As noted in the prior post, there are no formal legal defenses available when a company violates the Gross Human Rights Abuse provisions of the Criminal Finances Act. How, then, should companies deal with allegations that they’ve committed violations?… Continue Reading
The most important thing for a company to remember when dealing with the Gross Human Rights Abuse provisions of the Criminal Finances Act is that they appear to be designed as a strict liability regime with no statutory defenses available.… Continue Reading
The UK’s Criminal Finances Act, a new law that expands remedies for UK prosecutors to use against gross human rights abuses, also targets activity “connected to” gross human rights abuses.
Activity “connected to” gross human rights abuses includes: directing or sponsoring, profiting from, materially assisting, or acting as an agent in connection with, the commission of gross human rights abuses.… Continue Reading
Ever since the Panama Papers exposed the underground nexus of global tax evasion, regulators have been trying to figure out how to get ahead of it. In the UK, the Criminal Finances Act was passed in late April 2017.… Continue Reading
In the prior post, we introduced readers to the UK’s Criminal Finances Act, a new law that expands remedies for UK prosecutors to use against gross human rights abuses. But what are gross human rights abuses?… Continue Reading
In April 2017, the United Kingdom enacted the Criminal Finances Act which has created substantial new scopes of liability for companies engaging in business abroad.
Section 13 of the CFA expands the scope of the Proceeds of Crime Act to cover the international commission of gross human rights abuses against whistleblowers and human rights activists.… Continue Reading