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United Kingdom
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UK practice compliance weekly highlights: Russia crypto sanctions; OFSI cryptoasset reporting; EU anti-fraud partnership; corporate criminal liability reform (CPA 2026); AI misuse censured by EWHC - 28 May 2026
In this issue: Sanctions Fraud Other financial crime Artificial intelligence Daily and weekly news alerts Horizon scanning Trackers New and updated content Sanctions FCDO announces Russia sanctions targeting crypto exchanges and A7 network The Foreign, Commonwealth and Development Office (FCDO) announced a suite of UK sanctions aimed at cryptocurrency exchanges and the Kremlin-backed ‘A7 network’, which Russia has used to sidestep existing curbs and funnel money into its war economy in Ukraine. The package seeks to counter Russia’s growing reliance on ‘dark networks and shadow financial systems’ to circumvent restrictions and interrupt the movement of funds. The measures include 18 designations striking at Russia’s illicit financial architecture, covering A7-associated persons, a Kyrgyz lender alleged to process payments for the network, and three Georgian firms running Russia-facing exchanges that attempt to dodge sanctions. The A7 network is...
NEWS
FCA review of firms’ financial and trade sanctions systems and controls: findings, good and poor practice, common weaknesses, reporting expectations, and MoU with OTSI to enhance co-operation.
The Financial Conduct Authority (FCA) has released the results of a review evaluating financial services firms’ frameworks and controls relating to financial and trade sanctions. The publication sets out illustrations of effective and weak practice, plus development priorities, to support firms in meeting sanctions legislation. According to FCA, firms have advanced in avoiding sanctions breaches, yet deficiencies persist......
NEWS
From directing mind to senior managers: UK corporate criminal liability, enforcement trends and governance imperatives under the Crime and Policing Act 2026
CPA 2026 materially widens corporate criminal exposure by extending attribution for all offences to conduct by ‘senior managers’ exercising significant decision-making power. This moves risk beyond the narrow ‘directing mind’ test and brings companies-particularly large, decentralised groups-under sharper enforcement scrutiny. Expect prosecutors to probe operational leadership, governance gaps and aggregate evidence across individuals. Boards should revisit delegation, clarify accountability and reinforce oversight of operational choices. A continuing hurdle is pinpointing who is a senior manager in complex structures, with courts likely to prioritise substance over form. More broadly, the regime will reshape how organisations record authority, decisions and escalation, with greater emphasis on demonstrating how choices are taken and supervised in practice. A reshaped strategic risk profile The most immediate effect of CPA 2026 is a broader range of situations in which a company can be criminally liable. Historically, attribution turned on the...
NEWS
UK financial sanctions: OFSI updates General Licence INT/2024/4761108 with cryptoasset definition and new reporting obligations for cryptoasset payments
OFSI General licence INT/2024/4761108 The Office of Financial Sanctions Implementation (OFSI) has revised General Licence INT/2024/4761108. The update: Introduces a fresh definition of ‘cryptoasset’, meaning a cryptographically secured digital expression of value or contractual rights that relies on a form of distributed ledger technology and is capable of being transferred, stored, or traded electronically Adds a new obligation to report for any person using cryptoassets to send or receive a payment under the General Licence The updated licence is available here. Source: OFSI General licence INT/2024/4761108......
Client due diligence—law firms—overview
Client due diligence (CDD) sits at the heart of the anti-money laundering (AML) and counter-terrorist financing (CTF) framework: CDD obligations underpin the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. Where the MLR 2017 apply (see Practice Note: Money Laundering Regulations 2017-scope and application-law firms), undertaking CDD is mandatory. CDD itself is not operated on a risk-based basis, though individual elements allow flexibility and specifically require risk assessment.
What is CDD?
The constituent elements of CDD are:
- identifying any client, unless you already know who the client is and have verified them
- verifying that identity (unless you have previously verified the client’s identity), and
- assessing-and, where appropriate, obtaining information about-the purpose and intended nature of the business relationship or occasional transaction
See further Practice Note: Money Laundering Regulations 2017-client due diligence-law firms.
When is CDD required?
You must apply CDD measures when you:
- establish a business relationship
- carry out an occasional transaction:
- that amounts to a transfer of funds within the meaning
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