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......
Risk & Compliance weekly highlights-28 May 2026 In this issue: Sanctions Fraud Other financial crime 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) has unveiled a fresh UK sanctions package aimed at cryptocurrency exchanges and the Kremlin-backed ‘A7 network’, which Russia uses to evade existing measures and channel funds into its war economy against Ukraine. The actions are intended to curb Russia’s growing reliance on ‘dark networks and shadow financial systems’ to sidestep controls and disrupt related financial flows. The package introduces 18 designations against Russia’s illicit financial infrastructure, covering A7-linked individuals, a Kyrgyz bank suspected of processing payments for the network, and three Georgian firms operating Russia-focused exchanges seeking to avoid sanctions. The A7 network is...
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...
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......
Organisations often fail to give due weight to data protection by design and default (DPbDD) when assessing their UK GDPR compliance. That is understandable, as DPbDD is a diffuse, overarching idea that can be hard to convert into concrete steps, especially when set against other self-contained duties in the UK General Data Protection Regulation (UK GDPR). Still, the UK GDPR has a dedicated provision on DPbDD (Article 25) and the Information Commissioner’s Office (ICO) has produced extensive guidance.
Put simply, DPbDD means addressing data protection and privacy considerations from the outset in everything you do. You must build data protection into your processing operations and business practices, starting at design and continuing throughout the lifecycle.
DPbDD is both a broad organising principle of the UK GDPR framework and a specific obligation under Article 25 of Assimilated Regulation (EU) 2016/679 (UK GDPR):
Recital 78 supplements this, although much of it reiterates the substance of Article 25. The UK GDPR can be challenging to interpret in places, and Article 25/Recital 78 are prime...
When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...
This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...
Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...