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.

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

  • UK and EU sanctions in response to Belarus’ forced diversion of a Ryanair flight
  • OFSI: Imposition of monetary penalty for breach of financial sanctions
  • HMT: Call for evidence on the UK’s AML/CFT regulatory and supervisory regime and consultation on amendments to MLRs
  • HMCPSI inspection report on CPS and SFO Proceeds of Crime Divisions
  • NCA: Annual Report and Accounts 2020/21
  • SFO secures two further DPAs
  • Money Laundering and Terrorist Financing (Amendment) (No 2) (High-Risk Countries) Regulations 2021
  • Home Office Circular 004/2021: SARs in the context of disclosure in private civil litigation
  • ICO launches investigation into the use of private correspondence channels at DHSC
  • SFO enters into DPA with Amec Foster Wheeler Energy Ltd
  • SFO speech on making the UK a safe place for business
  • FCA: ‘Dear CEO’ letter on common control failings in AML frameworks
  • Revised POCA Codes of Practice
  • Former Unaoil executive ordered to pay £402k in confiscation
  • Law Commission discussion paper on corporate criminal liability
  • Pensions Regulator comments on draft criminal offences policy consultation
  • SFO seizes £248k from fraudster with account forfeiture order
  • CPS: Updated guidance on money laundering offences
  • The Sanctions and Anti-Money Laundering Act 2018 (Commencement No. 3) Regulations 2021
  • NCA strategic assessment of organised crime 2021
  • The Regulation of Investigatory Powers (Criminal Conduct Authorisations) (Amendment) Order 2021
  • FCA charges individual with fraudulent trading and carrying on regulated activities without authorisation
  • UK Serious Fraud Office confirms investigation into Gupta Family Group Alliance


  • EC: Consultation on guidance on the rules applicable to the use of PPPs in AML/CFT framework
  • EC announces new EU AML Package
  • EC: Consultation on proposed Directive on cross-border law enforcement access to bank account registries
  • EP calls for corruption to be treated as a crime subject to restrictive measures
  • EPPO and OLAF enhance cooperation
  • ECA: Report on EU efforts to fight money laundering in the banking sector
  • EC: Public consultation on freezing and confiscating proceeds of crime
  • EC: Opinion on EU sanctions and “making available”
  • EBA: Consultation on Guidelines on AML/CFT cooperation and information exchange


  • FATF: Report on review of revised AML/CFT standards on virtual assets and VASPs
  • FATF report on opportunities and challenges of new technologies for AML and CFT
  • Wolfsberg Group statement on demonstrating effectiveness of AML and CFT programme
  • FATF Report on EoRMT
  • FATF: Guidance on proliferation financing risk
  • FATF: CP on BO of legal persons; June 2021 Plenary outcomes; Report on environmental crime



  • Climate Bill: stronger environmental justice
  • French Parliament adopts a mechanism for the restitution of “ill-gotten gains”
  • French Parliament: Evaluation of the Sapin 2 Law
  • French Conseil d’Etat: assessment of governmental investigative powers
  • Whistleblower protection: overview of the public consultation
  • Publication of the 2020 activity report of the High Authority for Transparency in Public Life
  • Disciplinary sanction and knowledge by the employee of internal ethical rules



  • Update on implementation of the EU Whistleblower Directive



Hong Kong

  • SFC issues circular regarding suspected ramp and dump scams involving market manipulation in shares of listed companies
  • HKMA publishes seventeenth issue of Complaints Watch
  • FSDC issues research report on cybersecurity strategy for Hong Kong financial services industry
  • Sanctions and anti-terrorism updates
  • SFC increases efforts to combat IPO-related misconduct and outlines approach in joint statement with SEHK
  • MMT sanctions listed company and its directors for late disclosure of inside information
  • Former bank employee imprisoned for bribery over customer data for business touting


  • China top government body issues statement on tackling illegal activities in securities market
  • Former official of China’s biggest policy bank accused of corruption
  • Former anti-corruption investigator faces graft charges
  • Over 1,100 arrested in China’s crackdown on crypto-related money laundering
  • China’s central bank publishes proposed amendments to the Anti-Money Laundering Law for public consultation




  • RBI provides guidance in relation to customer due diligence for transactions in virtual currencies
  • Covid-19: RBI announces extension of required periodic updating of KYC – restrictions on account operations for non-compliance


  • UMNO leader charged with 106 counts of money laundering
  • Laws on beneficiary ownership required in combating corruption
  • First case of “smurfing” in Malaysia
  • MACC announces 29 initiatives to eradicate corruption completed

South Korea

  • Anti-corruption presidential secretary resigns over allegations of real estate speculation
  • 12 South Korea ruling party lawmakers implicated in real estate corruption
  • South Korea exposes cryptocurrency Ponzi scheme


  • Possible 20-year prison sentence for arrested journalist



  • Well-known animation studio and its president indicted for tax evasion
  • Revised guidelines for the prevention of bribery of foreign public officials



  • Proposed restructure of Australian Securities and Investments Commission
  • Parliamentary Inquiry into Australia’s AML/CFT financing regime
  • Potential amendments to the NSW Modern Slavery Act
  • Further Australian modern slavery statements now available



  • Sanctions update June – August 2021
  • HSF podcast series on sanctions law
  • DoJ: Cryptocurrency fraudster sentenced for money laundering and securities fraud
  • DoJ: Former construction executive sentenced for tax evasion and bribery scheme
  • DoJ: Turkish businessman arrested for money laundering
  • FDIC: Bank Secrecy Act/Anti-Money Laundering Examination Manual update
  • SEC: Biotech company and executives charged in $10 million offering fraud
  • DoJ: Former Minister of Government of Bolivia charged in bribery and money laundering scheme
  • DoJ: Two bank executives charged for conspiring to launder money in connection with bribery and fraud scheme
  • DoJ: Chadian diplomats to the US charged in connection with international bribery and money laundering scheme



  • State Capture of R57 billion
  • South Africa has lost over R1.5 trillion to corruption in five years
  • Minister of Health, Zweli Mkhize, put on leave following corruption allegations



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