Legal News

From 2 August 2026, the EU’s landmark AI Act will require firms such as Open AI, Google and Meta to apply machine-readable labels to material produced by Chat GPT, Gemini and similar systems, indicating whether content is machine-generated or has been manipulated. The legislation also charges the European Commission with guiding the development of a voluntary code of practice to support the effective roll-out of this labelling duty. Early groundwork for the code has been laid through expert studies examining technical methods to mark content by type. Preparatory studies At a technical workshop on 4 September 2025, AI companies, experts and other stakeholders will be shown the preliminary findings from these studies. The text study was overseen by Giovanni Puccetti, associate professor at the University of Milan; the audio work was led by Xavier Serra and Martin Rocamore, professors at Barcelona’s University Pompeu Fabra; and the image and...

SFO powers to claw back dirty cash to be tested Two matters pencilled in for late 2025 could clarify, by way of precedent, when and in what situations the SFO may confiscate funds suspected to be the proceeds of crime. The first, listed for September 2025, concerns an appeal against an account forfeiture order made by Westminster Magistrates’ Court in 2023 for upwards of £7m. The order targets Mario Ildeu de Miranda, a one-time Petrobras executive at the Brazilian-owned oil group. The SFO was originally authorised to take the money from de Miranda following his conviction in Brazil for involvement in a bribery scheme linked to the energy major. This cash seizure represents the largest sum the SFO has ever obtained from a single bank account. It followed a painstaking agency inquiry tracking the funds within Brazil’s “ Operation Car Wash”. De Miranda is...

In this issue: Financial sanctions Other financial crime Data protection Other Practice Compliance updates this week Daily and weekly news alerts Trackers New and updated content Financial sanctions FCDO targets Kyrgyz financial institutions and crypto exchanges in Russia sanctions update On 20 August 2025, the Foreign, Commonwealth & Development Office unveiled further measures against Russia’s evasion networks operating in Kyrgyzstan. Those named include Capital Bank of Central Asia and its director, Kantemir Chalbayev, plus the crypto platforms Grinex and Meer, which run the rouble‑linked A7A5 token, reportedly processing US$9.3bn in four months. This step adds to the UK’s existing Russia regime, mirrors comparable US action, and introduces eight additional designations. They are intended to block Russia’s use of Kyrgyz banking and crypto channels to sidestep western controls. It sits within co‑ordinated international efforts, alongside ongoing US‑led talks to secure peace in...

Chevin Asset Management Ltd has accused Darby & Darby in a newly public claim at the High Court of breach of an undertaking and breach of trust linked to the sale of a house in London. Chevin acquires residential homes under market value and subsequently sells them on to make a profit. The row concerns a London property owned by Paul Davies. The claim further alleges that Darby & Darby was instructed by someone masquerading as Davies. It contends that the individual who gave Darby directions was not, in truth, the real Paul Davies......

Following its creation in the Economic Crime and Corporate Transparency Act 2023 ( ECCTA 2023), the failure to prevent fraud offence is scheduled to take effect on 1 September 2025. Under ECCTA 2023, s 199, large organisations can be made answerable for fraudulent conduct by employees, agents, subsidiaries, or others providing services for, or on behalf of, the organisation, where the wrongdoing was intended to benefit the organisation or its clients. For a case to proceed, at least one element of the underlying fraud must have occurred in the UK, or the gain or loss arising from it must have been realised in the UK. Businesses do, however, have a potential defence, as set out in the government’s guidance on the offence. Reasonable procedure In November 2024, the government issued guidance describing the reasonable procedures that companies should adopt if they are to stand a chance of...

Concealed within those measures sits section 196 of the Bill, ushering in a far‑reaching broadening of the identification doctrine so that corporate employers are answerable for any offence committed by a senior manager acting under their actual or ostensible authority, in effect. This proposed, radical uplift in organisational liability for employee conduct conspicuously omits several common‑sense protections long seen and applied in other jurisdictions. As presently framed, the legislation indeed risks producing counter‑intuitive results that the Bill’s architects can hardly have intended or envisaged. A modest handful of straightforward, pragmatic tweaks would sharpen the drafting and impose a sensible, workable limiting principle on what is otherwise a major enlargement of the identification doctrine. Identification doctrine expanded Section 196 of the Economic Crime and Corporate Transparency Act 2023 ( ECCTA 2023) extends the identification doctrine to make companies criminally responsible for specified economic offences...

A UK accountancy practice’s imminent prosecution for failing to stop tax evasion has thrown a spotlight on the country’s weak track record on enforcement, across this area of compliance, though the proceedings may galvanise a renewed push. Bennett Verby, which operates in northern England, is due to stand trial in September 2027, marking the first corporate case for failing to prevent tax evasion since the offence reached the statute book eight years ago. HMRC, the UK tax authority, has recently charged Bennett Verby with failing to prevent the facilitation of UK tax evasion under section 45 of the Criminal Finances Act 2017. Company representatives appeared before a Manchester court earlier this month. No plea has been entered yet, but the firm will reportedly contest the claims. The failure to prevent tax evasion offence was enacted with fanfare eight years ago, in the wake of the 2016...

