On 19th October, law firm Allen & Overy published a detailed briefing on a recent UK case where a bank was ordered to disclose, to a customer, SAR that the bank had sent to the NCA at the time of freezing the customer’s bank accounts.  The bank’s arguments concerning confidentiality, tipping-off and prejudicing an investigation were unsuccessful. The court’s made observations on the interplay between the SAR regime and the law on data protection, defamation and breach of contract.

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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