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Corporate Crime Update, Autumn 2019

10 October 2019 | Global
Legal Briefings


Welcome to the Autumn 2019 edition of our corporate crime update - our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters. This bumper edition covers a number of jurisdictions, and includes content from the summer break.

For the full update on each jurisdiction, please click read more on the jurisdiction below. Below we provide a brief overview of what is covered in each update.


United Kingdom

  • Approval of UK’s fifth DPA concludes SFO investigation into Serco companies
  • Three individuals acquitted following SFO DPA with Sarclad
  • SFO Corporate Co-operation Guidance
  • Permission to appeal granted in case on the extraterritorial reach of s.2 SFO powers
  • Former company director prosecuted for failure to produce documents
  • Bank trader acquitted in EURIBOR trial
  • FH Bertling sentenced for $20m Angolan bribery scheme
  • SFO charges former director of Global Forestry Investments
  • SFO appoints new Non-Executive Directors
  • Commercial Court considers contractual discretion of bank to close customer account without notice where there is suspicion of money laundering 
  • Accounts worth £100m frozen by NCA
  • NCA announces UWO issued against businessman linked to serious organised crime
  • Operation Tabernula: FCA announces sentencing of Richard Baldwin
  • FCA AML annual report 2018/19
  • FCA reviews ML risks in the capital markets
  • FCA and Practitioner Panel survey report: FCA’s targeting of financial crime and market abuse is important to firms
  • FCA holds 2019 AML TechSprint
  • FCA speech on the challenges of regulating financial innovation 
  • Treasury Committee calls for FCA and NCA to investigate allegations of banks forging signatures
  • UK Government publishes economic crime plan 2019 to 2022
  • UK Government to launch new modern slavery research centre
  • HMT AML/CTF supervision report 2017-18
  • MPs call for urgent action on UK’s 'unclear' sanctions policy
  • Law Commission Anti-money laundering: the SARs regime report
  • UK FAP calls for more investment in tackling domestic bribery
  • OFSI publish guidance, FAQs and information on monetary penalties relating to financial sanctions
  • OFSI publish Russia post EU-Exit financial sanctions guidance 
  • OFSI cyber-attack financial sanctions guidance
  • OFSI extends its international financial sanctions engagement programme
  • OFSI Financial Sanctions Notices
  • US DOJ applauds work with UK financial regulators 

European Union

  • Council of the EU adopts Directive allowing access to financial information for preventing financial crime
  • Council of the EU adopts mandates aiming to facilitate access to e-evidence in collaboration with the US 
  • FMLC report on U.S. Sanctions and the E.U. Blocking Regulation
  • OECD very concerned that active bribery is no longer a felony in Greece
  • Europol calls for further international cooperation against AML
  • Europol and New Zealand sign MoU to increase collaboration against international crime 

International Bodies

  • FATF report to G20 Leaders' Summit
  • G20 Finance Ministers Affirm Amended FATF Guidelines for “Crypto Assets”
  • FSB report on work underway to address crypto-asset risks
  • FAFT releases guidance on its risk-based AML approach
  • FATF Terrorist Financing Risk Assessment Guidance
  • FATF Plenary: 16-21 June 2019
  • FATF mutual evaluation reports and updated consolidated assessment ratings
  • FATF 30 years
  • New FATF President

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  • Corporate Criminal Liability and Internal Investigations – Expected Legislative Changes

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Middle East

  • UAE launches UN-developed platform to curb money laundering
  • FSRA enhances guidance on regulation of crypto asset activities
  • DFSA make amendments to AML Rulebook
  • DFSA fines Abraaj Group USD 315 million for deceiving investors and the Regulator
  • Ex-Emirati chairman and expat CEO fined EUR300 million in UAE
  • Fake currency worth Dh12.2 million seized in Dubai
  • Four on trial for Dh1.2 million fake property development scam in Dubai

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  • Moscow Corporate Crime and Investigations Newsletter – July 2019

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Hong Kong/China

  • FATF and APG publish long-awaited mutual evaluation report on Hong Kong
  • ICAC signs collaboration MoU and hosts training with SFC
  • Former government official found guilty of misconduct in public office
  • China to embed anti-corruption officers in Belt and Road projects
  • Stricter prison rules for corrupt convicts in China
  • ICAC mounts joint operation with SFC
  • ICAC secures fraud convictions
  • Former Hong Kong chief executive cleared of criminal misconduct

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  • India tightens AML laws by widening definition of proceeds of crime
  • SEBI publishes revised guidance note on insider trading norms
  • 10-year jail term proposed for dealing in crypto-currency


  • MAS extends AML/CFT requirements to insurers and payment service providers
  • Executive penalised S$336,000 for insider trading
  • Singapore collaborates with OCBC to quicken financial crime detection
  • 333 counts for insider trading offences against three individuals
  • Directors' bribery charges disrupted parent's IPO
  • 25 years and 10 months imprisonment for $41m embezzlement
  • Singapore eyes on shell companies to fight money laundering
  • Jailed men receive ban for insider trading


  • New reporting requirement for digital asset trading
  • Ministers jailed for embezzlement
  • Senior anti-corruption official accused of hiding millions in assets
  • Members of Parliament charged over alleged corruption linked with construction project


  • Trade misinvoicing causes loss of US$ 6.5 billion
  • Six years imprisonment for DPR deputy speaker for bribery


  • Amendment to Anti-Corruption Act 2009 takes effect on 1 June 2020
  • Ministers to declare asset or subject to jail
  • Update on 1MDB
  • SCM to implement anti-corruption action plan
  • Malaysia plans increased anti-money laundering enforcement
  • Joint raid against illegal Money Services Business Operators
  • Executives face jail terms and heavy fine for money laundering and illegal operation


  • Vietnam issues guide to money laundering regulations
  • Shipbuilding tycoon sentenced to 13 years for embezzlement
  • Vietnam on anti-corruption spree
  • Jailed senior banker faces further criminal investigation

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  • Whistleblower law reforms have now commenced
  • Referrals for criminal prosecutions following the Banking Royal Commission expected
  • NSW government delays state's Modern Slavery Act for inquiry and report
  • Supply chain risk a key focus of workplace regulator

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United States

  • President Trump Issues New Executive Order Blocking Property of the Government of Venezuela
  • SEC adds fraud charges against purported cryptocurrency company, CEO and consultant
  • Walmart charged with failing to operate sufficient anti-corruption compliance program
  • SEC Obtains Freeze of $8 Million in Assets in Alleged Fraudulent Token Offering and Manipulation Scheme 

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South Africa

  • Extradition of Manuel Chang, Mozambique's former Finance Minister
  • State-owned freight and rail transport company – loss in the billions

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