Welcome to Allen & Overy’s Investigations Insight blog, sharing with you our views and insights into the latest trends, risks and developments in business crime and financial services investigations

A steady hand on the tiller: how to build operational resilience

In a financial services sector heavily reliant on technology and subject to increasing numbers of cyber-attacks, how can firms hope to avoid operational disruption? This is the focus of a suite of consultation papers published on 5 December by the Prudential Regulation Authority (PRA), the Financial Conduct Authority (FCA), and the Bank of England. Although Read More

SARS extended moratorium period used sparingly, reveals NCA report

The NCA Suspicious Activity Reports Annual Report 2019 reports that the NCA received a record number of SARs, including over 50% more requests for a Defence Against Money Laundering (DAML). While the number of DAML SARs that are granted remains high, the use of a new power to extend the moratorium period to up to Read More

From ‘enabler’ to ‘game changer’: fighting financial crime with technology

Financial crime is big business. Serious organised crime facilitated by money laundering costs the UK £37 billion every year. The estimated annual cost of fraud is £190 billion. This is the current scale of the problem according to Megan Butler, Executive Director of Supervision at the UK Financial Conduct Authority (FCA). And rapid advances in Read More

Anti-Money Laundering: HMRC raises its game

The UK’s fight against money laundering is not breaking news. In particular, the regulatory spotlight has increasingly been focused on anti-money laundering (AML) compliance. In light of HM Revenue & Customs’ (HMRC) largest ever fine against the money transmitter Touma Foreign Exchange Ltd (Touma), the question arises of whether the enforcement spotlight is shifting away Read More

The UK FCA shines a light on personal account dealing

In its latest Market Watch newsletter, the FCA has reported on the ‘varied’ quality of firms’ personal account dealing (PAD) controls and set out points that it says all firms should consider when reviewing their PAD controls. The requirement for firms to have PAD controls The FCA requires firms to establish adequate PAD controls in Read More