WilmerHale W.I.R.E. UK RSS Feed

UK Financial Sanctions Compliance and Enforcement Update

Tue, 17 Feb 2026 14:56:00 Z

January 2026 brought tougher UK sanctions enforcement, a single sanctions list, and new OFSI penalties emphasizing stronger screening and disclosure.

FCA Enforcement Trends In 2025 And Expectations For 2026

Fri, 09 Jan 2026 06:30:00 Z

FCA aims for fewer probes, quicker resolutions, and stronger financial crime enforcement in 2026.

UK White Collar Crime: 2025 Year-End Roundup

Mon, 29 Dec 2025 14:00:00 Z

2025 was a watershed year in UK white collar crime enforcement and corporate compliance, with organisations facing a new and more dangerous landscape of criminal liability along with significant regulatory shifts.

Budget 2025: HMRC whistleblower scheme a welcome change

Tue, 02 Dec 2025 17:00:00 Z

The UK government, through HMRC, has announced a new whistleblower reward scheme in the 2025 Budget, wherein whistleblowers can receive up to 30% of tax amounts collected over £1.5 million based on their information.

New UK SFO Guidance on Evaluating Corporate Compliance Programmes

Mon, 01 Dec 2025 14:24:00 Z

On 26 November 2025, the UK Serious Fraud Office (“SFO”) published an updated version of its Guidance on Evaluating a Corporate Compliance Programme (the “Guidance”).

Non-Financial Misconduct: Navigating the Emerging Divergence between the U.S. and U.K.

Mon, 22 Sep 2025 13:14:00 Z

The UK and US are taking diverging paths on workplace misconduct and DEI, creating compliance challenges for global companies.

UK Independent Review of the Criminal Courts – Part 1

Tue, 22 Jul 2025 12:56:00 Z

On 9 July 2025, part 1 of the Independent Review of the Criminal Courts, chaired by Sir Brian Leveson was published.

Why UK Sanctions Review Recommendations Lack Substance

Fri, 27 Jun 2025 15:15:00 Z

On 15 May 2025, the UK Government published the conclusions of its cross-government review of UK sanctions implementation and enforcement.

The FCA abolishing its plans to name and shame is a welcome move

Tue, 10 Jun 2025 17:23:00 Z

Never before have the Financial Conduct Authority’s proposals attracted such widespread outcry: from politicians, the financial services industry and practitioners alike, all have condemned the regulator’s plans announced in February 2024: to ‘name and shame’ investigation subjects at an early stage in the investigation.

New SFO Guidance Unlikely to Drive Increase in Self-Reporting of Corporate Wrongdoing

Thu, 08 May 2025 15:00:00 Z

The UK SFO's new guidance encourages self-reporting of corporate wrongdoing, favoring DPAs over prosecution, but does not guarantee them.

FCA's Regulatory Plans Signal Cause For Cautious Optimism

Wed, 23 Apr 2025 19:21:00 Z

This blog post discusses the FCA's recently released 2025-2030 strategy document.

Europe’s anti-corruption alliance: a shift in global enforcement leadership?

Thu, 17 Apr 2025 14:52:00 Z

The UK, France and Switzerland’s respective anti-corruption agencies have long been active in Europe and have a track record of working closely and well together.

What FCA's 2024 Changes Suggest For Enforcement In 2025

Wed, 18 Dec 2024 15:20:00 Z

Over the last year, there has been much change at the FCA, and apparently, more is to come.

Concerns remain over FCA’s ‘name and shame’ proposals

Wed, 04 Dec 2024 15:36:00 Z

An enforcement investigation by the Financial Conduct Authority (FCA) can be an extremely expensive and stressful experience for regulated firms and individuals alike.

FCA Survey Results Reveal Rise In Nonfinancial Misconduct

Tue, 26 Nov 2024 16:28:00 Z

Make no mistake, nonfinancial misconduct remains at the top of the Financial Conduct Authority's agenda. While the financial industry awaits a policy statement from the FCA on nonfinancial misconduct finalizing changes to its rules as consulted on last Autumn, in October the regulator published the results of its February survey on nonfinancial misconduct.

