June 28, 2022

Volume XII, Number 179

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June 27, 2022

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UK Introduces Economic Crime Legislation in Wake of Russian Invasion of Ukraine

As anticipated in our previous GT Alert, the UK government is bringing forward its economic crime legislation in response to Russia’s invasion of Ukraine. The measures include:

  • a register of overseas entities that own real estate in the United Kingdom, including through a trust structure – a failure to declare being a beneficial owner could result in restrictions on selling a property and a prison sentence of up to five years. The register would apply to properties bought in the preceding 20 years for England & Wales, and from December 2014 for Scotland;

  • capping the cost of unsuccessful applications by government agencies such as the Serious Fraud Office, HMRC, and National Crime Agency for unexplained wealth orders;

  • allowing additional time for government agencies to consider material provided under an unexplained wealth order;

  • requiring applicants to provide more information as to their identity when creating new companies;

  • a new department dedicated to investigation of sanctions violations within the National Crime Agency.

In addition, the UK in common with the United States and EU has imposed sanctions on Russia’s central bank (and therefore its ability to use its $630bn war chest), and banned a number of Russian banks from SWIFT, the international payment system.

©2022 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume XII, Number 59
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About this Author

Of Counsel

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...

+44 0-203-349-8700
Shareholder

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...

+44 (0) 203-349-8700
Kara Bombach, Greenberg Traurig, Washington DC, International Trade and White Collar Defense Attorney
Shareholder

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Sudan), entities and individuals....

202-533-2334
Cyril Brennan, Greenberg Traurig Law Firm, Washington DC, International Trade Law Attorney
Shareholder

Cyril (Cy) Brennan focuses his practice on international trade regulation and compliance, with an emphasis on U.S. export controls and economic sanctions. Cy handles matters regarding the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), U.S. sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s anti-boycott regulations. In addition, he represents clients before the Committee on Foreign Investment in the United States (CFIUS), and advises clients...

202-533-2342
Sonali Dohale, Greenberg Traurig Law Firm, Washington DC, Environmental and International Trade Law Attorney
Associate

Sonali Dohale focuses her practice on compliance counseling, environmental due diligence and environmental litigation under state and federal statutes. Sonali’s experience at government regulatory agencies and her background in civil and environmental engineering help give her insight into both the legal and technical challenges faced by her clients.

In addition, Sonali assists clients engaged in international trade with a variety of federal regulatory issues, including matters related to the International Traffic in Arms Regulations (ITAR), the...

202-533-2381
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