Author: gracechurchfcp

Fraudsters Sentenced for £21m Loss in Cryptocurrency

Digital Currencies, Fraud, Prosecutions
Four offenders were sentenced today (13 January 2023) for fraudulently obtaining and laundering Bitcoin and other cryptocurrency worth tens of millions of pounds from an Australia-based cryptocurrency exchange. Stephen William Boys, 58, Kelly Caton, 44, Jordan Kane Robinson, 23, and James Austin-Beddoes, 27, were found guilty of fraud, converting and transferring criminal property at Preston Crown Court and then sentenced to a total of 15 years. All four were associates of James Parker, who masterminded the conspiracy from his home in Blackpool over a three-month period between October 2017 and January 2018. James Parker identified and then exploited a loophole…

Thailand’s SEC issues rules on management of digital wallets for custody of digital assets and keys

Digital Currencies, Regulation
The Securities and Exchange Commission (SEC) has issued regulations requiring digital asset business operators that provide custody of clients’ digital assets to establish a digital wallet management system to accommodate efficient custody of digital assets and keys* and ensure safety of clients’ assets. The regulations cover the following requirements: (1) Policy and guidelines for overseeing risk management and management of digital wallets and keys as well as communication to clarify such policy, action plans and procedures, work supervision and internal control to ensure compliance with the policy; (2) Policy and procedures for designing, developing and managing digital wallets as well…

FCA penalises Al Rayan Bank PLC for anti-money laundering failures 

Money Laundering, Prosecutions
The Financial Conduct Authority (FCA) has fined Al Rayan Bank PLC (Al Rayan) £4,023,600 for failing to put in place adequate anti-money laundering (AML) controls. Between 1 April 2015 and 30 November 2017, Al Rayan allowed money to pass through the bank and be used within the UK without carrying out appropriate checks. The firm failed to adequately check its customers’ Source of Wealth and Source of Funds when it was required to make sure the money was not connected to financial crime.  The failings were made worse by the lack of proper training provided to staff about how to handle…

St. Louis Man Sentenced to 19+ Years for Money Laundering

Money Laundering, Prosecutions
A St. Louis man was sentenced to 19 years and seven months in prison after admitting to his involvement in a methamphetamine operation in southern Illinois. Terrence Thompson, 35, pled guilty to one count of conspiracy to launder monetary instruments. According to court records, Thompson conspired with the co-defendants to distribute more than 500 grams of methamphetamine in the Southern District of Illinois. Law enforcement conducted a search warrant on Thompson’s residence and recovered more than 10 kilograms of methamphetamine. Members of the conspiracy utilized various payment methods to deal the illegal narcotics, including CashApp, cashier’s checks, bank transfers and…

New York’s Financial Regulator Takes Aim at Firms Co-Mingling Crypto Funds

Digital Currencies, Regulation
New York’s chief financial regulator is set to release new guidance on Monday dictating that companies separate customers’ crypto assets from their own, after alleged co-mingling of funds at collapsed crypto exchange FTX and its affiliated trading firm Alameda Research led to hefty losses for clients. The New York State Department of Financial Services (NYDFS), which leads one of the few state agencies with a regulatory system in place for cryptocurrency companies, will also stipulate that state-regulated companies disclose to customers how they account for clients’ digital currency. The guidance is the latest in a series of crypto-related directives NYDFS…

UK Government Expands Enforcement Measures To Address Fraud and Money Laundering

Money Laundering
On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in 2023. The bill seeks to build on the Economic Crime (Transparency and Enforcement) Act 2022 (ECA 2022), which took effect on 15 March 2022. (See our 26 April 2022 client alert “New UK Economic Crime and Transparency Laws Take Effect” to review the key provisions of the ECA 2022.) Since that update, the “Register of Overseas Entities” requirements came into force on 1 August…

UK crime agency arrests ‘wealthy Russian’ over money laundering

Money Laundering
Britain’s National Crime Agency (NCA) said on Saturday it had arrested a “wealthy Russian businessman” on suspicion of money laundering and other offences as part of a crackdown on corrupt oligarchs. The NCA said the 58-year-old was among three men arrested by officers from the Combatting Kleptocracy Cell (CKC) on Thursday at a “multi-million pound residence” in London. The Russian embassy in London has demanded information from Britain’s Foreign Office on the reasons and circumstances of the detention of the unidentified businessman and the conditions in which he was being held, Russian news agencies said. The man was detained on…