By law, employers must publish pay gap figures solely for their staff, leaving law firms to choose if and how they reveal disparities within partnerships. This flexibility materially hampers like-for-like comparisons over time and obscures any sense of progress, as firms can alter how they present their numbers or drop publication entirely. In 2024, 39 of the 111 firms reviewed by Law360 voluntarily shared a business-wide median pay gap—a weighted blend of partner and employee gaps—across their operations. The average stood at 33.8%, versus 26.7% for employees alone during the same period. Of the 51 firms that issued a separate partner-only gap for 2024, the median was 24.7%, an increase of 2.8 percentage points on 2023 figures. Female representation in partnerships also trails noticeably. Women account for just 37% of partners in the UK, according to data from the Solicitors...

In this issue: Practice Compliance forecast Sanctions Other financial crime Data protection Daily and weekly news alerts New and updated content Practice Compliance forecast New Practice Compliance forecast as at 19 August 2025 Our refreshed Practice Compliance forecast (dated 19 August 2025) is now live and available for use. This edition covers, among other matters: (1) HMRC’s consultation on AML supervision charges; (2) the NCA’s revised system priorities for combating economic crime; (3) amendments to Le O’s case fee model; and (4) the SRA’s 2025 practising certificate and firm registration renewals. See News Analysis: New Practice Compliance forecast as at 19 August 2025. Sanctions OFSI updates UK Financial Sanctions FAQs The Office of Financial Sanctions Implementation ( OFSI) has revised its UK Financial Sanctions FAQs, adding three entries, Q162–164, concerning General Licence INT/2025/6641960. They confirm the licence does not extend to assets held in, by, or via...

The failure to prevent fraud offence Introduced by the Economic Crime and Corporate Transparency Act 2023 ( ECCTA 2023) as part of wider efforts to combat financial crime, the failure to prevent fraud offence takes effect on 1 September 2025 and is intended to drive a meaningful, positive shift in corporate culture. This is the latest in the suite of corporate “failure to prevent” offences, following the failure to prevent bribery under the Bribery Act 2010 ( BA 2010) and the failure to prevent the facilitation of tax evasion in the Criminal Finances Act 2017. The offence is contained in ECCTA 2023, ss 199–206. Its purpose is to ensure large organisations are accountable for fraud carried out by employees, agents, subsidiaries, or others who provide services for or on behalf of the organisation, where the conduct was intended to benefit the...

Analysis by Law360 Across 100 UK firms, men received average bonuses 31.2% higher than women in 2024, even though similar proportions of men and women were awarded bonuses that year. The difference was 26.8% in 2023. Specialists suggest that bonus disparities are often driven by a small number of particularly large awards. They also note that closing the bonus gap is proving more challenging than addressing base pay, partly because men still dominate higher-billing commercial practices. Solicitors Regulation Authority figures from 2023 show men outnumber women in corporate, financial, criminal and intellectual property roles, and the imbalance grows at partnership level. Women comprise only 30% of corporate law partners and 26% of full-equity partners in that practice area, compared with 47% at the beginning of their careers. ‘ This is a persistent issue and, frankly, one we need to stop tiptoeing around’, said Hannah Bradshaw,...

As at 19 August 2025, our Practice Compliance forecast monitors anticipated regulatory developments affecting law firm compliance, helping you prepare for any impacts on your organisation. Please review it carefully; however, key points that merit attention are highlighted below. New items we’re tracking this month HMRC’s AML supervision fees— HMRC has issued a policy paper setting out suggested revisions to its AML supervision charges under the Money Laundering Regulations ( MLR 2017). The engagement period is open until 29 August 2025. A summary and proposed next steps will follow. See: AML, CTF and counter-proliferation financing. NCA system priorities—the NCA has released its ‘ System Priorities’ for addressing economic crime in 2025. These priorities are intended to help the regulated sector deploy resources efficiently whilst maintaining regulatory compliance. See: AML, CTF and...

HMRC has charged a tax accountancy firm with the failure to prevent tax evasion in connection with an alleged fraud involving research and development repayments HMRC has brought a case against a tax accountancy practice, alleging failure to prevent tax evasion linked to purported research and development repayment fraud. It marks the first occasion the authority has hauled a company before the courts over whether its tax evasion compliance programmes were adequate. Alongside the corporate action, six individuals have also been charged, among them a former director of the firm. After criticism from lawmakers about limited enforcement, HMRC has deployed the offence, signalling a willingness to test the law in court rather than depend on its deterrent effect, according to Reuben Vandercruyssen of Hogan Lovells LLP. He said the matter indicates a tougher stance on financial crime, with HMRC opting to pursue...

