On 24th January, law firm Eversheds published its “Horizon Scanner: Financial Crime Update” for December 2017.  This identified major issues and risks involving the UK during 2018, for example –

  • the FATF evaluation of the UK AML/CFT regime, with the on-site visit anticipated to take place in February/March 2018 and a plenary discussion at FATF anticipated in October 2018;
  • transposition of the EU cybersecurity Directive by May 2018;
  • FCA consultation on proposed text for a specialist sourcebook for professional body supervisors, that sets out expectations in relation to AML supervision under the new OPBAS;
  • publication of an asset recovery plan will set out how the UK is responding to the challenges involved in improving the recovery of the proceeds of crime;
  • the new National Economic Crime Centre (NECC);
  • the Sanctions and AML Bill currently before Parliament;
  • the EU Proposal for a Directive on countering money laundering by criminal law;
  • implementation of the remaining provisions of the Criminal Finances Act 2017;
  • the proposed, so-called 5th ML Directive;
  • the GDPR and Data Protection Bill; and
  • the EU proposal for new EU wide cyber-security measures.

Highly recommended.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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