On 15 June 2022, the UK Office of Financial Sanctions Implementation (OFSI) implemented important changes to its enforcement powers and updated its “Monetary Penalty” guidance. In summary, OFSI has introduced three key changes: 1) new strict liability standard; 2) publication powers; and 3) flexibility in the review process.

Click here to read the full GT Alert.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Jo Rickards

Jo Rickards is the Chair of the London office’s White Collar Crime & Investigations Group where she represents a wide range of companies and individuals. Jo is recognised as a leading individual in her practice area advising clients in investigations involving allegations of

Jo Rickards is the Chair of the London office’s White Collar Crime & Investigations Group where she represents a wide range of companies and individuals. Jo is recognised as a leading individual in her practice area advising clients in investigations involving allegations of corruption, cartels, tax and investment fraud and contentious financial services. She has advised directors and companies in the UK and internationally for over 20 years. She represents companies and individuals investigated by the SFO, FCA, CMA and HMRC and those who are subject to mutual legal assistance requests from criminal authorities abroad.

Jo’s corporate representations range from advising a U.S. parent whose subsidiary agreed to a civil recovery order with the SFO, conducting an independent review for a UK casino chain, advising an online gambling platform in respect of a money laundering investigation and advising a sovereign wealth fund involved in a high profile sanctions matter. She has advised numerous companies on corruption, money laundering and fraud issues. She has acted for individuals in relation to investigations into Unaoil, Patisserie Valerie, Quindell, Rolls Royce, and a multinational tobacco company. She also has deep experience with insider dealing prosecutions and market abuse investigations. She was involved in the Leveson Inquiry into the culture, practices and ethics of the British press and the Manchester Arena Inquest/Inquiry.

She has a particular interest in bribery & corruption, environmental crime and greenwashing and regularly writes and speaks on these subjects.

Photo of Annabel Thomas Annabel Thomas

Annabel Thomas is an experienced commercial litigator with a strong background in corporate disputes and civil fraud. She represents clients on matters involving asset-tracing and injunctive relief; partnership disputes; competition law; and regulatory/disciplinary litigation. She also handles company and shareholder disputes (including unfair…

Annabel Thomas is an experienced commercial litigator with a strong background in corporate disputes and civil fraud. She represents clients on matters involving asset-tracing and injunctive relief; partnership disputes; competition law; and regulatory/disciplinary litigation. She also handles company and shareholder disputes (including unfair prejudice claims, breach of directors’ duties, JV disputes, LLP disputes and breach of warranty and indemnity claims), as well as insurance disputes (including coverage, subrogated recovery and brokers’ negligence). Annabel’s practice covers litigation in the high court, as well as arbitral proceedings. She is experienced in both defending and bringing claims, often involving multiple jurisdictions and applications for interim relief, including freezing injunctions, search & seizure orders, disclosure orders and security for costs.

Photo of Bethany Histed Bethany Histed

Bethany Histed focuses her practice on commercial litigation, civil fraud, and complex multi-jurisdictional disputes. She has worked on complex contentious cases of significant value involving allegations of fraud, conspiracy, breach of fiduciary and directors’ duties, breach of contract, claims under the Insolvency Act…

Bethany Histed focuses her practice on commercial litigation, civil fraud, and complex multi-jurisdictional disputes. She has worked on complex contentious cases of significant value involving allegations of fraud, conspiracy, breach of fiduciary and directors’ duties, breach of contract, claims under the Insolvency Act 1986, and unfair prejudice petitions under section 994 of the Companies Act 2006. Bethany also has experience of dealing with asset disclosure and preservation issues.

Photo of Gavin Costelloe Gavin Costelloe

Gavin Costelloe is a senior associate in Greenberg Traurig’s White Collar Defense & Special Investigations Practice in London. Gavin is a former lawyer and prosecutor for the UK’s Serious Fraud Office (SFO). Gavin advises companies and individuals on internal, government and regulatory investigations…

Gavin Costelloe is a senior associate in Greenberg Traurig’s White Collar Defense & Special Investigations Practice in London. Gavin is a former lawyer and prosecutor for the UK’s Serious Fraud Office (SFO). Gavin advises companies and individuals on internal, government and regulatory investigations and compliance issues related to the UK Bribery Act, fraud, market manipulation, anti-money laundering, economic sanctions, and other serious and complex cross-jurisdictional matters. Gavin has considerable experience assisting with diligence for mergers, acquisitions, and other investments including in jurisdictions with high corruption risk.

Gavin’s practice is focused on business crime investigation, defence, compliance, and risk mitigation. This includes assisting companies with internal, government, and regulatory investigations (including those conducted by the SFO, Her Majesty’s Revenue & Customs (HMRC), the Crown Prosecution Service (CPS) and the Competition and Markets Authority (CMA)), individual defence for senior executives and compliance professionals, and devising and implementing internal training and compliance progammes.