Hannah Laming

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A Gap in the Market for Corruption Enforcement

This article will examine the evolving attitudes of the United Kingdom (“UK”), European Union (“EU”) and United States (“US”) toward corruption enforcement and will assess whether the UK and EU will be able to plug the potential enforcement gap created by President Trump’s recent Executive Order. The United States On February 10, 2025, President Trump … Continue Reading

Supply Chain Transparency: Updates on UK and EU Provisions on Forced Labour and Modern Slavery

Forced labour and modern slavery have been the subject of renewed focus across the UK and EU in recent months. Below we touch upon key issues relating to the UK Home Office’s update to its statutory guidance on the Modern Slavery Act; the EU ban on products made with forced labour due to come into … Continue Reading

UK Sanctions Update: OFSI Releases Financial Services Threat Assessment – Part 2

Last month, the UK’s Office of Financial Sanctions Implementation’s (“OFSI”) published a Threat Assessment analyzing sanctions compliance involving UK financial services firms since February 2022, when Russia invaded Ukraine. In the first of our two-part article (available here), we summarized the six key areas of risk that OFSI identified in its Threat Assessment. In this … Continue Reading

UK Sanctions Update: OFSI Releases Financial Services Threat Assessment – Part 1

In February 2025, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a report outlining its assessment of the sanctions-related threats posed to the UK by firms operating in the UK’s financial services sector.  As to be expected, the report focuses on the risks associated with transactions since February 24, 2022, when Russia invaded Ukraine … Continue Reading

Fast-Growing UK Challenger Bank Fined £29m for Insufficient Sanctions and Financial Crime Controls

On September 27, 2024, the Financial Conduct Authority (“FCA”), which is a financial regulatory body in the UK that regulates firms providing financial services to consumers, fined a UK Challenger Bank (the “Bank”) £29 million due to significant failings in its financial sanctions compliance and anti-money laundering systems and controls. The FCA’s Summary of Reasons … Continue Reading

Non-Financial Misconduct in the UK: A Thoughtful Initiative or a Hastily Conceived Concept?

Non-financial misconduct (“NFM”) within the financial sector has posed significant challenges for the U.K. Financial Conduct Authority (“FCA”) for several years. The FCA handbook prescribes that regulated firms must assess and certify to the FCA, at least annually, that senior individuals and those performing regulated activities meet the relevant standards of fitness and propriety to … Continue Reading

Insider Dealing: Increasing Scope and Greater Focus from UK and US Enforcement – Are You up to Speed?

The UK and US enforcement agencies have been actively pursuing insider dealing (“insider trading”, in US parlance) since the COVID-19 pandemic ended. The UK and US have different securities enforcement regimes, but both have seen recent developments expanding the scope of conduct that can be prosecuted. For individuals and organizations trading across multiple jurisdictions, it … Continue Reading

Increasing US Enforcement Action for Sanctions Violations by Crypto Exchanges Likely to Have Ripple Effect in UK and Europe

The investigation and enforcement of potential sanctions violations by crypto exchanges is an area of focus in the US at present.  The US Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent settlement with Kraken, a global virtual currency exchange, is the most recent OFAC case demonstrating the risks for virtual currency platforms … Continue Reading
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