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October 22, 2013 8:50 AM  | Link
For regular commentary on issues related to Anti-Corruption and Anti-Bribery, follow us at: and for issues specifically related to Asset Recovery, follow us at: read more
April 16, 2014 10:14 AM | Permalink |
Antonio Suarez-Martinez
The City of London Police Overseas Anti-Corruption Unit (OACU) has launched a video highlighting the damaging consequences for UK companies and individuals of engaging in corrupt business activities. read more
April 15, 2014 1:16 PM | Permalink |
Antonio Suarez-Martinez
Whilst the Serious Fraud Office (“SFO”) is expected to walk the talk in response to the Bribery Act, it expects corporates to do the same when self-reporting wrongdoing. read more
April 14, 2014 12:39 PM | Permalink |
Antonio Suarez-Martinez
The White House has publicised a legislative proposal as part of the President’s budget to help law enforcement investigate the use of shell companies for unlawful purposes including money laundering. read more
April 9, 2014 10:14 AM | Permalink |
James Maton
The English Court of Appeal has decided that the National Crime Agency is entitled, in civil recovery proceedings, to all of the profits made on investments funded in part by the proceeds of crime and in part by loans made by a bank. read more
Towards the end of last year the OECD published a report on measuring OECD country responses to illicit financial flows from developing countries (“the Report”). read more
April 1, 2014 3:27 PM | Permalink |
James Maton

Trace International has published its 2013 report summarising international anti-bribery enforcement trends.

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March 27, 2014 10:40 AM | Permalink |
Ajita Shah
The International Commission Against Impunity in Guatemala (CICIG) recently received a €4m boost from the European Union (EU) when the EU and the United Nations in Guatemala signed a cooperation agreement worth €4m or 44 million Guatemalan Quetzales to support the work of the CICIG. read more
The United States and Europe have launched two rounds of sanctions against Russia, which formally annexed the Crimean region of Ukraine on March 21st. The recent addition of 20 more individuals and Bank Rossiya to the U.S. black list has begun to have ramifications for the Russian economy, as reported by The Economist1, The Wall Street Journal2, and Bloomberg3. Some lawmakers advocate for more stringent sanctions, such as the type that were imposed against Iran. But Washington has other tools at its disposal that could more subtly dampen the Russian economy without requiring legislative action.   read more
Money laundering and tax evasion will be harder to hide following the approval of new amendments to the EU’s proposed Fourth Anti-Money Laundering Directive by the European Parliament on Tuesday, 11 March 2014 which in future will require the ultimate owners of companies and trusts to be listed in public registers in EU countries. read more
“Breathtaking" is how one European Commissioner characterized the corruption described in the European Commission's February 2014 Anti-Corruption Report, which details each E.U. Member State's efforts in fighting corruption and provides advice for improving the effectiveness of those efforts. read more
Following the Council of the European Union’s agreement through Council Regulation (EU) 208/2014 on 6 March 2014 to impose financial sanctions, including asset freezes, against certain Ukrainian persons, entities and bodies in view of the situation in Ukraine, the UK Treasury has published its financial sanctions notice (the Notice). read more

Antonio Suarez-Martinez has co-written a piece with Nick Maxwell of Transparency International UK for Money Laundering Bulletin on “Closing down the UK as a safe haven for corrupt assets” available here


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On Friday, 28 February, the Swiss Public Prosecutor very publicly declared that it had launched a money laundering investigation into deposed Ukrainian President Viktor Yanukovych and his son Oleksandr. read more
The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury on February 25, 2014 warned all financial institutions “to take reasonable, risk-based steps regarding the potential suspicious movement of assets related to Viktor Yanukovych departing Kyiv and abdicating his responsibilities and other senior officials resigning from their positions or departing Kyiv.” This action comes amidst widely published allegations that Ukrainian officials, and especially President Yanukovych, used their offices to enrich themselves.   read more
February 25, 2014 10:12 AM | Permalink |
James Maton
The United Kingdom’s Supreme Court has handed down an important judgment on the limitation period for two types of claim that can be deployed in civil proceedings against third parties that have wrongfully assisted with the transfer or concealment of corrupt assets. read more
February 24, 2014 11:22 AM | Permalink |
Antonio Suarez-Martinez

After a long wait and public consultation process, Deferred Prosecution Agreements (“DPAs”) became available to prosecutors in England & Wales from 24 February 2014.

Under a DPA, a company that has engaged in unlawful conduct can avoid prosecution in exchange for certain promises to the prosecution, for example, the payment of a financial penalty, implementation of a compliance programme, compensation for victims and costs. DPAs can lead to a situation of mutual benefit where the company avoids a public trial and potential conviction, and the prosecutor avoids the expense of a prosecution. However, if the company fails to comply with the terms of a DPA then this would allow the prosecutor to reopen the prosecution

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On 20 February, the EU’s Economic Affairs and the Justice and Home Affairs committees voted to amend the proposed Fourth EU Anti-Money Laundering Directive (“the AMLD”) to require the ultimate owners of companies, foundations and trusts be listed in public registers in EU countries. read more
February 19, 2014 12:20 PM | Permalink |
Stephen Huggard, Haley Morrisson
More than ever before, financial institutions must have effective anti-money laundering policies. In his recent speech to the Association of Certified Anti-Money Laundering Specialists, U.S. Attorney for the Southern District of New York Preet Bharara emphasized that enforcing the Bank Secrecy Act (BSA) and anti-money laundering laws is a priority for his office, and that he expects financial institutions to assist in the fight against money laundering, or else pay a steep price.   read more
Governments that have identified the proceeds of corruption located abroad have a number of criminal and civil mechanisms available to recover them. read more
In 1986, the President of the Philippines, Mr Ferdinand E. Marcos, was deposed by a non-violent coup later popularised as the ‘People Power Revolution’. During his tenure, Mr Marcos, his family and close associates are alleged to have illicitly looted public assets to amass a huge personal fortune. read more