Legal News

New Risk & Compliance forecast as at 17 June 2025 Our Risk and Compliance forecast, dated 17 June 2025, monitors anticipated regulatory developments linked to risk and compliance, enabling you to prepare for any shifts that could affect your organisation. This helps you plan for potential changes relevant to your operations. Please examine it thoroughly; priority points that merit attention are highlighted below. New items we’re tracking this month No additional entries are under review this month......

As part of Chancellor Rachel Reeves’ recent government spending review, the government has pledged an extra £8.3m in additional support to the SFO over the coming three financial years. This will lift the specialist prosecutor’s budget up to £97.64m by 2028 in total. The money will target proactive intelligence activity, bolster its proceeds of crime team, and improve the effective use of advanced technology in disclosure processes. This settlement enables sustained investment in intelligence capability, broadens investigative reach, and reinforces efforts to recover criminal assets, including crypto assets, wherever they are found across jurisdictions, said Nick Ephgrave, the SFO’s director. The agency added that the cash has revived firm plans to relocate to new accommodation, probably in Canary Wharf, within around 18 months’ time. In February 2025, the SFO said budget pressures had forced it to...

GPAI model developers should still get a final draft of the EU Code of Practice from the Commission in July 2025, despite a potential ‘stop the clock’ on the EU AI Act, MLex has learned Bilateral talks are continuing, and the draft is foreseen for the first week of July. MLex earlier reported that the Commission was weighing a hold on the EU AI Act after a critical letter from the Trump administration in the US and a visit to Washington by the Commission’s Executive Vice- President for Tech Sovereignty, Security and Democracy, Henna Virkkunen. The matter was recently put on the agenda of a meeting of EU digital ministers, where Virkkunen formally indicated that parts of the EU AI Act could be paused if technical standards and administrative guidance are not ready when the rules take effect. The EU AI Act phases in over...

Risk & Compliance weekly highlights—12 June 2025 In this issue: Data protection Sanctions AML, CTF & counter-proliferation financing Other financial crime Daily and weekly news alerts Trackers New and updated content Data protection Data ( Use and Access) Bill passes through Parliament and heads for royal assent Parliament approved the Data ( Use and Access) Bill ( DUA Bill) on 11 June 2025. Proposed in October 2024, its passage caps a lengthy journey marked by extensive legislative ‘ping pong’, with nine rounds of exchanges between the two Houses. At the heart of the dispute sat the thorny question of employing copyright-protected works to train AI systems. In the final debate on 11 June 2025, the House of Lords chose not to persist with its amendment, which would have compelled the government to introduce further measures on copyright...

John Bedford, a partner at Dechert LLP, observed that a number of companies have approached him to clarify whether they can trade in securities that have remained frozen or otherwise blocked since Russia’s invasion of Ukraine more than three years ago. Others are exploring if they should start laying groundwork now to re-enter the Russian market after a prolonged hiatus, mindful of the lengthy lead time needed to re-establish and stabilise operations. Any prospective geopolitical reset becomes more complex if the UK and EU decline to follow America’s lead, leaving advisers to grapple with applying divergent, and potentially conflicting, regimes. For multinational businesses, obtaining permission in a single jurisdiction is far from straightforward, as they risk breaching, or being seen to breach, rules in other territories. Bedford warned that, even where firms consider themselves subject only to US sanctions or believe...

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...

Introducing a layered sanctions framework that permits adaptable reactions to varied hostile conduct is strongly urged in a paper from the Adam Smith Institute, the free-market think tank, and co-written by Robert Buckland KC. According to the report, such an approach would draw distinctions among modern forms of aggression, including cyber attacks, violations of human rights and economic subversion. The paper also lists environmental damage alongside political meddling as well. In addition, the institute argued that revising the legal meaning of ‘conflict’ would enable the UK to calibrate for differing degrees of risk and to take measured steps against state as well as non-state entities......

It marks the fifth bid by the House of Lords to harness the Data ( Use and Access) Bill to shield the creative sectors, taken despite ministers urging the upper revising chamber to step aside. Though the government is almost certain to strip out the amendment when the Bill returns to the House of Commons, where it commands a substantial majority, the mounting stand-off between both houses endangers the Bill’s prospects, with consequences for UK data protection law and the nation’s EU data adequacy standing. The Data ( Use and Access) Bill is a post- Brexit initiative to adjust elements of the United Kingdom General Data Protection Regulation, Assimilated Regulation ( EU) 2016/679, carried over from EU membership. The Bill is already on its third version, having been tabled and then heavily reworked by the previous Conservative...

