SFO brings first Bribery Act charges

The Serious Fraud Office (“SFO“) had its first day in court in a Bribery Act prosecution on 24 September 2013, with three of four defendants connected with a £23m fraud at Sustainable AgroEnergy plc (“AgroEnergy“) facing charges of making and accepting a financial advantage contrary to sections 1(1) and 2(1) of the Bribery Act 2010. Read more

New EU Directive: Reporting by Extractive Companies on Government Payments

The European Parliament and Council of Ministers have agreed the final form of the new EU rules for the disclosure, on a project by project basis, of payments to governments by companies operating in the extractive  industries. The EU’s agreement is part of a suite of transparency initiatives which are designed to promote good governance … Read more

EU takes steps towards easing Zimbabwe sanctions

Susannah Cogman and Jeremy Sher comment on the EU’s recent easing of the Zimbabwe sanctions regime. On 19 February 2013, the European Union (“EU“) took a small step towards easing its sanctions regime in relation to Zimbabwe.  Twenty one individuals and one entity were removed from the EU’s list of designated persons, and the travel ban … Read more

Deferred Prosecution Agreements consultation – one week to go!

On 17 May 2012 the Ministry of Justice published a consultation paper ‘Consultation on a new enforcement tool to deal with economic crime committed by commercial organisations: Deferred prosecution agreements‘.  The paper proposes – as an alternative to the current options of criminal prosecution or a civil recovery order – a variant of the US … Read more

Proposed changes to the Money Laundering Regulations 2007 – Government response to consultation

Following a somewhat leisurely consultation process, the Government has this week published a response to its consultation on changes to the Money Laundering Regulations 2007 (“MLR”) and an impact assessment of the proposed changes (http://www.hm-treasury.gov.uk/fin_review_laundering_regs.htm).  The consultation follows a review of the operation of the MLR which was undertaken in 2009-10, and a consequential consultation … Read more

FSA fines bank and its former MLRO for failure to comply with anti-money laundering requirements

In May 2012 the FSA issued Final Notices fining Habib Bank AG Zurich (“Habib”) £525,000 for failure to take reasonable care to establish and maintain adequate anti-money laundering (“AML”) systems and controls and fining its former Money Laundering Reporting Officer (“MLRO”) Syed Hussain £17,500 for failure to take reasonable steps to ensure that Habib complied … Read more