Fraud alert: Five bank scams to watch out for 2023

Fraud
As many of us wind down over the festive period into the New Year, fraudsters are busy at work luring in unsuspecting victims. The UK is currently in the grip of a fraud epidemic, from get-rich-quick schemes to unknown sellers tempting consumers with fake bargains. The rising cost of living is forcing many people to seek alternative ways to save and make money, and fraudsters are capitalising on it. They will often trick victims into making quick bank transfers rather than using other, more secure payment methods. UK consumer group Which? is warning against unwittingly handing over money and has…

Criminals are using the cost of living crisis to scam the public – don’t become a victim

Fraud
Law enforcement, government and private sectors partners are working together to encourage members of the public to be more vigilant against fraud, particularly about sharing their financial and personal information, as criminals seek to capitalise on the cost of living crisis. Criminals are experts at impersonating people, organisations and the police. Stop: Taking a moment to stop and think before parting with your money or information could keep you safe. Challenge: Could it be fake? It’s ok to reject, refuse or ignore any requests. Only criminals will try to rush or panic you. Protect: Contact your bank immediately if you…

Tax dodging and non-compliance during pandemic cost UK £9bn – NAO

Tax Evasion
Tax dodging and non-compliance during the pandemic cost the government £9bn, Whitehall’s spending watchdog has found. The loss to the public purse came as HM Revenue & Customs (HMRC) moved thousands of tax compliance staff to Covid support schemes, reducing its capacity to investigate people and businesses not paying the right amount, according to the National Audit Office. About 1,350 workers were redeployed to Covid schemes throughout 2020-2021, shrinking the number of those working on tax compliance by 12%, the NAO said. Before the pandemic, tax revenues from HMRC’s compliance work were on average 5.2% of its total revenues. This…

SEC Charges Danske Bank with Fraud for Misleading Investors about Its AML Compliance Failures in Estonia

Fraud, Money Laundering, Prosecutions, Regulatory Fines
The Securities and Exchange Commission today announced fraud charges against Danske Bank, a multinational financial services corporation headquartered in Denmark, for misleading investors about its anti-money laundering (AML) compliance program in its Estonian branch and failing to disclose the risks posed by the program’s significant deficiencies. Danske Bank agreed to pay $413 million to settle the SEC’s charges. According to the SEC’s complaint, when Danske Bank acquired its Estonian branch in 2007, it knew or should have known that a substantial portion of the branch’s customers were engaging in transactions that had a high risk of involving money laundering; that…

Santander Fined £108M for AML Failings

Money Laundering, Prosecutions, Regulatory Fines
BRITAIN’S Financial Conduct Authority (FCA) today announced it has fined Santander almost £108M for AML failures in its business banking division. The FCA ruled the UK division of the Spanish bank had failed to manage its anti-money laundering systems properly – affecting the way it dealt with 560,000 business customers. Between 2012 and 2017 the bank’s systems were not able to verify properly information provided by customers about their businesses. “Santander’s poor management of their anti-money laundering systems and their inadequate attempts to address the problems created a prolonged and severe risk of money laundering and financial crime,” said Mark…

Elizabeth Warren’s Tough-On-Crypto Bill is Taking Shape

Digital Currencies, Regulation
Sen. Elizabeth Warren, D-Mass. is working on a sweeping cryptocurrency bill that would hand the Securities and Exchange Commission most regulatory authority over the market, according to two people familiar with her efforts. While discussions are still early and details could change, Warren’s office is looking at a range of crypto-related issues, including regulations, taxation, climate, and national security. The senator has recently stepped up her criticism for the industry and demanded “comprehensive” new rules to govern it following the massive collapse of the crypto exchange FTX. (FTX founder Sam-Bankman Fried is an investor in Semafor.) Ideas on the table…

Former director in the Office of the Director General of Audit Sentenced to 4 Years in Bribery Case

Bribery, Prosecutions
A Paramasivan, former director (AMF-II) in the Office of Director General of Audit, Central Expenditure, New Delhi has been sentenced to four years of rigorous imprisonment and a fine of Rs 10,000 by the principal special judge for CBI Cases, Chennai (Tamil Nadu) in a bribery case. The Indian Audit and Accounts Service was sentenced along with Sivaram Thilagar, then Assistant Surgeon, Government Primary Health Centre,Kanchipuram (Tamil Nadu) in a bribery case. Sivaram has been sentenced to undergo three years rigorous imprisonment with fine of Rs 5000 in a bribery case. The CBI had registered a case against the accused…