On 4 June 2025 at Southwark Crown Court, the Serious Fraud Office ( SFO) accused United Insurance Brokers Ltd of corporate misconduct, arising from its purported failure to prevent employees of a US-based intermediary from paying bribes to a state official in the South American country during the period October 2013 to March 2016......

In this edition: Financial sanctions AML, CTF & counter-proliferation financing Other financial crime Lex Talk® Risk & Compliance: a Lexis®Nexis community Daily and weekly news alerts Trackers New and updated content Financial sanctions OFSI publishes new financial sanctions video guidance series The Office of Financial Sanctions Implementation ( OFSI) has launched a new video guidance series, ‘ Financial Sanctions: The Basics’. The collection features six videos outlining key elements of UK financial sanctions delivery, including guidance, the consolidated lists, reporting obligations and licensing processes. The aim is to support individuals and businesses in meeting UK financial sanctions obligations. See: LNB News 04/06/2025 44. Outcomes from the cross-government review of sanctions implementation and enforcement On 15 May 2025, the UK government issued its first cross-government review of sanctions implementation and enforcement. The review assessed the UK’s enforcement model and set out the wider...

The AI Act follows a staggered timeline for when its different chapters take legal effect, although the enforcement rules and sanction regime will only apply with the bulk of the provisions starting 2 August 2026 The AI Act is being phased in, with different chapters activating at separate times, while the enforcement mechanisms and penalties start alongside most provisions on 2 August 2026. The early roll-out has been demanding, with the Commission juggling the creation of a new AI Office, the publication of administrative guidance, and the orchestration of a code of practice for general-purpose AI models. That code has become especially divisive, touching on delicate matters such as copyright safeguards in developing generative AI and approaches to societal risks, which ultimately led to the legal deadline being missed. It has also turned into a source of friction with the US...

In February 2025, the European Commission issued two guideline suites clarifying core aspects of Regulation ( EU) 2024/1689, the EU Artificial Intelligence Act ( EU AI Act)— Guidelines on the definition of an AI system and Guidelines on prohibited AI practices. These texts aim to steer stakeholders through the tranche of EU AI Act duties that took effect on 2 February 2025, in particular the definitions section of the EU AI Act, requirements on AI literacy, and bans on certain AI practices. Spanning well over one hundred pages in length, the Guidelines deliver highly detailed direction on interpreting and applying each of the eight prohibited AI practices listed in Article 5 of Regulation ( EU) 2024/1689. As a reminder, Article 5 sets out practices that are forbidden in relation to AI systems. The Guidelines also closely examine how high-risk AI systems...

What did the review look at and why? The review commenced in October 2024 to explore ways to bolster the UK's enforcement model. Overall oversight sat with the Foreign, Commonwealth and Development Office ( FCDO), and it incorporated input from HM Treasury, the Department of Business and Trade, the Department of Transport, HM Revenue and Customs, and the National Crime Agency. Furthermore, the process also drew on further meetings with various cross industry sanctions specialists, academics, and others, informing its conclusions......

Appeal by Dmitrii Ovsiannikov over UK Russia sanctions conviction Dmitrii Ovsiannikov, once a politician for Russia’s ruling party, has filed an appeal after his April conviction for breaching the UK’s Russia sanctions. He was found guilty of six counts of circumventing sanctions under the Russia ( Sanctions) ( EU Exit) Regulations 2019, SI 2019/855, alongside two counts of money laundering. At Southwark Crown Court, a judge handed the former Russian trade minister and ex‑governor of Russian‑occupied Sevastopol a 40‑month prison term. Liam Lane of Peters & Peters, who acted for Ovsiannikov, confirmed an application had been submitted on his behalf. Ovsiannikov’s brother, Alexei Owsjanikow, received a 15‑month sentence, fully suspended, after he too was convicted of circumventing sanctions for paying the school fees of Ovsiannikov’s children. Owsjanikow’s lawyer did not immediately respond to a request for comment. These convictions and sentences were the first in the UK for...

