On 18 November 2024, a UK court fined English company EDM Limited £89,359.80 for export control rule violations, finding the company guilty on three counts
Continue Reading UK Company Fined for Breaking Export RulesGavin Costelloe
Gavin Costelloe is a member of 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.
UK Failure to Prevent Fraud Offence Widens Net for Corporate Criminal Liability
On 6 November 2024, the UK government published its long-awaited Guidance for the new offence of failure to prevent fraud (FTP Fraud Offence), which will…
Continue Reading UK Failure to Prevent Fraud Offence Widens Net for Corporate Criminal LiabilityUK Enforcement Agencies Crack Down on Financial Crime Control Failures, Sanctions Violations
On 2 October 2024, the FCA issued a final notice announcing it had fined digital challenger bank Starling Bank Limited £28,959,426 for financial crime and…
Continue Reading UK Enforcement Agencies Crack Down on Financial Crime Control Failures, Sanctions ViolationsUK Announces New OTSI Civil Enforcement Powers on Trade Sanctions
On 12 September 2024, His Majesty’s Government (HMG) published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (Regulations), introducing new civil enforcement powers…
Continue Reading UK Announces New OTSI Civil Enforcement Powers on Trade SanctionsOFSI Issues Licensing Guidance for Payments to Personal Staff of Designated Persons
The UK’s Office of Financial Sanctions Implementation (OFSI) has issued guidance on when payments can be made to personal staff of designated persons (DPs).[1]…
Continue Reading OFSI Issues Licensing Guidance for Payments to Personal Staff of Designated PersonsUK Announces New Office of Trade Sanctions Implementation
On 11 December 2023, His Majesty’s Government (HMG) announced that it will create a new unit – the Office of Trade Sanctions Implementation (OTSI) within…
Continue Reading UK Announces New Office of Trade Sanctions ImplementationUK Court of Appeal Expands Scope of ‘Control’ Under Russia Sanctions Regulations: ‘Mr Putin could be deemed to control everything in Russia’
In a judgment handed down on 6 October, a UK Court of Appeal (the Court) provided an obiter, or non-binding, ruling expanding the scope…
Continue Reading UK Court of Appeal Expands Scope of ‘Control’ Under Russia Sanctions Regulations: ‘Mr Putin could be deemed to control everything in Russia’No Breach Too Small: OFSI Reports First Breach of UK’s Russian Sanctions Regulations
On 31 August 2023 the UK’s Office of Financial Sanctions Implementation (OFSI) issued a “Disclosure” against Wise Payments Limited, a UK-registered company, regulated by the…
Continue Reading No Breach Too Small: OFSI Reports First Breach of UK’s Russian Sanctions RegulationsUK Government General Licence Reduces Breadth of Recent Sanctions-Related Legal Advisory Services Ban
On 11 August 2023, the UK Department for Business and Trade issued a General Licence authorising the provision of legal advice in relation to sanctions…
Continue Reading UK Government General Licence Reduces Breadth of Recent Sanctions-Related Legal Advisory Services BanOFSI Updates Guidance on Refusing Licences
HM Treasury announced 26 July that the UK’s Office of Financial Sanctions Implementation (OFSI) has amended Section 6.12, Refusal of a licence, of its UK…
Continue Reading OFSI Updates Guidance on Refusing Licences