Tipping off meaning

According to the Department for Business and Trade, a former Insolvency Service employee, who remains anonymous, supplied The Times, the Financial Times and Sky News in November 2023 with confidential details about the agency’s plan to seek director disqualification against Greensill. The government’s High Court defence, dated 29 April 2024 and now public, asserts this constituted unlawful processing of the Australian businessman’s personal data under the UK GDPR, together with a breach of confidence and misuse of private information. However, the government rejected the contention that the disclosures caused Greensill “significant anxiety and distress”. By then, the department argued, the ex-Citigroup and Morgan Stanley banker’s standing as a businessman was “already significantly, if not irreparably, damaged”. Greensill issued proceedings against the government in March 2024, seeking damages and compensation, contending that the Insolvency Service’s investigation was “an obviously confidential and private process”. He alleges the staff member, referred to only as X, infringed his privacy by tipping off the media about the scope and key areas of focus in the...

Across sectors where high‑value, cross‑border transactions are commonplace, exposure to financial crime is pronounced. Specific hazards include the possibility that assets traded are stolen or were acquired with the proceeds of crime; that either buyer or seller is implicated in terrorist activity; or that the asset functions simply as a vehicle for money laundering or terrorist financing. Although anti‑money laundering (AML) controls—such as requirements to disclose suspicious activity—are now firmly embedded within many firms’ compliance procedures, the absence of parallel counter‑terrorist financing controls persists as a key weakness. There are important lessons to draw from Ojiri’s case. Art sales lead to hot water From October 2020 to December 2021, Ojiri is reported to have sold eight artworks, with a combined value of £140,000, to an individual alleged to be involved in terrorist financing. Although this individual was not personally designated under the UK sanctions regime until April 2023, he had been listed by US authorities in 2019 as a ‘special designated global terrorist’, thereby barring him from entering...

In the words of the Education Committee, the special educational needs and disabilities (SEND) system is ‘broken’ () The current SEND framework was never built to handle today’s caseload. Outlays are rising to unsustainable levels while results worsen and trust has ebbed away. For five years, ministers have relied on a statutory override to keep SEND shortfalls off council balance sheets—an accounting fix that alone has stopped nearly half of local authorities from tipping into effective insolvency. This override lapses in March 2028; by then, the Office for Budget Responsibility (OBR) expects cumulative gaps to total £14bn. While the last administration largely looked on, Labour—credit where due—is beginning to move, with reforms slated (after repeated slippage) for early 2026. Last week’s budget pledge to centralise SEND costs has given councils firmer medium‑term financial certainty, vital for strategic planning. It also signals the government is taking the reins: from 2028/29, all subsequent deficits—projected at £6bn in year one—will be met centrally...

This Practice Note offers advice on setting up systems and controls to meet obligations under the UK sanctions framework. It excludes systems and controls for organisations providing sanctions-related services, e.g. contesting designation decisions, which demand specialised skills and expertise. Your systems and controls There are several actions to take when creating your systems and controls. You should: evaluate your potential exposure to sanctions restrictions, i.e. carry out an organisation-wide risk assessment use the findings to design and implement suitable policies and procedures, covering due diligence, screening against sanctions lists, and steps to follow if a designated person is identified, etc keep appropriate records of sanctions compliance, including the organisation-wide risk assessment, per customer/matter risk assessments, policies and procedures, and investigations into possible matches, etc train staff on the sanctions framework and your internal procedures regularly review your systems and controls report regularly to senior management on the sanctions risks faced and the effectiveness of your systems and controls ...

Within the regulated sector, several distinct offences exist for tipping-off and for conduct that could prejudice an investigation. A distinct offence of prejudicing an investigation applies solely to the unregulated sector. An additional offence relating to the interference with documents captures activity across both sectors. This Practice Note examines tipping-off and the prejudicing of a money laundering investigation under the Proceeds of Crime Act 2002 (POCA 2002). It accords with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692. For guidance on what amounts to the regulated sector, see Practice Note: Money laundering—key information for law firms. Suspicious activity report The main money laundering offences are: concealing criminal property being concerned in an arrangement that facilitates money laundering possessing criminal property POCA 2002 imposes a duty to report knowledge or suspicion of money laundering, which is done by submitting a suspicious activity report (SAR)...

While the Investigatory Powers Act 2016 (IPA 2016) largely superseded the Regulation of Investigatory Powers Act 2000 (RIPA 2000), the Part III provisions of RIPA 2000—dealing with the ability of public bodies to issue notices requiring the decryption of encrypted information or the provision of decryption keys—remain in effect, albeit as modified by the IPA 2016. For further details on the IPA 2016, see Practice Note: The regulation of intelligence gathering—an introductory guide... Investigation of encrypted electronic data RIPA 2000, Pt III governs investigations by a public authority into electronic data protected by encryption. The statutory scheme is supplemented by a Code of Practice, which is admissible in evidence in both criminal and civil proceedings. A wide range of methods enable businesses, individuals and criminals to secure and protect their electronic data and to maintain the privacy of their electronic communications. Such protection can be implemented in various ways; at its simplest, a password may unlock the data and render it accessible in an intelligible form...

1 Assemble an incident management team Demonstrate a truly proactive stance by involving the right people from the start. Taking action early signals that you are actively managing the situation. As the nominated officer holds ultimate responsibility for any external reports, ensure they are brought in at the earliest opportunity, if that has not already happened. Notify the nominated officer, if this has not yet been done. Assess whether any additional (and/or external) support is required to manage the incident; this may not be necessary. Designate someone to lead the team—the nominated officer (if you have one) is typically best placed to take this role. 2 Contain the report Once concerns have been raised, keep the information as confidential as possible to avoid unintentionally committing a tipping-off offence under the Proceeds of Crime Act 2002 (POCA 2002) or the Terrorism Act 2000 (TA 2000). Maintaining strict confidentiality helps prevent accidental tipping-off under these Acts...