Sanctions Targets Allowed up to £1m of Frozen Funds to Pay Jersey Legal Bills

Sanctions
Russian oligarchs and others facing sanctions can now access up to £1 million of their Jersey-based funds to pay outstanding bills to local lawyers. The island’s External Relations Minister has issued a new ‘general licence’, which allows legal firms who have represented clients facing international sanctions to be paid more easily. While people linked to the regimes in Russia have had their financial assets in Jersey frozen since the country invaded Ukraine in February, they have still been able to get legal advice or representation – but have not been able to pay their bills without an individual licence from…

The European Union’s Qatar Bribery Scandal

Bribery, Corruption
The European Union is embroiled in a scandal involving alleged influence peddling through a European Parliament vice president, literal bags of cash, a nonprofit organization called Fight Impunity, and a “Gulf State” widely reported to be Qatar, host of the 2022 FIFA World Cup. Nothing less than “Europe’s credibility is at stake” in the EU’s response, German Foreign Minister Annalena Baerbock said. Here’s what you need to know: Who was allegedly bribed to do what?Belgian police raided at least 20 sites across Brussels between Dec. 9 and Dec. 13, including inside European Parliament offices, arresting six people and seizing more…

Federal Court Orders Man to Pay More than $2.8 Million in Restitution for Virtual Currency Fraud

Fraud, Prosecutions
The Commodity Futures Trading Commission today announced the U. S. District Court for the Southern District of New York entered a consent order on November 29 for a permanent injunction, restitution, and equitable relief against Jeremy Spence of Bristol, Rhode Island. Spence, at times, conducted business as Coin Signals. The consent order resolves a CFTC action filed against Spence on January 26, 2021 alleging that he operated a virtual currency Ponzi scheme in which he fraudulently solicited individuals to invest in digital assets such as bitcoin and ether. [See CFTC Press Release No. 8356-21] The order requires Spence to pay…

Rabobank Investigated for Suspected Dutch Money Laundering Violations

Money Laundering
Dutch co-operative bank Rabobank (RABO.UL) on Wednesday said it is under investigation by public prosecutors in the Netherlands for suspected violations of national money laundering laws. The bank in a statement said it was cooperating with the investigation. The disclosure follows a 2021 warning by the bank that it had been instructed by the Dutch central bank (DNB) to fix its customer due diligence practices and that it was facing a “punitive enforcement procedure.” Rabobank is one of the Netherlands’ three largest banks. Competitors ING Group and ABN Amro incurred massive fines in similar situations, with ING docked $900 million…

Argentina Vice President Cristina Fernández de Kirchner Sentenced to 6 Years in Prison for Corruption

Fraud, Prosecutions
A federal court in Argentina sentenced the current Vice President Cristina Fernández de Kirchner to six years in prison and a life ban from public office after finding her guilty of corruption. The court found her guilty of fraudulent administration during her time as president from 2007 to 2015 in awarding public works contracts to friend and businessman Lázaro Báez, who was also given a six-year sentence as part of the same case. Last year, Báez was sentenced to 12 years in a separate case for money laundering. The prosecutors said that they found irregularities in multiple public work tenders…

Son of Former Mozambique President Sentenced to 12 Years in Prison for Fraud

Fraud, Prosecutions
The son of Mozambique’s ex-president was sentenced Wednesday to 12 years in prison for embezzlement and money laundering. Judge Efigenio Baptista said Armando Ndambi Guebuza defrauded the government of more than $2.7 million, and is responsible for crimes of money laundering, embezzlement of State funds; use of false documents; four crimes of forgery of other writings; blackmail, influence peddling and association to commit crime. Guebuza, the oldest son of former Mozambique president Armando Guebuza, was sentenced along with 10 other defendants including the former head of security and intelligence Gregorio Leao. The corruption case came after three newly state-owned companies…

