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NEWS
The Scottish Affairs Committee (SAC) is set to hold its inaugural session on 20 November 2024, with the Secretary of State for Scotland, Rt Hon Ian Murray MP, making his first appearance. The cross-party committee will scrutinise the future of intergovernmental relations between the UK and Scottish Governments, exploring potential 'reset' strategies and differing approaches from the previous administration. The Scotland Office's work programme and priorities will be examined, including the newly announced £750,000 'Brand Scotland' initiative. MPs are also expected to probe the Scotland Secretary on matters concerning the Scottish energy industry, such as GB Energy and the Great British Energy Bill, as well as ongoing developments at Grangemouth. Also attending as witnesses will be Advocate General for Scotland, Baroness Smith of Cluny KC, and Director and Solicitor to the Advocate General, Neil Taylor.This session marks a significant step in parliamentary oversight of Scottish affairs and intergovernmental dynamics.
GLOSSARY
Significant Adverse Condition Investigation
FLOWCHARTS
This Flowchart illustrates the process of deciding whether an external suspicious activity report (SAR) must be made to the National Crime Agency (NCA). It covers both the situation where a member of staff: • refers a concern, and • submits an internal SAR to the nominated officer See further Practice Notes: Making a SAR and obtaining a defence or consent, or for law firms Making a SAR and obtaining a defence or consent—law firms and
GLOSSARY
This is an acronym for the Swiss Averaged Rate Overnight. SARON has been selected to replace Swiss Franc LIBOR.
PRACTICE NOTES
Issues of confidentiality arise in two different respects in terms of suspicious activity reports (SARs): • your professional or regulatory duty of confidentiality to your customer (if you owe such a duty), and • the confidentiality of the SAR itself This Practice Note discusses both aspects. It provides guidance which is of general application. You should check whether the law or your regulatory body has any additional, sector specific requirements in relation to confidentiality. Counter-proliferation financing is an established component of theanti-money laundering (AML) and counter-terrorist financing (CTF) regime. Requirements in relation to counter-proliferation financing were introduced into the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 through the Money Laundering and Terrorist Financing (Amendment) (No. 2) Regulations 2022, SI 2022/860. While counter-proliferation financing requirements cover the appointment of a nominated officer, because they scoop up regulations 21 to 24 (see reg 19A), neither the Proceeds of Crime Act 2002 (POCA 2002) or the Terrorism Act 2000 (TA 2000) have been amended to include reference
PRACTICE NOTES
Issues of confidentiality arise in two different respects in terms of suspicious activity reports (SARs): • your duty of confidentiality to the client • the confidentiality of the SAR itself This Practice Note discusses both aspects. It provides guidance which is of general application. You should check whether the law or your regulatory body has any additional, sector specific requirements in relation to confidentiality. Counter-proliferation financing is an established component of the anti-money laundering (AML) and counter-terrorist financing (CTF) regime. Requirements in relation to counter-proliferation financing were introduced into the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 through the Money Laundering and Terrorist Financing (Amendment) (No. 2) Regulations 2022, SI 2022/860. While counter-proliferation financing requirements cover the appointment of a nominated officer, because they scoop up regulations 21 to 24 (see reg 19A), neither the Proceeds of Crime Act 2002 (POCA 2002) or the Terrorism Act 2000 (TA 2000) have been amended to include reference to proliferation financing suspicions. See further Practice Note: Counter-proliferation
NEWS
The UK Financial Intelligence Unit’s (UKFIU) magazine, SARs in Action, has published its 29th issue focusing on recent developments in economic crime prevention. The publication emphasises the financial sector's crucial role in detecting and disrupting human trafficking, which affects an estimated 49.6 million people globally. It introduces the Illicit Finance Public Private Threat Group (PPTG) Hydroponics Cell and its recent Amber Alert. The magazine also covers the 2024 Global Financial Institutions Partnership Summit in Ottawa and announces the winners of the 2024 Tackling Economic Crime Awards. Additionally, it highlights Companies House's analysis of company formations used for money laundering and introduces a new Trafficking in Human Beings Handbook, underscoring the importance of the regulated financial industry in combating this pervasive criminal enterprise.
NEWS
The UK Financial Intelligence Unit’s (UKFIU) magazine, SARs in Action, has published its 37th issue. The UKFIU’s 37th issue of SARs in Action highlights several key developments, with particular emphasis on the use of artificial intelligence (AI) to bypass customer due diligence (CDD) checks. A Joint Money Laundering Intelligence Taskforce (JMLIT) Amber Alert, published in April 2026, confirms that the use of AI to bypass CDD is a current threat to the UK financial sector. AI has been used to manipulate identity documents and create deepfakes to impersonate individuals or create synthetic identities, and accounts opened using AI-manipulated images or video have been used to facilitate fraud and launder proceeds from criminal activity. Where related activity gives rise to a suspicion of money laundering or terrorist financing, institutions may submit a suspicious activity report (SAR) and are encouraged to include Amber Alert reference 0801-NECC.
NEWS
The UK Financial Intelligence Unit’s (UKFIU) magazine, SARs in Action, has published its 28th issue focused on the Interpol General Assembly themes of Global Leadership, Innovation and Collaboration. This issue examines how the National Economic Crime Centre Project Winterproof is spearheading the fight against international fraudsters targeting UK individuals and businesses. The issue also looks into Egmont Group and how its network plays a crucial role in promoting co-operation and improving the efficiency of financial intelligence.
NEWS
The UK Financial Intelligence Unit’s (UKFIU) magazine, SARs in Action, has published its 30th issue. The UKFIU's 30th issue of SARs in Action highlights several key developments. The UKFIU has joined new international partnerships to combat illegal wildlife trade, including Europol's IWT work stream and the Egmont Group's Environmental Crimes Project. An analysis of SARs related to illegal wildlife trade revealed low reporting levels, suggesting potential knowledge gaps. The issue also covers an Amber Alert on AI use in bypassing customer due diligence, progress on the SARs Digital Service, case studies on fraud prevention and money laundering, and an overview of Operation DESTABILISE targeting Russian money laundering networks. A new 'Dear UKFIU' feature has been introduced to address reporter questions.
PRACTICE NOTES
The underwriters or initial purchasers in an international securities offering will customarily require that the issuer's accountants provide one or more comfort letters relating to financial information contained in the prospectus or offering memorandum relating to the offering. Comfort letters are an important part of the underwriters' due diligence review and defence from potential liability under US securities law. Comfort letters are often referred to as SAS 72 letters, which relates to the Statement on Auditing Standards 72 (SAS 72) on which they are based. The Statement on Auditing Standards 72 has now been superseded by AU Section 634, Letters for Underwriters and Certain Other Requesting Parties (AU 634). Comfort letters and the 'due diligence' defence The basis for potential liability under US securities laws differs depending on whether the offering is publicly offered in the US, ie registered with the Securities and Exchange Commission (SEC), or privately offered to US investors, eg in an institutional placement
NEWS
The Subsidy Advice Unit (SAU) has published a report in response to a request from the Department for Energy Security and Net Zero (DESNZ) regarding the Capacity Market scheme, as amended in 2025. The report evaluates DESNZ's assessment of the scheme's compliance with the requirements outlined in the Subsidy Control Act 2022 (SCA 2022).