13 January 2023
Nearly a year after Russia’s invasion of Ukraine in February 2022, what’s the latest on the UK’s economic crime and sanctions regime? Cameron Brown KC, Red Lion Chambers, and Olivia Haggar, 5KBW, assess the effectiveness of the UK’s efforts to date, in this week’s NLJ.
Brown & Haggar review the powers introduced in March 2022 under the Economic Crime (Transparency and Enforcement) Act 2022, including setting up the Register of Overseas Entities as well as making the breaching of sanctions a strict liability offence.
They highlight weaknesses in the system, for example, where multiple individuals hold overseas entities or where the ultimate beneficial owner is a nominee. They also look ahead to a bill currently at report stage in Parliament.
There is still much to do. For example, the authors note, ‘at present, Companies House requires minimal checks and information when a company is incorporated—meaning shell companies, through which illicit funds can be washed, can be created without detection.’
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