Sanctions Forcing Russia’s Sberbank to Close UAE Office

Sanctions
Russia’s dominant lender Sberbank will be forced to close its office in the United Arab Emirates (UAE) early next year, First Deputy Chairman Alexander Vedyakhin said on Monday, blaming sanctions pressure. Sweeping Western sanctions targeted Russia’s financial system after Moscow sent tens of thousands of troops into Ukraine on Feb. 24. Sberbank is one of several major Russian banks to have been blocked from the international SWIFT payments system and some senior executives have been personally hit by sanctions. “Unfortunately, in the context of sanctions restrictions, we are facing serious constraints on our SberInvest Middle East office in Abu Dhabi…

Angolan Court orders Seizure of Dos Santos Assets

Money Laundering, Proceeds of Crime
Angola’s Supreme Court has ordered the “preventive” seizure of assets worth around $1 billion held by Isabel dos Santos, the daughter of the southern African country’s former president, Portugal’s Lusa news agency said on Tuesday. The court document cited by Lusa, dated Dec. 19, said authorities had evidence of alleged embezzlement and money laundering and ordered the seizure of the money dos Santos holds in “all banking institutions”. The seizure also includes all of dos Santos’s shares in Angolan company Embalvidro, as well as 100% of shares in Cape Verde’s telecom company Unitel T+ and Unitel STP in Sao Tome…

Dutch Banks Bring in new fees for money laundering checks

Compliance
Companies, foundations and churches are being asked to pay additional banking fees to cover the cost of money laundering investigations, broadcaster NOS noted on Tuesday. ABN Amro, ING and SNS have already introduced the new fees and Rabobank will follow on next week, NOS said. Banks say the monthly charge is needed to pay for the extra checks they have to make for money laundering and funding terrorism. ‘The cost for banks have risen considerably in recent years,’ Helène Erftemeijer from the Dutch banking association said. ‘Some 13,000 people are involved in this sort of research and the increasing costs…

France’s Safran to pay $17.2 million to settle China Bribery in US probe

Bribery, Corruption
(Reuters) – French jet engine maker Safran SA will pay about $17.2 million as part of a settlement with the U.S. Justice Department over bribes its subsidiaries allegedly paid in China, the Department of Justice (DoJ) said in a statement made public on Friday. The Paris-based aerospace supplier will be required to turn over profits from “corruptly obtained” and retained contracts by its U.S.-based subsidiary, Monogram Systems, the DoJ said. Monogram and Safran’s German unit, Evac GmbH, allegedly paid bribes to obtain “lucrative” train lavatory contracts with the Chinese government. Safran did not immediately respond to Reuters request for a…

UK Anti Money Laundering and Countering the financing of Terrorism – Supervision Report 2020-22

Regulation
This report provides information about the performance of AML/CTF supervisors between 6 April 2020 – 5 April 2022 and fulfils the Treasury’s obligation, under Section 51 of the MLRs, to publish an annual report on supervisory activity. The report includes supervisory and enforcement data on both the Statutory and Professional Body Supervisors, highlighting any notable changes in supervisory activity and any fines that supervisors have issued. This report provides supervisory and enforcement data for both the 2020-2021 period (6th April 2020 – 5th April 2021) and the 2021-2022 period (6th April 2021 – 5th April 2022). The two years have…

FTX diverted $200 million of customer money for two venture deals that caught the SEC’s attention

Digital Currencies, Fraud
Of the billions of dollars in customer deposits that disappeared from FTX in a flash, $200 million was used to fund investments in two companies, according to the Securities and Exchange Commission, which charged founder Sam Bankman-Fried with “orchestrating a scheme to defraud equity investors.” Through its FTX Ventures unit, the crypto firm in March invested $100 million in Dave, a fintech company that had gone public two months earlier through a special purpose acquisition company. At the time, the companies said they would “work together to expand the digital assets ecosystem.” The other deal the SEC appears to have…

Biggest Bribery Fines of 2022

Bribery, Corruption, Prosecutions, Regulatory Fines
Key bribery fines & settlements in 2022 Glencore – $1bn settlementFirstEnergy – $180m settlementTenaris – $78m settlementStericycle – $84m settlementK.T. Corporation – $6.3m settlementKPMG – £3.4m fineBoulting Group – £500k fineTritec and Electron – £70k fine each Whilst companies face multi-million settlement penalties, the consequences for individuals can include jail time. Biggest bribery fines in 2022 in detail The SFO’s investigation revealed that Glencore paid over $28m (£22.2m) in bribes through its employees and agents in exchange for preferential access to oil, including larger cargoes, more valuable oil grades, and preferred delivery dates. The firm gave the go-ahead for these…