As the SFO's drive for whistleblower incentives gathers momentum, corporations should consider the implications for managing misconduct risk On 22 April 2025, the Home Office unveiled the second part of Jonathan Fisher KC’s fraud offences review, the first independent examination of UK fraud law since 1986. Spanning six phases of the fraud lifecycle, the opening phase features an in-depth appraisal of rewards for criminal informants and whistleblowers. The Fisher review is anticipated to be pivotal to the Labour government’s fraud agenda, offering the SFO a key platform to advance incentives reform within government. Soon after the announcement, the SFO stated it would liaise with the Fisher Review team to set out its case for change. These moves followed HM Treasury’s March 2025 commitment to introduce a fresh informants’ scheme aimed at tackling serious tax non-compliance, with a focus on major...

In this issue: Sanctions Cybersecurity Other Risk & Compliance updates this week Daily and weekly news alerts Trackers New and updated content Sanctions DBT and OTSI update guidance on reporting suspected trade sanctions breaches The Department for Business and Trade ( DBT) and the Office of Trade Sanctions Implementation ( OTSI) have revised their guidance on how to report suspected breaches of trade sanctions. A fresh section, ‘ Whistleblowing for trade sanctions’, has been introduced, confirming that from 26 June 2025, individuals will be able to make whistleblowing disclosures to OTSI about people or businesses they suspect of breaching trade sanctions that OTSI implements and enforces. These changes follow the Public Interest Disclosure ( Prescribed Persons) ( Amendment) Order 2025, SI 2025/604, laid before......

External guidance on corporate co-operation and enforcement in relation to corporate criminal offending External guidance on corporate co-operation and enforcement in relation to corporate criminal offending supersedes and replaces the SFO’s 2019 co-operation guidance. It underscores swift self-reporting and comprehensive co-operation with SFO investigations as pivotal factors for prosecutors when considering a DPA to conclude a corporate investigation and to refrain from formal charges, save in exceptional cases and subject to prosecutorial discretion. However, the availability of a DPA is not ruled out where a company has not self-reported, provided it has offered exemplary co-operation with the SFO’s investigation. DPAs have been deployed in the US for more than 30 years as a corporate pre-trial diversion mechanism, alongside non-prosecution agreements, with federal authorities entering approximately 327 corporate DPAs in total between 1992 and the present day. Reflecting a broader global movement in favour of...

Home Office plans to prohibit public-sector organisations from paying ransoms, and to require other entities to consult with the authorities before contemplating any transfer to their attackers, are designed to undercut the prevailing ransomware business model by making the UK a far less lucrative destination. Yet lawyers also warn the measures, set out in a wide‑ranging government consultation, may underestimate their opponents. Julian Hayes, a partner at BCL Solicitors LLP, described the idea as “deceptively simple and unquestionably well‑intentioned”, but said it verges on the naive. He added that, even if it succeeded, it would simply divert ransomware operators towards softer targets. According to the Home Office, ransomware drew in more than £1bn from victims worldwide in 2023. It has become a profitable stream of cash for cybercriminals and state‑sponsored actors able to penetrate businesses and public agencies and seize control of their...

In this issue: Risk & Compliance forecast Financial Sanctions Other Risk & Compliance updates this week Daily and weekly news alerts New and updated content Risk & Compliance forecast New Risk & Compliance forecast as at 20 May 2025 The latest Risk & Compliance forecast, dated 20 May 2025, is now available. This edition covers: (1) the ICO’s consultation on encryption guidance; (2) HM Treasury’s proposed package of amendments to the Money Laundering Regulations; (3) OPBAS’s forthcoming targeted review of SARs; and (4) progress in the Crime and Policing Bill widening corporate criminal liability. See News Analysis: New Risk & Compliance forecast as at 20 May 2025. Financial Sanctions FCDO announces West Bank sanctions and pauses Israel trade talks Announced by Hamish Falconer MP and the Rt Hon David Lammy MP, the Foreign, Commonwealth & Development Office ( FCDO) has imposed fresh sanctions on three individuals, two illegal settler outposts and two...

On 13 May 2025, the watchdog gave reassurance to the profession — and to Big Law in particular — that it will keep domestic turnover as the basis for penalties in the most serious breaches of its rules. Specialists in legal ethics expressed immediate public relief at the reversal. Julie Norris, a partner at Kingsley Napley LLP in London, said the proposal was 'ill-thought through' because it failed to account for the realities of different law firm ownership models and ways of sharing costs and profits. She added: ' Its potential impact was huge. At a macro level, it would have served to undermine England and Wales’ position in the global legal services market'. The solicitors’ watchdog had to overhaul its approach to financial penalties after it obtained new powers in March 2024 to issue unlimited fines for economic crime offences. In June 2024 it...