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United Kingdom
United Kingdom
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
UK Risk & Compliance: Russia crypto sanctions; OFSI cryptoasset licence update; EU joins fraud partnership; Crime and Policing Act 2026 expands corporate liability; plus horizon scanning, trackers and content updates
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...
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......
Managing legal risk—overview
Every thriving commercial organisation embraces a measure of risk. Refusing to take risks leaves a business static, which is a hazard in its own right. Firms accept risk in pursuit of higher revenue or profit. Rather than eradicating risk altogether, most commercial organisations seek to manage it, capturing the benefits while limiting potential downsides.
What is risk?
An everyday view frames risk as the chance that something adverse might occur. A clearer, more practical definition treats risk as probability multiplied by impact.
For any legal risk your business encounters, ask two questions:
- How likely is the risk to occur - what is the probability?
- If it does occur, how serious will it be - what is the impact?
You can then assess the risk using a simple matrix or scoring method. How likely is the risk to occur - what is the probability? Assign a score between 1 and 5 (where 1 = very low probability and 5 = maximum probability). If that risk occurred, how severe...
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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 ]...
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