£4.5bn Lost in 3 COVID Schemes as “Eat Out to Help Out” Scheme Recorded 9.5% Rate of Fraud

Fraud, Uncategorized
The revelation emerges during a hearing of the Treasury Committee, which hears the HMRC seized a non-fungible token cryptocurrency asset and is “ahead of the game” compared to “most other tax authorities” on the potential use of cryptocurrencies for tax evasion, according to CEO Jim Harra. The total value of fraud in three COVID-19 schemes totalled £4.5bn, of which the taxpayer is only going to get £1.1bn back, the head of HM Revenue and Customs (HMRC) has told MPs. Speaking at the Treasury Committee on Wednesday, HMRC chief executive Jim Harra said the £4.5bn was lost to fraud in the…

UNODC Launch Manual to Tackle Underreported Crime of Organ Trade

Financial Crime, Trafficking
The United Nations Office on Drugs and Crime (UNODC) has launched a new toolkit on how to effectively investigate and prosecute the trafficking of people for the purpose of organ removal – a form of trafficking that has been persistently left in the dark, yet is detected in many countries around the world. Driven largely by the global shortage of organs available for transplant, it is estimated that ethical transplants cover less than 10% of the global need. This disparity has resulted in sick patients seeking out organs from the black market, a process facilitated by criminal groups who engage…

OFAC Sanctions Internet-based Suppliers of Illicit Fentanyl and Other Synthetic Drugs

Digital Currencies, Drug Trafficking, Sanctions
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three individuals and nine entities associated with darknet marketplaces and research chemicals sites under the Illicit Drugs Executive Order (EO 14059) for supplying illicit synthetic substances to U.S. markets through internet sales and a host of shell companies. Today’s action marks the first time this EO has been used to designate activities related to online and darknet market illicit drug sales. Two individuals, Alex Adrianus Martinus Peijnenburg (Peijnenburg) and Martinus Pterus Henri De Koning (De Koning) began their business selling illicit fentanyl, synthetic stimulants, cannabinoids, and…

Cross-Border Cybercrime Raid Nabs Scam Call Centers Exposed By OCCRP

Fraud, Prosecutions
European authorities this month launched a coordinated action against hundreds of suspects accused of running a massive investment fraud network that was exposed by OCCRP in a 2020 investigation, Eurojust and Europol announced. Police and prosecutors from Albania, Bulgaria, Finland, Georgia, Germany, Latvia, North Macedonia, Spain, Sweden, and Ukraine worked together on an “unprecedented” cross-border investigation that culminated in the arrests of five suspects and confiscation of hundreds of thousands of euros’ worth of cash, as well as cryptocurrency wallets, properties, and bank accounts, according to Eurojust. The joint team, which Eurojust, the EU agency for judicial cooperation, coordinated and…

Hochul Signs Partial Cryptocurrency Mining Nan into New York Law

Digital Currencies, Regulation
New York’s nation-leading Climate Leadership and Community Protection Act, the most aggressive climate and clean energy law in the nation, while also continuing our steadfast efforts to support economic development and job creation in upstate New York.” The new law will also trigger a study by state Department of Environmental Conservation to study the impacts of the cryptocurrency mining industry on the environment. The measure was hotly debated in the halls of the state Capitol this year, with environmental groups pushing lawmakers and Hochul to support the bill and the industry urging Hochul to reject it. “Thank you, Governor Hochul,…

EU Court of Justice Rolls Back Anti-Money Laundering Rules

Money Laundering, Regulation
In a stunning reversal, the Court of Justice of the European Union weakened an existing anti-money laundering rule on Tuesday, limiting use of one of the most potent tools against financial secrecy – access to beneficial ownership information. “Beneficial ownership” is the term for who, in reality, benefits from (or owns) a given company or corporate structure. Wealthy individuals, criminals and tax cheats are among those who routinely disguise ownership of such entities, often to hide their wealth from authorities. Organizations fighting for tax equity and reform immediately denounced the ruling. “By requiring corporations and offshore entities to publicly disclose…