District Judge Louisa Ciecióra At Westminster magistrates’ court in London, District Judge Louisa Ciecióra handed Aozma Sultana, 42, a ten-week jail term, suspended for a year. Sultana breached counter-terrorism rules by failing to supply information to the Office of Financial Sanctions Implementation ( OFSI). After a trial in July 2025, she was found guilty of one count of refusing or failing to comply with a request for information under the Counter- Terrorism ( Sanctions) ( EU Exit) Regulations 2019, SI 2019/577, reg 23. The charity head, Judge Ciecióra concluded, had not put forward ‘evidence of reasonable excuse’ for missing the June 2024 deadline. The judge described the conduct as deliberate and, consistent with her findings at trial, observed that Sultana was asked for the material multiple times and repeatedly did not provide it......

How have plans for UK data protection reform evolved since Brexit? Since Brexit, the UK’s approach to data protection reform has ebbed and flowed markedly, with successive governments seeking to carefully balance innovation, economic growth and individuals’ rights. The Conservative government aimed to pivot to a GDPR ( General Data Protection Regulation) lite regime by introducing the Data Protection and Digital Information Bill. That bill outlined a series of business‑friendly amendments to existing data protection rules and progressed reasonably well through parliament, only to be ultimately shelved following a change of government in 2024. Once in office, the Labour‑led administration reignited the agenda, bringing forward the Data ( Use and Access) Bill ( DUAB). While retaining the core UK GDPR framework, DUAB set out targeted reforms that indicate a shift towards a more UK‑specific regime centred on data‑driven innovation, enhanced public services and strong data...

In this issue: Financial sanctions AML, CTF & counter-proliferation financing Other financial crime Other Practice Compliance updates this week Daily and weekly news alerts Trackers New and updated content Financial sanctions Improving civil enforcement of financial sanctions under SAMLA 2018 Christopher Gribbin, managing associate, and Molly Vann of Mishcon de Reya’s White Collar Crime & Investigations team review the recent consultation from the Office of Financial Sanctions Implementation ( OFSI), opened on 22 July 2025, which proposes overhauls to the UK’s civil enforcement of financial sanctions. The package aims to make OFSI’s procedures clearer, more transparent and more efficient. Key measures include refreshed case assessment guidance, a new settlement route, and an Early Account Scheme to promote swift, full disclosure. OFSI also suggests streamlined penalties for reporting and licensing breaches, alongside a substantial rise in statutory maximum fines. While...

What is the background to this consultation? OFSI, a unit within HM Treasury, is tasked with making sure the UK’s financial sanctions are understood, put into practice, and enforced. On 22 July 2025 it launched a consultation seeking views on proposed adjustments to the civil enforcement process for financial sanctions. These proposals follow mounting criticism of how the UK enforces sanctions. Spotlight on Corruption’s report last year, All Bark and No Bite, contended that weak enforcement undermines the UK’s efforts against economic crime. Moreover, at a Commons Foreign Affairs Committee session in November last year, Giles Thompson, OFSI’s head, accepted the need for more robust enforcement. The consultation paper itself notes that the impetus includes recognition that OFSI could make enforcement processes clearer and more transparent, and make resolving enforcement cases quicker and easier. That backdrop informs the current...

Company representatives attended Manchester Crown Court on 7 August 2025, after a charge was issued by the UK tax authorities alleging a failure to prevent the facilitation of UK tax evasion, in breach of section 45 of the Criminal Finances Act 2017.......

The inquiry uncovered evidence that products made, in whole or in part, with forced labour are entering the UK market, despite the government’s position that no company operating in the UK should have forced labour anywhere in its supply chain. The Report concludes that the UK is now lagging behind international trading partners in addressing forced labour in supply chains. Its principal recommendation is to strengthen existing laws and their enforcement, and to introduce new measures to embed corporate responsibility (including mandatory human rights due diligence), apply an import ban on goods linked to forced labour, and create a ‘duty to prevent’ that establishes civil liability for companies that fail to take adequate steps to prevent forced labour in their supply chains. The Report’s themes The Report examines six themes: Corporate responsibility Import bans and...

In this issue: Financial sanctions AML, CTF & counter-proliferation financing Data protection, cybersecurity and AI Complaints Other Practice Compliance updates this week Lex Talk®Practice Compliance: a Lexis®Nexis community Daily and weekly news alerts Trackers New and updated content Financial sanctions DBT and OTSI update guidance on trade sanctions breach assessments The Department for Business and Trade ( DBT) and the Office of Trade Sanctions Implementation ( OTSI) have revised their guidance on how trade sanctions breaches are assessed. Section 5, ‘ Referral to HMRC’, has been updated to state clearly that HMRC holds the power to offer compound penalties in criminal enforcement cases. See: LNB News 01/08/2025 24. DBT updates guidance on countering Russian sanctions evasion and circumvention The DBT and OTSI have refreshed their guidance on addressing Russian sanctions evasion and...