As part of the Government's desire to improve transparency and stop foreign criminals using UK property to launder money, anonymous foreign owners of UK properties are now required to reveal their identities. The Register of Overseas Entities (ROE) (as implemented by The Economic Crime (Transparency and Enforcement) Act 2022 (the ECTEA) came into force on [...]
The Economic Crime (Transparency and Enforcement) Act 2022 (Commencement No. 2 and Saving Provision) Regulations 2022 brought into force Chapter 1 (monetary penalties) of Part 3 (sanctions) of the Economic Crime (Transparency and Enforcement) Act 2022 with effect from 15th June 2022. A breach of financial sanctions is a criminal offence punishable by up to [...]
Although we think of sanctions as part and parcel of the CDD process for anti-money laundering compliance, the requirement to check clients against the sanctions list is, in fact, totally separate. And it is not only confined to those clients whose cases/transactions fall within the scope of the anti-money laundering regulations. If your firm routinely [...]
