Companies are paying increased attention to the Transparency in Supply Chains provision contained in the U.K. MSA, which is aimed at requiring companies to root out modern slavery.  Those obligated to comply must prepare and publish a slavery and human trafficking statement for each financial year. 2017 is the first year when all organisations to which it applies must publish a statement. The Transparency in Supply Chains provision in the U.K. MSA applies to any…

The Election On 29 March 2017, the U.K. invoked Article 50 of the Treaty of the European Union, setting in motion the two-year period to negotiate a settlement for their political separation. The two sides began settlement negotiations in June. The talks are time-limited: under Article 50, the U.K. will leave the EU automatically in March 2019, absent either unanimous consent from the 27 remaining Member States or ratification of an exit treaty. U.K. Prime…

On April 1, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) acquired new civil enforcement powers, including the ability to impose civil monetary penalties. These authorities come from implementation of portions of the Policing and Crime Act 2017 (the Act). OFSI has issued finalized guidance of its compliance and enforcement approach, including how it will assess whether to apply a monetary penalty (the Guidance). The office is now authorized to impose civil monetary penalties…

Her Majesty’s Treasury (HM Treasury) will soon publish its final policy decisions in advance of the June 26, 2017 implementation of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (2017 MLRs). The 2017 MLRs are intended to transpose the EU’s fourth directive on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (4MLD). The Fund Transfer Regulation (FTR) which…

On February 1, 2017, the U.K. House of Commons voted preliminarily by a large majority (498 votes to 114) in favor of the Withdrawal from the European Union (Article 50) Bill 2016-2017 (the “Withdrawal Bill” – available here). Once the Withdrawal Bill receives royal assent, it will provide a formal mandate to the U.K. Government to notify the European Council of its intention to withdraw from the European Union. This notification will, itself, start…

Government to Shortly Offer Legislation to Keep Timetable for Planned March 2017 Notice In a judgment dated 24 January 2017, by a majority of 8 to 3,1 the Supreme Court has upheld the High Court’s ruling in November 2016 that an Act of Parliament is required before the UK Government may give notice under Article 50 of the Treaty of the European Union (TEU), thereby beginning the formal process of Britain’s withdrawal from…

On December 1, 2016, the U.K. Office of Financial Sanctions Implementation (OFSI) published its draft guidance on the process of imposing monetary penalties for breaches of financial sanctions. The draft guidance is now open for comments from stakeholders in the context of a public consultation launched by OFSI. By way of background, OFSI was established on March 31, 2016 within Her Majesty’s Treasury, with a remit to help “ensure that financial sanctions are properly understood,…