Sanctions: a new dawn for enforcement in the UK? Following Russia’s invasion of Ukraine, the UK’s sanctions regime underwent significant change at speed. The UK’s Office of Financial Sanctions Implementation (OFSI) described 2022-2023 as “a genuinely historic and transformative period for the use of financial sanctions at both global and UK levels”, and it is likely that this will continue over the next 12 months. Given OFSI’s enforcement team has nearly doubled in size in the last financial year, and the government has announced the implementation of a new unit (the Offic ..read more

The UK Appointed Representative Regime (ARR) enables certain businesses – Appointed Representatives (ARs) – to conduct UK-regulated activities without having to be authorised by the Financial Conduct Authority (FCA). Instead, a fully authorised firm (a Principal) accepts responsibility for the AR’s actions and compliance with regulatory requirements. This has proven a popular arrangement, especially for startups and smaller businesses. According to the FCA there are currently around 40,000 ARs with 3,600 Principals. However, the FCA is concerned that ARs are a disproportionate source of UK con ..read more

As anticipated, the Economic Crime Bill was passed and became the Economic Crime (Transparency and Enforcement) Act 2022 on 14 March 2022. Overseas entities, their beneficial owners and officers may take steps now to consider whether they are required to make an application for registration. Click here to read the full GT Alert ..read more

In December 2021, the UK Financial Conduct Authority (FCA) published a consultation to set a higher standard of consumer protection in retail financial markets, an endeavor which began in July 2018. At the core of the proposed new rules is a new Principle for Businesses: “A firm must act to deliver good outcomes for retail customers”. In this GT Alert we focus on seven key takeaways for regulated businesses. Click here to continue reading the full GT Alert ..read more

The Appointed Representatives Regime (ARR), a well-known and important feature of the UK regulatory landscape, enables certain businesses – Appointed Representatives (ARs) – to conduct regulated activities without having to be authorised by the Financial Conduct Authority (the FCA). The FCA is proposing significant new rules and guidance that seek in the main to increase the regulatory burden on Principals to oversee ARs and to provide information to the FCA. According to the FCA, there are currently around 40,000 ARs with 3,600 Principals. Click here to read the full GT Alert ..read more

To expedite decisions to prevent or stop consumer harm, the Financial Conduct Authority (FCA) has implemented a controversial change to its decision-making procedures. The change forms part of the FCA’s wide-ranging “Transformation Programme” that seeks (in summary) to make the regulator smarter, more proactive and more agile. Click here to read the full GT Alert ..read more

Welcome to the May 2021 issue of GT’s Competition Currents, a monthly newsletter for Greenberg Traurig clients and colleagues highlighting significant developments in global antitrust and competition law. Click here to read the full newsletter ..read more

Welcome to the March 2021 issue of GT’s Competition Currents, a monthly newsletter for Greenberg Traurig clients and colleagues highlighting significant developments in global antitrust and competition law. Click here to read the full newsletter ..read more

With the UK now no longer part of the EU, and EU law ceasing to apply at the end of the current transitional period, the future application of many of the bloc’s laws and regulations in the UK (and if/how the UK will transpose them) is the subject of increased speculation, not least in the already complex area of sanctions law. Some of that speculation was put to bed when on 6 July 2020 Foreign Secretary Dominic Raab placed before Parliament the Global Human Rights Sanctions Regulations 2020 (the Regulations) which provide for the freezing of funds and economic resources of certain persons, en ..read more

The UK’s sanctions monitor, the Office of Financial Sanctions Implementation (OFSI), has issued its biggest fine to date, imposing a total financial penalty of approximately £20.47 million on Standard Chartered Bank for breaches of EU and UK sanctions in relation to Ukraine. The fine, which was imposed after review by John Glen, Economic Secretary to the Treasury, represents a significant increase on OFSI’s previous (and at that point largest) financial penalty of £146,341, issued against Telia Carrier UK Limited (Telia), for having ‘indirectly facilitated international telephone calls’ to a ..read more