NCA secures £50m identified by Barclays as the Proceeds of Crime

Money Laundering, Proceeds of Crime
The National Crime Agency (NCA) has obtained a ruling from the High Court that allows Barclays to hand over criminal funds to the NCA in a first-of-its-kind civil recovery case. The money – amounting to over £50m – was identified by the bank in a number of accounts and transferred to secure holding accounts. The civil recovery order means that for the first time, legal powers were used to recover the proceeds of crime where the account holders were not named in the court action. Adrian Searle, Director of the National Economic Crime Centre (NECC) in the NCA said: “Identifying…

JP Morgan, Deutsche Bank sued by Epstein accusers in New York

Regulatory Risk
(Bloomberg) — JPMorgan Chase & Co. and Deutsche Bank AG were accused of enabling the sexual abuse of Jeffrey Epstein in New York class action suits that allege the banks turned a blind eye in order to “churn profits.” The lawsuits, filed separately in a New York court, allege the banks had “knowingly benefited and received things of value for assisting, supporting, facilitating, and otherwise providing the most critical service for the Jeffrey Epstein sex trafficking organization.” JPMorgan was accused in the suit of “financially benefiting from participating” in the alleged sex trafficking through providing financial support from 1998 to…

Belgium has seized more cocaine than it can destroy

Drug Trafficking
The amount of cocaine being seized at the Belgian port of Antwerp is so massive that authorities are worried smugglers could steal it back because police can’t burn it fast enough. Officials said there is not enough incinerator capacity to cope with rising seizures of the drug at the port, creating what has been dubbed a “cocaine-berg”. As a result, Belgian port authorities and ministers are worried the backlog of cocaine being stored at secret depots near the port could be targeted by organised crime gangs, who are known to have corrupt police and port workers on their books. Antwerp…

Trace Releases 2022 Bribery Risk Matrix

Bribery, Corruption
ANNAPOLIS, MD, U.S.—15 November 2022—TRACE, a non-profit international business association dedicated to anti-bribery, compliance and good governance, has released the 2022 Bribery Risk Matrix, which measures business bribery risk in 194 jurisdictions. According to this year’s data, North Korea, Turkmenistan, Equatorial Guinea, Syria and Venezuela present the highest commercial bribery risk, while Norway, New Zealand, Sweden, Switzerland and Denmark present the lowest. Other notable findings: The United States ranked 16th and scored 19 out of 100. The enforcement environment hasn’t improved since a slump during the Trump administration, and the free press environment continues to decline.Ukraine ranked 103rd and scored…

Crypto Regulatory Affairs – Global Regulatory Response to FTX Collapse

Digital Currencies
The collapse of FTX – once one of the most dominant cryptoasset exchanges worldwide – has sparked concern from investors, consumers, industry participants and regulators alike. Previously, there were discussions – and a signed letter of intent – indicating that fellow crypto exchange Binance would be acquiring FTX. Shortly after, news broke that it would be walking away from the deal completely due to the severity of FTX’s internal mismanagement. A spokesperson from Binance told media outlets: “As a result of corporate due diligence, as well as the latest news reports regarding mishandled customer funds and alleged US agency investigations,…

New Crackdown on Fraud and Money Laundering to Protect U.K. Economy

Financial Crime, Fraud, Regulation
The Economic Crime and Corporate Transparency Bill will strengthen the UK’s reputation as a place where legitimate businesses can thrive while driving dirty money out of the UK. Through the reforms, anyone who registers a company in the UK will need to verify their identity, tackling the use of companies as a front for crime or foreign kleptocrats. The reforms to Companies House – its biggest upgrade in 170 years – will also see the organisation armed with new powers to check, challenge and decline incorrect or fraudulent information, making it a more active gatekeeper over company creation. The investigation…

U.K. No Longer an Active Enforcer of Foreign Bribery as Global Enforcement Hits Historic Low

Bribery, Corruption
Britain has lost its place among the top enforcers of foreign bribery laws in new research published today by Transparency International. Exporting Corruption 2022, which ranks the world’s biggest exporters on how well they investigate and sanction companies for paying bribes abroad, sees the UK relegated from the ‘active’ enforcers group to join Germany, France, and others deemed to be only ‘moderate’ enforcers. Foreign bribery wreaks havoc in countries around the world, illicitly channelling public money into private profits and buying undue influence over government decision-making for major multinationals. This is the first time the UK has fallen out of…