program and 2012 Opinion of DoJ’s OLC
  • DoJ: Individual pleads guilty to violating FCPA
  • SEC adopts final rules for the disclosure of payments by resource extraction issuers
  • DoJ: Venezuelan individuals charged in relation to international bribery and money laundering scheme
  • DoJ: Individual charged in relation to international bribery and money laundering scheme
  • SEC and DoJ: OECD Working Group on Bribery issues Phase 4 Report



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.