Disclosing Suspicious Activity Reports in civil litigation

The Government has recently published Circular 003/2021 clarifying how Anti-Money Laundering Suspicious Activity Reports (SARs) should be disclosed in civil litigation. The Circular provides important guidance for institutions who raise SARs (reporters) to the National Crime Agency and need to disclose the SAR in litigation. However, the guidance is in very general of terms and leaves some specific circumstances unaddressed.

Related briefings

Impact of FCA’s Business Plan on payments

As part of its 2021/22 Business Plan, published on 15 July, the FCA has stated that making payments safe and accessible is one of its four “consumer priorities” for the coming year.

BEIS and CMA step up consumer protection agenda

Last week the Government has announced an “arsenal” of planned reforms to boost competition and enhance consumer rights. The proposals, which are set out in the consultation paper Reforming Competition and Consumer Policy, cover three areas: competition policy; consumer rights; and consumer law enforcement. The ambitious reforms “seize the opportunity of the UK being able to chart its own way” post-Brexit and deliver on the ambitions set out in both the 2018 Consumer Green Paper and the more recent Penrose report on competition policy.

Latest Briefings

Funds & Investment Management Update – Ireland and Luxembourg – Q2 2021

This quarter’s highlights include the coming into force of the Investment Firms Directive and the Investment Firms Regulation, a number of AML developments, ESMA’s publication of funds’ marketing communications guidance and the CBI’s call for UCITS managers to review their liquidity risk management frameworks. Other notable developments include the CSSF’s updated guidance on granting loans to the public and updates to its UCITS and AIFM FAQs, the publication of a Circular on remote working as well as further EU sustainable finance developments.

The ILC Articles at 20: Introduction to the Symposium by Prof. Christian Tams and Dr Federica Paddeu

The Articles on the Responsibility of States for Internationally Wrongful Acts (Articles), developed by the International Law Commission (ILC), turn 20 this year. On 9 August 2001 – 45 years after the first report by Special Rapporteur Francisco García-Amador on the topic, after 5 Special Rapporteurs and 34 reports by them – the ILC adopted the final text of the Articles, thus bringing to an end work that (in the words of Rosalyn Higgins) were it not for the Commission‘s broad understanding of responsibility, ‘should on the face of it [have] take[n] one summer’s work’.

Scaling expertise through digital solutions

Neota Logic provides the ability to scale access to expertise through automation solutions using its no-code platform, making it an easier, faster and less expensive way to engage your stakeholders.

Portugal: Managing the Impacts of COVID-19

The COVID-19 pandemic has led to the adoption of legal measures that have a profound impact on businesses in different sectors and on society at large. The implications are broad and complex and we are committed to focusing our knowledge and experience to help you navigate these legal issues as they arise.


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