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Click for PDF Those with operations in the United Kingdom, especially in the financial services or regulated sectors, will have been very aware during the course of this year of the flood of new legislation imposing significant and varied compliance obligations: Coupled with this new wave of regulation has been another year of substantial enforcement by a range of regulators and prosecutors, for a wide variety of offences.
These enforcement actions are discussed below in the relevant sections. The year has also seen significant developments from the courts. Most notably this can be seen in the High Court decision on privilege in SFO v ENRC which is discussed below and will, unless overturned, have significant implications for the conduct of internal investigations relating to the UK. In addition, given the large number of offences which require the prosecution to prove dishonesty, the fundamental change to the test for dishonesty in the Supreme Court decision of Ivey v Genting Casinos UK Limited  UKSC 67 will have repercussions for a vast number of prosecutions in years to come.
This judgment is likely to have significant impact on the cross-border co-operation between the U. The Government claims that the SFO will continue to act as an independent organisation, supporting the multi-agency response led by the NCA, but there is room to question how the SFO can be expected maintain its independence when acting under the direction of the NCA.
The first NRA was published in and set out the areas where action was needed to combat money laundering and terrorist financing. In response, in , the Government released an action plan which set out planned reforms to the AML regime: The key findings of the assessment are that: As regards the financial services sector, the NRA found that overall the sector remained at high risk of money laundering.
The report provides separate assessments for retail banking, wholesale banking, capital markets, and wealth management. In summary, retail banking was identified as being at a high risk of money laundering due to the increasing speed and volume of transactions together with a widespread criminal intent to exploit retail banking products, although the NRA noted that controls are more developed in retail banking than other areas.
In wholesale banking and capital markets, the risk of money laundering was found to be high due to the risks of large sums being laundered through capital markets and the relative lack of controls. Wealth management was also found to be high risk due to its exposure to the proceeds of political corruption and tax evasion and regulatory concerns.
Privilege As reported in our last update, regulators continue to take an aggressive stance on privilege and two important judgments over the past year demonstrate this. The investigation focused on allegations of fraud, bribery and corruption. Assertions of both legal advice privilege and litigation privilege were made in respect of the documents sought by the SFO.
All assertions of privilege, save for a limited legal advice claim in respect of a narrow group of documents, failed. Since then there have been two further developments. The Law Society has expressed concern throughout the case over the impact of the case on privilege. The interviews were conducted by in-house and outside counsel as part of two internal investigations carried out by the bank.
The High Court rejected these arguments and held that the notes of interviews were not privileged. Following that party failing to maintain its Parliamentary majority albeit remaining in government , there have been no further statements since then and this pledge appears to have been quietly dropped and replaced with the above-mentioned plan from the Home office for the Economic Crime Unit.
The figure for is, however, smaller than the total fines collected in each of , and This was the first enforcement action based on allegations of the non-reporting of details of trading instruments since the European Markets Infrastructure Regulation reporting requirements were introduced in to help improve transparency and help regulators understand the risks banks faced.
Merrill Lynch cooperated with the FCA. It is important to stress that this was the only misconduct complained of and which generated this significant fine. The lessons for companies with multiple regulators are clear; the PRA and the same applies to the FCA expects to be told in advance about any regulatory enforcement against a company taking place around the world.
The continued use and promotion of DPAs is an indication that the SFO and other government bodies are using and intend to continue to use the new powers made available by recent legislation. As discussed below in relation to sanctions offences under the PCA, and the new failure to prevent tax evasion offences under the CFA, the DPA regime is being extended to other offences as and when they are enacted.
The government did not publish a further review in However, in October , the Home Office issued updated guidance on compliance with the Act. The October guidance now encourages smaller organizations to produce the statements voluntarily. The guidance requests that organizations keep public archives of their annual statements to allow the public to compare statements between years and monitor the progress of the organization over time.
The report found that there had been 80 prosecutions for offences in Paradise Papers In November , over 13 million documents were leaked, mostly related to the law firm Appleby. These documents revealed the tax and other arrangements of a large number of individuals and corporations.
Although there has been media criticism of some of the high-profile individuals involved and calls for legislation on offshore arrangements to be reformed, one of the most notable aspects of the leak is that the response within the UK has been reasonably muted, especially in comparison to the reaction to the Panama Papers leak which we reported in our Year-End UK White Collar Crime Alert.
The Panama Papers leak resulted in a Panama Papers Taskforce being set up and the FCA contacting 64 firms to establish their links with the Panama law firm at the centre of the controversy. One possible reason why public reaction to the Paradise Papers has been so limited is that most of the schemes revealed were lawful.
In addition, it appears many of the public figures named were not directly involved in organising these arrangements and the public may simply be losing interest following coverage of Lux Leaks in , and Swiss Leaks and the Panama Papers both in Nonetheless, companies will continue to be conscious of how aggressive tax avoidance schemes and use of offshore tax jurisdictions, even if legal, can cause adverse headlines.
The Bill aims to allow the UK government to continue to comply with the current UN sanctions regime post Brexit, as well as imposing and enforcing sanctions. For more information, please see the Sanctions section below. Underneath that headline story two other companies have been found guilty of corruption and 27 individuals have been convicted of bribery or corruption offences. Moreover, press reports indicate that DPA negotiations between the SFO and Airbus on another substantial resolution are currently in progress.
