The firm was issued a £5,000 penalty following an investigation by the Solicitors Regulatory Authority into money laundering and terrorist financing risks.

In a clear demonstration of the SRA’s willingness to flex its new fining powers, the SRA has penalised Settle-based Goad & Butcher for six years of anti-money laundering failures. The firm has also had conditions imposed on its authorisation. This comes after previous efforts to bring it into compliance failed.

According to the SRA, since June 2017 the firm failed to have in place a documented and compliant firm-wide risk assessment or compliant policies, controls and procedures. This is  contrary to the 2017 Money Laundering,Terrorist Financing and Transfer of Funds Regulations. The firm then failed to have sufficient regard for the SRA’s warning notice on firm-wide risk assessments in May 2019.

Glencore, the mining and commodities giant, has been fined a record-breaking £281 million for bribery in five African countries. The company was found to have paid cash bribes to officials in the national oil and gas companies in Cameroon, Equatorial Guinea, Ivory Coast, Nigeria and South Sudan to secure its access to oil. The Serious Fraud Office (SFO) launched an investigation into Glencore in 2019, focused on the activity of the London-based West Africa desk, which sourced and traded crude oil from African countries.

The Legal Sector Affinity Group (LSAG) has updated its guidance on the anti-money laundering (AML) regulations. As of 28 March, Guidance on the new requirement to carry out proliferation financing risk assessments, either as part of the firm’s existing practice-wide risk assessment or as a standalone document.

What is proliferation financing?

Proliferation financing is defined by the FATF as the provision of funds or financial services used for the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical or biological weapons and their means of delivery and related materials, including both technologies and dual-use goods used for non-legitimate purposes.

A key focus on preventing the threats posed by Proliferation Financing is the strict implementation of the sanctions regime on North Korea and Iran, as well as preventing chemical weapons activity. 

Sanctions laws apply to all businesses. Any business who breaches a UK sanctions regime could be fined or subject to criminal prosecution. Breaching sanctions was recently made a strict liability offence, meaning a business only has to have breached the law to be liable for a penalty, there is no requirement for intent. 

What to do now

• Review your business for PF risks with a dedicated risk assessment process
• Review your AML policies and sanctions policies in light of PF risks
• Amend your risk assessments to incorporate PF risks
• Implement specific controls and measures highlighted by the PF risk assessment
• Record these controls and analyse their effectiveness

VinciWorks have published a new guide covering the basics of proliferation financing, how PF occurs, key PF risks in the UK, red flags and more.

Download proliferation financing guide

The Gambling Commission announced the largest penalty ever issued by the regulator. William Hill, the betting giant, was slapped with a fine of £19.2M, for failing to protect consumers and stop money laundering.

The Commission’s Chief Executive, Andrew Rhodes, revealed that the problems at the three companies owned by William Hill were “widespread and alarming,” and the regulator seriously considered suspending the firm’s licence.