Welcome to the May 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

  • Launch event: Law Commission review of the law relating to corporate criminal liability
  • SFO publishes Business Plan for 2021/22
  • FCA fines firm for financial crime control failings
  • FCA: Speech by CEO on regulation for a different world
  • HO/HMT: Statement of progress on Economic Crime Plan
  • FRC imposes sanctions on actuary in relation to advisory services provided to Coats Group plc
  • SFO ends investigations into individuals in Airbus case
  • SFO offers no evidence against former Serco Geographix executives
  • The Global Anti-Corruption Sanctions Regulations 2021
  • FCA: Criminal proceedings for fraud and unauthorised business
  • JMLSG consults on revised trade finance sectoral guidance
  • SFO announces investigation into the Raedex Consortium group of companies
  • FCA speech on AML controls at AML & ABC Forum 2021
  • FCA: Policy statement on extending annual financial crime reporting obligation
  • PSR: Statement of Objections on breaches of competition law
  • CPS: Economic crime strategy 2025
  • Gambling Commission announces enforcement action for casinos
  • HC: Company unlawfully advised on investments and promoted CFD trading
  • The Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations 2021
  • HMT advisory notice on ML/TF controls in higher risk jurisdictions
  • OFSI: Quarterly report on the operation of the UK’s asset freezing regime under TAFA
  • SFO closes investigation into KBR Inc.’s UK subsidiaries
  • FCA statement on trial dates in criminal cases
  • FCA starts criminal proceedings against bank under MLR
  • OFSI: Updated guidance on monetary penalties for breaches of financial sanctions
  • FCA speech on market abuse
  • NCA updated guidance on submitting better quality SARs


  • EBA: Consultation on a central AML/CFT database
  • BaFin orders bank to further enhance anti-money laundering measures
  • Commission roadmap on law enforcement access to interconnected bank account registries
  • ESMA: Technical advice to the EC on administrative and criminal sanctions under MiFID II/MiFIR
  • EBA: Consultation Paper on the revised Guidelines on Risk-based AML/CFT supervision
  • Key resolution on corporate due diligence and corporate accountability adopted by the EP


  • FATF: Launch of project on mitigating unintended consequences of FATF standards
  • FATF report on Trade-Based Money Laundering: Risk Indicators



  • Justice Reform: the main features of proposed judicial reforms
  • The European Public Prosecutor’s Office is willing to start its investigations on 1 June 2021
  • AFA 2020 Report
  • Bolloré Group fined €12 million in Togo corruption case
  • Decision handed down by the Versailles Court of Appeal on the jurisdiction to award preventive actions in respect of French Vigilance Law
  • French government introduces Climate Bill to promote stronger environmental justice
  • Release of the new French Anti-Corruption Agency’s guidelines



  • Transposition of Fifth Anti-Money Laundering Directive in Spain



  • Professional beggars turn to Whatsapp during Ramadan
  • German expat targeted in sophisticated phishing attack
  • UAE Cabinet approves the establishment of the executive office for AML and CFT



Hong Kong

  • HKMA publishes key messages and observations from thematic review of use of external information in AML/CFT control systems
  • SFC and police conduct joint operation against listed company and senior executives in connection with suspected ramp-and-dump market manipulation schemes and fraud
  • SFC revokes corporation’s licence and bans its former co-CEOs for life
  • Hong Kong Customs cracks down on HK$2.5 billion money laundering syndicate
  • ICAC charged former government consultant with misconduct and fraud over HK$4.2 million services for overseas health organisations including WHO
  • Solicitor acquitted of insider dealing in shares of listed company
  • MMT sanctions two former executives of listed company for insider dealing
  • Two former law firm employees jailed for fraud over HK$20 million mortgage loans and money laundering


  • Former top official of China’s biggest policy bank accused of bribery
  • China’s anti-money laundering regulations tightened for financial institutions
  • Vice Governor of Shanxi Province faced corruption investigations
  • Former Shanghai Clearing House chief faced corruption charges
  • China’s financial regulators released new Know-Your-Customer rules for public consultation
  • Former culture and tourism official faces corruption charges
  • Former senior political advisor of Hainan charged with bribery




  • SEBI amends the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015
  • Former Uttar Pradesh minister charged with money laundering


  • First company director charged for corporate liability for corruption


  • Broadened anti-money laundering rules


  • Businessman charged for $750 million fraud over cheating investors

South Korea

  • South Korea vows to crack down on money laundering via crypto transactions
  • Anti-corruption initiatives to tighten discipline in public service
  • South Korea’s crypto anti-money laundering rules enter into force


  • Taiwan to launch new anti-money laundering regulations for crypto exchanges


  • Updates to anti-money laundering laws


  • Vietnam achieved best corruption control in a decade



  • Japanese government officials punished for dining for free



  • Further tranches of Australian modern slavery statements now available
  • ASIC pilots express investigation system for enforcement activities
  • ASIC launches immunity policy for market misconduct offences
  • Australian Government releases response to the Senate Economics References Committee report into foreign bribery



  • Sanctions update March – May 2021
  • SEC charges Texan with defrauding investors in a purported wireless energy project
  • SEC obtains judgement in insider trading case involving clinical trial
  • DoJ indicts two companies and nine individuals for alleged large-scale visa fraud employment scheme
  • DoJ: High-level organiser of notorious hacking group sentenced to prison for scheme that compromised tens of millions of debit and credit cards
  • SEC obtains final judgment against lawyer who assisted fraud
  • CFTC announces that Federal Court orders UK man to pay more than $571 million for operating fraudulent bitcoin trading scheme
  • DoJ sentences former CEO and founder of technology company for his role in investment-fraud scheme
  • Former oil trader pleads guilty to DoJ for commodities price manipulation conspiracy
  • DoJ: Former Venezuelan official pleads guilty in connection with international bribery and Money Laundering Scheme
  • DoJ: Former Ecuadorian government official sentenced to prison for role in bribery and money laundering scheme
  • SEC: Additional unregistered broker who sold $8.5 million in securities to retail investors charged with securities violations
  • DoJ: First North Korean national brought to the US to stand trial for money laundering offences
  • DoJ: Iranian nationals charged with conspiring to evade US sanctions on Iran by disguising $300 million in transactions over two decades
  • DoJ announces South Korean national pleads guilty to scheme to defraud US Department of Defense
  • SEC charges Texas investment adviser and two executives in connection with $17 million energy fund fraud
  • SEC charges recidivist securities fraudster with defrauding investors
  • SEC charges unregistered investment adviser with defrauding investors in decade-long scheme
  • Individual sentenced for role in investment-fraud scheme
  • Cryptocurrency fraudster pleads guilty to securities fraud and money laundering charges in multi-million dollar investment scheme
  • CFTC charges individual with fraud and misappropriation
  • CFPB takes action against payment processor and its former CEO for supporting internet-based technical-support scams


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.