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TI-UK publishes response to the Cayman Island’s consultation on providing legitimate interest access to beneficial ownership

Claims that proposals, in their current form, will not enhance the Cayman Islands effort to tackle money laundering, corruption and its predicate offences, nor will it strengthen the integrity of its financial services.

TI-UK analysis reveals £5.9bn in suspicious funds used to purchase UK properties via shell companies in UK’s Overseas Territories, with over 90% channelled through the British Virgin Islands

Corporate secrecy in the UK’s Overseas Territories plays a central role in enabling corruption, money laundering, and the evasion of tax and sanctions on a global scale. The research highlights the Overseas Territories’ role as global hubs for suspicious and illicit wealth. The secrecy provided by these jurisdictions have made them destinations of choice for corrupt individuals seeking to conceal criminal acts and enjoy the proceeds of their crimes with impunity. Greater transparency is essential to trace these financial flows, not only within the property sector but in the broader fight against corruption and money laundering. Of UK£11.1 billion (US$14.1bn) invested in 1,600 UK properties, since 2016, using funds with dubious origins, half (UK£5.9bn (US$7.5bn)) came via shell companies set up in UK Overseas Territories, with most (UK£5.5bn (US$7.0bn) from entities registered in the British Virgin Islands (BVI)…

New ICO Guidance on sharing personal data in fraud investigation provides important directions for organisations on how to lawfully share personal data under UK GDPR

The ICO Guidance aligns with UK Govt Guidance measures that encourages voluntary information sharing for preventing economic crime, as outlined in the ECCT Act 2023. Key takeaways: Data Protection Impact Assessments (DPIA) Required – to assess and mitigate risks associated with sharing personal data for fraud investigations. Clear Data-Sharing Agreements – to ensure there is a lawful basis for sharing personal data under GDPR. Provide Practical Tools, Templates & Case Studies – to assist organisations in staying compliant when sharing data. Supporting Cross-Sector Collaboration – to improve the overall impact of data-sharing efforts…

Isle of Man FSA releases a series of videos to raise awareness of proliferation financing risks

The videos are part of a PF outreach programme being coordinated by a number of government agencies, including the Financial Services Authority, Gambling Supervision Commission, Financial Intelligence Unit, Cabinet Office, and Treasury’s Customs and Immigration Division.The recordings will cover a range of key topics to enhance understanding of PF and assist firms in meeting their obligations in relation to the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Code 2019. The proliferation of weapons of mass destruction is identified by the FATF as an emerging threat in terms of financial crime…

 

Bank of England and FCA 2024 survey on AI and Machine learning in UK financial services, reveals a sharp increase in AI adoption, with 75% of firms now use AI, with growing reliance on third-party providers

Of the top five perceived current risks, four are related to data: data privacy and protection, data quality, data security, and data bias and representativeness. The risks that are expected to increase the most over the next three years are third-party dependencies, model complexity, and embedded or ‘hidden’ models. The increase in the average perceived benefit over the next three years (21%) is greater than the increase in the average perceived risk (9%). Cybersecurity is rated as the highest perceived systemic risk both currently and in three years. The largest increase in systemic risk over that period is expected to be from critical third-party dependencies…

 

 

 

Home Office releases ‘New Guidance on Failure to Prevent Fraud,’ offering key insights on corporate criminal offense compliance

The Guidance clarifies the steps large organisations must take to avoid criminal liability for fraud committed by their employees or agents. Effective from Sept 2025, this offence holds companies accountable if they profit from fraud, requiring them to demonstrate “reasonable procedures” to prevent such activities. The guidance emphasizes the need for a strong anti-fraud culture…

Legal Services Board consults on guidance for new regulatory objective on economic crime

Views sought on proposals to underline the important role of legal services regulators in tackling economic crime. This follows a new legal duty being placed on the LSB and the legal services regulators to ‘promote the prevention and detection of economic crime’.

HM Treasury announces further reforms to UK MiFID framework

HM Treasury has committed to make the changes to the UK’s Markets in Financial Instruments Directive (MiFID) framework as part of the government’s work to reform our rulebook for capital markets so that it delivers for investors and firms, and supports growth across the UK.

OFSI issues Financial sanctions guidance for High Value Dealers & Art Market participants

It provides financial sanctions guidance for entities and individuals that operate in the sale or trade of high value goods, especially those trading internationally with regions that may be subject to UK…

NCA issues its 28th SARs in Action magazine, focusing on the Camden Asset Recovery Interagency Network (CARIN), and international stakeholders collaboration in AML

CARIN is involved in the tracing, freezing, seizure and confiscation of international assets. Other organisations covered in this newsletter are Egmont Group and AUSTRAC.

FATF issues call to South Africa to advance efforts to enhance measures against ML and terrorist financing.

Since its 2021 mutual evaluation and the 2023 Follow-Up report, South Africa has made significant progress in strengthening its anti-money laundering and counter-terrorist financing measures. The country has improved its ratings in several FATF recommendations, with three re-rated from partially compliant to largely compliant. South Africa is now compliant on 5 recommendations and largely compliant on 32…

HM Treasury releases consultation response and draft legislation on regulating ESG ratings providers

HM Treasury has published its response to the outcome of its consultation on the future regulatory regime for Environmental, Social, and Governance (ESG) ratings providers, detailing the scope of the proposed regulatory framework, along with related draft legislation. Responses and comments on the draft regulation are sought by 14 January 2025.

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