UK Sanctions - Autumn Roundup

Wed, 23 Oct 2024 15:08:00 Z

In recent months there have been a number of significant developments in the UK sanctions space. This blog post summarises a few of them.

Nick Ephgrave’s First Year as SFO Director

Wed, 09 Oct 2024 14:45:00 Z

Nick Ephgrave QPM, the Director of the Serious Fraud Office (“SFO”), recently marked the end of his first year in office. Ephgrave has brought a renewed energy, sense of purpose and proactive approach to the SFO, opening six new investigations, improving staffing levels and significantly increasing the number of dawn raids and arrests. He has demonstrated ambition and innovation as he seeks to improve the culture, performance and reputation of an agency that has faced more or less continuous criticism since its establishment in 1988. However, as with all previous Directors, Ephgrave’s ability to truly transform the SFO over the remainder of his tenure remains hamstrung by the perennial issue of limited funding.

Society of Lloyd’s Acts to Toughen Byelaws for #MeToo Era

Thu, 26 Sep 2024 16:21:00 Z

Reflecting broader societal concerns and trends, the City of London has come under pressure to tackle poor behaviours that previously may have had an unclear regulatory status. Michelle Diamond and Imogen Makin discuss a Society of Lloyd’s consultation on amending formal powers to clamp down on non-financial misconduct.

Asset freezing and asset seizing under the UK sanctions regime

Wed, 21 Aug 2024 13:21:00 Z

The UK’s National Crime Agency (NCA) recently secured its first forfeiture of sanctioned funds.

Rewarding Whistleblowers Will Only be Effective as Part of a Wider Package of Reforms

Thu, 08 Aug 2024 14:40:00 Z

SFO Director Nick Ephgrave supports financial rewards for whistleblowers, but they should be part of broader reforms to improve protection and impose sanctions against retaliation, as financial incentives alone will have limited impact.

Lloyd's Law Reports: Financial Crime

Tue, 30 Jul 2024 16:06:00 Z

In this case note for Lloyd’s Law Reports, Alice Lepeuple and Chris Ladusans analyze the Court of Appeal’s recent decision in Celestial v. Unicredit, and its implications for how parties should manage their duties to comply with international sanctions laws alongside their commercial obligations under letters of credit.

Sexism in the City

Thu, 11 Apr 2024 16:58:00 Z

#MeToo is still moving across the pond. On March 8, 2024, the House of Commons Treasury Committee published a report entitled “Sexism in the City” (referenced as “Report” in this article), which found that the financial-services sector had made little progress in removing the systemic barriers faced by women in the workplace or the prevalence of sexual harassment.

USA v. Robertson: Implications for UK White-Collar Crime Practitioners

Thu, 11 Apr 2024 13:38:00 Z

In USA v Robertson, the USA Court of Appeals for the District of Columbia Circuit examined the meaning of corruption in cases of obstruction of official proceedings. Alice Lepeuple discusses the implications of the judgment for UK white-collar crime practitioners in a casenote for Lloyd’s Law Reports: Financial Crime.

FCA Business Plan: Firms Should Expect Assertive Supervision, Enforcement on Financial Crime as 2022-2025 Strategy Enters Final Year

Thu, 28 Mar 2024 15:26:00 Z

The UK Financial Conduct Authority is entering the final year of its 2022-2025 strategy, which features a commitment to be more innovative, assertive and adaptable. Its 2024/25 Business Plan outlines how the regulator intends to fulfil that promise in the next 12 months.

Will Companies House powers clean up the register?

Thu, 21 Mar 2024 15:27:00 Z

Companies House has been granted new powers to crack down on fraud, but whether it has the resources to take advantage of these and properly clean up the register of companies is questionable.

The Good, The Bad And The New Of The UK Sanctions Regime

Fri, 08 Mar 2024 18:19:00 Z

This blog post details the key takeaways from the Foreign Commonwealth and Development Office's recently published strategy paper.

