In a recent decision, the High Court has ordered that documents provided to Tesco plc ("Tesco") by the SFO for the purpose of negotiating a deferred prosecution agreement ("DPA") must be disclosed by Tesco in the separate civil action relating… Read more

Authors: Susannah Cogman, Partner, London; Daniel Hudson, Partner, London; Jonathan Cross, Counsel, New York; Geng Li, Associate, New York; and Christopher Milazzo, Associate, New York. On January 28, 2019, the US Department of the Treasury’s Office of Foreign Assets Control… Read more

Welcome to the December 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters. This month, we would like to wish all of our regular readers a… Read more

Federal Decree No. 24 of 2018 has amended certain provisions of Federal Law No. 3 of 1987 (the "Penal Code") to strengthen anti-corruption legislation in the UAE and bring it in line with other jurisdictions by including foreign public officials… Read more

Welcome to the autumn 2018 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… Read more

The Hong Kong Court of Final Appeal (CFA) has recently allowed the Securities and Futures Commission’s (SFC) appeal against the Market Misconduct Tribunal’s (MMT) findings that two former executives of a listed company (ATML), Mr Charles Yiu Hoi Ying and… Read more

Following President Trump’s decision on May 8, 2018 to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), the US government announced that it would re-impose pre-JCPOA nuclear-related Iran sanctions (both primary and secondary) that were lifted… Read more

In the case of R (On The Application Of KBR Inc) v The Director of the Serious Fraud Office [2018] EWHC 2368 (Admin) ("KBR"), the High Court dismissed a judicial review brought by the applicant, finding that the SFO was able to compel… Read more

How far can a sanctions clause protect a party from having to perform their contractual obligations - and in the case of Iran-related sanctions concerns, how does this interact with the Blocking Regulation? In Mamancochet Mining Limited v Aegis Managing Agency… Read more

On October 11, 2018, the Financial Crimes Enforcement Network ("FinCEN") issued official guidance entitled "Advisory on the Iranian Regime's Illicit and Malign Activities and Attempts to Exploit the Financial System" (the "Advisory"). The Advisory intends to help US financial institutions… Read more

Our investigations team has published an article for Thomson Reuters Regulatory Intelligence looking at the impact of data privacy laws on investigations in Asia. This also summarises the potential impact of Europe’s GDPR and what else is on the horizon… Read more

Thailand is the latest Asian jurisdiction to strengthen its anti-graft legislation. India, Japan, Singapore, Malaysia, Vietnam and China have all introduced anti-bribery legislation this year. The net effect is an uptick in the local enforcement risk for corporates operating in… Read more

The Securities and Futures Commission (SFC) issued a circular on 31 August 2018 highlighting both deficiencies and good practices observed in relation to anti-money laundering and counter financing of terrorism (AML/CFT) compliance by licensed corporations (LCs) and associated entities (AEs).… Read more

The Court of Appeal has today handed down its eagerly awaited decision in the ENRC appeal: The Director of the Serious Fraud Office v Eurasian Natural Resources Corporation Ltd [2018] EWCA Civ 2006. At first instance, the High Court took a restrictive… Read more

The Hong Kong Monetary Authority (HKMA) has recently released its first Guidance Note on Cooperation with the HKMA in Investigations and Enforcement Proceedings. In releasing the guidance note, the HKMA has expressly signalled its desire to encourage and facilitate cooperation,… Read more

Welcome to the summer 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters over July and August.  ... Read more

On August 24, 2018, the Second Circuit Court of Appeals rejected the government's broad interpretation of the jurisdictional reach of the Foreign Corrupt Practices Act ("FCPA") and held the government could not use aiding and abetting and conspiracy theories to… Read more

End of first wind-down period Following President Trump's decision on 8 May 2018 to withdraw the United States from the Joint Comprehensive Plan of Action ("JCPOA"), the US government announced that it would re-impose pre-JCPOA nuclear related sanctions (both primary… Read more

Tax authorities in the UK, the USA, Canada, Australia and the Netherlands have joined forces to launch the Joint Chiefs of Global Tax Enforcement, or “J5” alliance against transnational tax crime and money laundering. ... Read more

On 5 July 2018, the Securities and Futures Commission (SFC) issued a consultation paper on proposals to amend the Guideline on Anti-Money Laundering and Counter-Terrorist Financing (Main Guideline) and the Prevention of Money Laundering and Terrorist Financing Guideline issued by… Read more

Welcome to the June 2018 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… Read more

In May, we published an e-bulletin discussing President Trump's announcement that the United States would withdraw from the Iran nuclear deal (the Joint Comprehensive Plan of Action – "JCPOA"), and that all pre-JCPOA nuclear-related sanctions on Iran (including secondary sanctions) would be… Read more

Welcome to the May 2018 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… Read more

Late last week, the Hong Kong Insurance Authority (IA) published a circular setting out its key findings from anti-money laundering and counter-financing of terrorism (AML/CFT) onsite inspections of authorised insurers carrying on long term business.  ... Read more

On 24 May 2018, it was announced that the Sanctions and Anti-Money Laundering Act (the "Act") had received Royal Assent. The Act is the first piece of UK primary legislation governing the post-Brexit legal position and will create a post-Brexit… Read more

Kyle Wombolt, global head of corporate crime and investigations, and Anita Phillips, a professional support consultant, have published a guide to corporate investigations in China. This forms part of GIR's acclaimed 2018 text, The Practitioner's Guide to Global Investigations, available… Read more

The House of Lords has established an ad hoc Select Committee (the "Committee") to consider and report on the Bribery Act 2010 (the "Act"). The Committee, which was formally appointed on 17 May, is due to release a report by… Read more

Welcome to the first edition of our Anti-Corruption Regulation Legal Guide for the Middle East. We are delighted to launch this publication, which presents the legislative framework regulating bribery and corruption across arrange of Middle East jurisdictions, drawing upon the combined knowledge and experience… Read more

The Foreign & Commonwealth Office has published guidance detailing the UK Government's intended approach to sanctions exceptions and licences after Brexit. Sanctions exceptions and licences are mechanisms through which restrictive measures imposed by sanctions may be relaxed in specific circumstances.… Read more

The Hong Kong government has published a report detailing the money laundering (ML) and terrorist financing (TF) risk assessment of Hong Kong. This follows the recommendations of the Financial Action Task Force (FATF) that jurisdictions identify and assess their ML/TF… Read more