UK anti-corruption strategy for to On December 11, , the Department for International Development and the Home Office published the UK anti-corruption strategy for to The cross-government anti-corruption strategy provides a framework to guide UK government action to tackle corruption. The six priorities are as follows: Reduce the insider threat in high-risk domestic sectors 2.
Strengthen the integrity of the UK as an international financial centre 3. Promote integrity across the public and private sectors 4. Reduce corruption in public procurement and grants 5. Improve the business environment globally 6. Work with other countries to combat corruption The strategy notes that in the present Parliamentary session, a draft bill will be published for the establishment of a public register of beneficial ownership of overseas legal entities where they own or purchase property in the UK, or participate in central government contracts.
With this strategy the government intends to strengthen the dialogue between law enforcement agencies and Companies House as well as the central registers of UK Overseas Territories and Crown Dependencies to ensure that law enforcement can more effectively use information contained in PSC people with significant control registers, registers of taxable relevant trusts and registers of company beneficial ownership information.
The new Minister for Economic Crime will have oversight of anti-corruption. Bertling Limited and six of the individuals for conspiracy to make corrupt payments, contrary to section 1 of the Criminal law Act and section 1 of the Prevention of Corruption Act Bertling Limited also pleaded guilty. To the extent that F. This would be the first such conviction, and would underline the oft-stressed point that English law does not allow any exception for facilitation payments.
On October 20, three of the individuals were sentenced, fined and disqualified as company directors.
Bertling Limited, Mr Morreale and Mr Emler will be sentenced following the conclusion of connected proceedings against F. The resolution represents the largest ever criminal enforcement action against a company in the UK following an extensive four-year investigation by the SFO. The investigation concerning the conduct of individuals remains ongoing. A further individual, Petros Contoguris, who worked as an intermediary for Rolls-Royce was indicted.
The individuals involved all held significant roles within Roll-Royce or firms connected with the company: Mr Contoguris acted as an intermediary of Rolls-Royce in Kazakhstan.
The scheme involved two directors, Kevin McKee and John Zayya of Alandale making corrupt payments to the senior manager of a joint venture Innocent Obiekwe that oversaw the award of contracts in relation to the upgrade of Farringdon railway station in London. After improperly obtaining the contract, the three then colluded in manufacturing false invoices to enable Alandale to recover the cost of its bribes. When the scheme started to be uncovered, the bribes continued to be paid through an intermediary William Waring.
Nobody involved self-reported and the conduct was only uncovered after a whistleblower came forward from within Alandale. The two directors of Alandale, the recipient of the bribes, and the intermediary all pleaded guilty and were sentenced.
The bribe-paying directors received 12 months and 2 years respectively. Following a trial at Blackfriars Crown Court the bribe recipient was sentenced to 12 months in jail, and the intermediary was sentenced to 2 years. These sentences appear more lenient than might have been expected based on the usual application of the sentencing guidelines, which require that the base number used for calculating the fine for a corporation guilty of bribery or corruption is the gross profit from the contract obtained as a result of the offending.
This would then be increased or decreased depending on the presence of aggravating or mitigating circumstances, with a lowest fine available of 20 percent of the base figure. As Alandale did not plead guilty, the availability of maximum mitigation is unlikely to have been available. In addition, the Sentencing Guidelines also require a convicted company to have its profits disgorged from an improperly obtained contract.
No such order was made in respect of Alandale. It is unclear why the Sentencing Guidelines, which should be binding, may not have been followed in this case, or why the prosecution do not seem to have sought permission to appeal the sentence. In any event, it would be wrong for companies to assume that this case is anything other than a notable outlier. This is more than in any other year in the last decade. These were all prosecuted by the Crown Prosecution Service, but investigated by different parties.
With custodial sentences ranging up to 15 years, has also seen the longest ever custodial sentence for bribery and corruption offences. Buckingham Palace works contracts Bernard Gackowski pleaded guilty to conspiracy to make corrupt payments in relation to the Buckingham Palace works bribery scandal which we reported on in our Year End United Kingdom White Collar Crime Alert. He was given a month sentence suspended for two years and ordered to do hours of unpaid work.
The benefit was a holiday and it was in return for Farr providing confidential information relating to an adoption. Other than an example of the appetite of the UK authorities to prosecute low-value bribery, the case is only otherwise noteworthy as being a rare instance of a prosecution under the Public Bodies Corrupt Practices Act Five individuals were all convicted under the Bribery Act in relation to payments for confidential insurance information.
All but Shaiad Nawaz pleaded guilty. All five were sentenced on August 25, and were given suspended custodial sentences ranging from 6 months to 12 months. Mr Tough was the twenty-third individual convicted under the Bribery Act. We will not list all of those here, but only those where there have been significant developments during the course of Unaoil — Other Companies Involved The SFO is continuing its investigation into Unaoil for suspected bribery, corruption and money laundering offences after allegations of bid-rigging in the oil and gas industry were made against Unaoil and its directors, employees and agents.
The investigation, which has been ongoing since March , now includes a number of other companies involved with Unaoil. The alleged bribery in Iraq involved the use of Unaoil as an intermediary to pay bribes to foreign officials in Iraq to secure contracts./p>
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