FCA – Financial Crime Focus Areas for 2024

Tue, 05 Mar 2024 21:26:00 Z

The Financial Conduct Authority published a progress update and identified four key areas of focus for the agency in reducing and preventing financial crime going forwards.

FCA Highlights Risks Posed to Firms by Organised Crime Groups (OCG) and How Firms Can Mitigate These

Wed, 21 Feb 2024 21:30:00 Z

Combatting financial crime continues to be a key supervisory and enforcement priority for the FCA. The importance of this area was reiterated by the FCA’s February 2024 newsletter - Market Watch 77 - which sets out observations on insider trading and market abuse by OCG, and advises firms on how to mitigate the risks of being used by OCG to facilitate such trading.

SFO Director Nick Ephgrave: The First 100 Days

Fri, 12 Jan 2024 19:21:00 Z

The new SFO Director, Nick Ephgrave QPM, marks his first 100 days in post this month after succeeding Lisa Osofsky in September 2023. Ephgrave has overseen a dynamic start to his tenure with the announcement of three new investigations in quick succession.

White Collar Crime Year in Review

Mon, 18 Dec 2023 21:07:00 Z

2023 has been a year of change at the SFO with a new Director, enhanced investigatory powers and new statutory regime that will make it easier to prosecute corporate criminal offenders.

OTSI – the UK’s Specialist New Trade Sanctions Agency

Fri, 15 Dec 2023 19:18:00 Z

On 11 December 2023, the UK’s Industry and Economic Security Minister announced the creation of a new UK agency dedicated to implementing and enforcing trade sanctions. The Office of Trade Sanctions Implementation (OTSI) will operate as a sister unit to the existing Office of Financial Sanctions Implementation (OFSI).

A “New” City Bobby: Proactive FCA Supervision and Enforcement

Thu, 16 Nov 2023 20:17:00 Z

While the FCA may be facing its own difficulties with the timely resolution of cases, a proactive and prompt response if the FCA approaches a firm or individual will not only be well received but may be the deciding factor in whether a matter is referred to the enforcement team. It is also worth bearing in mind that “harder-edged” engagement with the FCA is not limited to enforcement; supervision can be equally robust.

The Financial Conduct Authority’s Review of Firms’ Approaches to Politically Exposed Persons

Tue, 24 Oct 2023 16:06:00 Z

The UK Financial Conduct Authority (FCA) launched in September a review of the treatment of domestic politically exposed persons (PEPs) by UK-regulated financial services firms. This review will look at firms’ arrangements for dealing with domestic PEPs and the potential money laundering risks that these PEPs can pose.

OFSI Encourages Self-Reporting of Sanctions Breaches

Mon, 16 Oct 2023 13:27:00 Z

Recent statements from the heads of OFSI and OFAC indicate that companies self-reporting minor and unintentional sanctions breaches in the UK and the US, acting in good faith, are unlikely to face enforcement actions.

The FCA’s Proactive Enforcement Approach Exacerbates Growing Case Backlog

Wed, 23 Aug 2023 16:15:00 Z

The UK Financial Conduct Authority (FCA) recently published its Annual Report and Accounts for the year ending March 2023, representing the first opportunity to assess progress made in the three-year strategy previously set out by the FCA.

Digital Assets Consultation Offers First Step In Regulation

Tue, 11 Jul 2023 15:48:00 Z

The International Organization of Securities Commissions published a consultation report in May intended to establish a clear and robust international baseline for the regulation of, and international cooperation in respect of, cryptocurrency and digital assets to address the market integrity and investor protection risks in crypto-asset markets.

Call for Reform of Regulatory Supervision of Auditors

Wed, 07 Jun 2023 15:16:00 Z

Increasing use of close supervisory and enforcement tools is putting auditors under pressure, but it needs to be reformed to speed up investigations, argue Richard Burger and Lindsey Cullen.

Responding to Allegations of Non-Financial Misconduct: Getting It Right

Fri, 12 May 2023 15:43:00 Z

Several recent, well-publicised allegations of non-financial misconduct have served as a potent reminder of the significant risks associated with these allegations and the vital role of a carefully-crafted investigative response.

