Welcome to the Winter 2021 edition of our corporate crime update – our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters.

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

  • FCA: First criminal prosecution under MLRs 2007
  • HMT: Updated Advisory Notice on ML/TF controls in higher risk jurisdictions
  • Autumn Budget and HMRC Policy paper on Economic Crime Levy
  • HMT: National risk assessment of proliferation financing
  • FCA: Final Notice on due diligence
  • OFSI annual review 2020 to 2021
  • FCA: Report on 2017-2020 REP-CRIM submissions
  • SFO secures conviction of a Jersey incorporated oil and gas company for seven counts of failure to prevent bribery
  • HMT: Global Anti-Corruption Programme annual review 2020
  • UK Finance report on definition of public officials for ABC compliance
  • SFO announces investigation into £150m investment schemes after dawn raid
  • TPR finalises criminal offences policy and launches consultation on new powers
  • Co-operative agreement between the NCA and Europol
  • UK Finance: Fraud report
  • OPBAS publishes report on progress and themes from 2020/21
  • OFSI frozen assets reporting 2021
  • FCA reminds firms about financial crime risks linked to Afghanistan


  • EP: Paper on preventing money laundering in the banking sector
  • EDPS opinion on legislative proposals for AML and CFT action plan


  • OECD: Updates to Anti-Bribery Recommendation
  • FATF: Updated guidance for a risk-based approach to virtual assets and VASPs
  • FATF updates – consultation and call for action



  • Consultation on the practical anti-corruption guide for SMEs and small ETIs
  • Lafarge in Syria: French Cour de cassation overturns the cancellation of the prosecution for “complicity in crimes against humanity”
  • Draft guidelines on conflicts of interest
  • Evaluation of the Sapin 2 Law: French Parliament seeks to boost anti-corruption policy in France



  • “Dieselgate”: Opel pays €65 million fine for breach of documentation requirements in the approval process for several diesel models but is no longer prosecuted for fraud
  • Introduction of a corporate sanctions law possible again after federal elections in Germany
  • Cum-ex-deals: Federal High Court of Justice confirms culpability



Hong Kong

  • SFC publishes revised AML/CFT guidelines
  • Sanctions and anti-terrorism updates
  • SFC and CCB of Police conduct joint operation against listed company and former senior executives in HK$450 million corporate fraud case
  • SFC and ICAC conduct joint operation on listed company’s suspicious money lending activities resulting in arrests


  • China launched anti-corruption review of 25 Chinese financial institutions
  • CIC updated its anti-corruption and anti-bribery statement
  • China promulgated Measures for the supervision and administration of AML/CFT of financial institutions
  • China targets corruption with new supervision law




  • ED raids multiple locations across India in relation to money laundering involving Karvy Stock Broking Limited

South Korea

  • Samsung Vice-Chairman released after serving more than half of his sentence for bribery


  • MAS launches platform to tackle trade-based money laundering
  • Individual sentenced to 26 months’ imprisonment and given fine for money laundering and operation of unlicensed remittance business
  • Former PUB officer charged with accepting bribes of $45,000 and falsifying invoices


  • BMAP launches anti-fraud campaign
  • President Duterte dismissed NEA administrator Masongsong due to corruption



  • Former Japanese government official imprisoned for receiving bribes from a gambling company
  • Japan urged to fight corruption and anti-money laundering with stricter countermeasures



  • NSW Modern Slavery Amendment Bill before Parliament
  • ASIC released new guidance for mandatory whistleblower policies
  • Corporate regulator ASIC still committed to enforcement
  • New Commonwealth Bill to ban the importation of goods produced by forced labour
  • Proposed Magnitsky-style reforms to Australian sanctions regime



  • Sanctions update
  • HSF podcast series on sanctions law
  • DoJ: Speech on corporate enforcement policy
  • DoJ announces that leader of money laundering network sentenced to 15 years in prison
  • DoJ announces bribery charges against CEO of major defense contractor
  • DoJ announces that former CEO of petrochemical company sentenced to 20 months in prison for foreign bribery scheme
  • SEC charges California cannabis company, CEO and president with fraud



Susannah Cogman
Susannah Cogman
+44 20 7466 2580
Daniel Hudson
Daniel Hudson
+44 20 7466 2470
Robert Hunt
Robert Hunt
+44 20 7466 3423
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.