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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...

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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......

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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...

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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......

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Client bills—overview

There are no fixed statutory or regulatory rules governing the shape or contents of a law firm’s final client bill. That does not entitle you to issue a bill in any format you wish. You must make sure that, if the bill goes unpaid, you are able to take steps to recover your costs. In general, this calls for compliance with the relevant requirements in the Solicitors Act 1974 (SA 1974). See Practice Note: Final client bill, Final client bill-checklist and Precedent: Final client bill wording.

When can you render a final bill


  • when the client has agreed to or requested a final bill
  • at the conclusion of the matter
  • on termination of the retainer
  • on an order of the High Court requiring a solicitor to deliver a bill of costs

Amount of your bill


There is very little set down about the amount you may charge a client; ordinarily this is a question of contract, as reflected in your client care letter and/or terms of business. You owe a general duty not to misuse your position by taking unfair advantage of clients and...

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