Money Laundering In The UK Art Market: Key Risks, AML Rules

Thu, 20 Apr 2023 13:16:00 Z

WilmerHale Associate Lindsey Cullen discusses the recently released FATF report underlining the risks of money laundering in the art market and uses it as a prompt for AMPs in the UK to reassess their standard of AML compliance.

The Gambling Commission reaffirms its status as one of the UK’s most active AML enforcement authorities.

Fri, 31 Mar 2023 17:48:00 Z

This blog discusses the UK Gambling Commission’s criminal and regulatory powers and explores some of the key learnings for companies in the gambling sector from recent enforcement actions in relation to compliance failures.

Significant UK Ruling on the Contours of Criminal Liability for Human Rights Abuses Occurring in Overseas Supply Chains

Wed, 15 Feb 2023 21:12:00 Z

A recent UK High Court decision clarifies the risks for companies operating in the UK being criminally investigated in respect of forced labour and other human rights abuses occurring in their overseas supply chains.

Kicking the Can? An Analysis of the UK Government’s Response to the Parliamentary Select Committee’s Report on Fraud and the Justice System

Tue, 31 Jan 2023 16:50:00 Z

The UK Government recently published its response to the Parliamentary Justice Select Committee report "Fraud and the Justice System." The report and the Government's response form part of the ongoing public debate about how to address the current fraud epidemic in England and Wales.

Online Safety Bill - Update on Senior Manager Liability

Mon, 30 Jan 2023 01:00:00 Z

The Online Safety Bill (the “OSB”) is back on the UK Government’s legislative agenda, this time with an important update relating to criminal liability of senior managers.

Sanctions, Fraud is Coming to Town: 2022 in Review

Thu, 22 Dec 2022 14:37:00 Z

In 2022, the UK government, facing criticisms for being soft on economic crime, turned its focus to long-awaited legislative reforms, but questions remain over whether criminal and regulatory agencies will be given the funding they need to make use of their new powers. A relatively sluggish year for enforcement suggests more investment is needed.

Law Commission POCA Reform—Is the Game Worth the Candle?

Wed, 14 Dec 2022 16:37:00 Z

Recovering criminal assets is difficult. A good recent example of this difficulty came in October this year, when the Treasury estimated that it could recover just £1.2 billion of the £4.5 billion lost to Covid fraud. However, even when defendants are convicted, recovering criminal assets presents a significant challenge.

UK GDPR Restrictions on Personal Data Transfers to South Korea Are Lifted

Thu, 08 Dec 2022 14:08:00 Z

In November 2022, the UK Government announced that it had put in place UK GDPR ‘adequacy regulations’ in respect of South Korea (the Republic of Korea (“ROK”)). These new regulations will allow UK based organisations to transfer personal data to ROK without restrictions.

The Continued Restricted Use of Information Obtained via Mutual Legal Assistance Request

Tue, 06 Dec 2022 16:40:00 Z

On 4 November 2022, the UK High Court reaffirmed the principle that information obtained via Mutual Legal Assistance requests can only be used for the purpose for which it was obtained, as articulated in the terms of the request, absent consent from the overseas authority.

UK Regulators Proposed Framework for Critical Third Parties

Thu, 06 Oct 2022 12:00:00 Z

Financial services firms are increasingly reliant upon third-party companies to provide important services, ranging from cloud services and data analytics to machine learning and cash distribution.

Avoid Contributing to Ecocide - Know Your Supply Chain

Wed, 28 Sep 2022 15:11:00 Z

Sustainability has risen to the top of the agenda for businesses around the world. Governments, investors and the public demand that organisations play a part in the global push to eliminate, or at least limit, the environmental impact of their business operations.

Failure to Prevent Money Laundering

Wed, 28 Sep 2022 13:37:00 Z

On 10 June 2022, the Law Commission published its long-awaited options paper on Corporate Criminal Liability (“the Paper”).