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Corporate Crime analysis: What are the main practical issues with implementing and enforcing the government’s Action Plan? Zia Ullah, partner, and Victoria Turner, associate, in the financial services disputes and investigations team at Eversheds, explore some of the key issues.
How will the proposals contained in the Action Plan be implemented in the UK and internationally?
The Action Plan includes a wide-ranging set of proposals, including:
Top of the list is the reform of the current suspicious activity report process and supervisory regime and the strengthening of enforcement agencies powers. The Home Office will hold central responsibility. They will have an October 2018 deadline for full implementation. Capability and capacity building will be led by the National Crime Agency (NCA), who have until June 2017 to deliver the up-skilling programme for high-end money laundering.
Increasing international reach is a key theme, with the NCA due to create new International Liaison Officer posts in a number of important jurisdictions before the end of 2017. A complex area will be the plan for the UK to work the G20 Financial Action Task Force and others on international information-sharing, looking at the impact of data protection rules and other issues. Naturally the anti-terrorism plans are also heavily international, with the National Terrorist Financial Investigation Unit, Foreign and Commonwealth Office and Charity Commission all having a role to play.
Can you identify any cross-jurisdictional issues in relation to enforcement?
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