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Articles by Bethany Gregory
A football club’s guide – dealing with information requests from the IFR and key risks for clubs, individuals and related parties
Friday, 08 May 2026 Author: Zeena Saleh, Joanna M Dimmock, Bethany Gregory The new Independent Football Regulator (IFR), modelled on UK financial services supervision, has extensive information-gathering and information-sharing powers under the Football Governance Act 2025[1] (the Act). Therefore, clubs should look (ever closer) at the horizon: What happens if the IFR deems it necessary to gather information for supervision and potential enforcement of the new regime?
Data Protection Guidance For Firms Sharing Customer Information For The Prevention Of Fraud
AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
Data protection guidance for firms sharing customer information for the prevention of fraud | JD Supra
Obstacles for information sharing The recent Economic Crime Transparency Act 2023 (2023 Act), along with accompanying guidance published in late 2024, encouraged the quicker and easier sharing of customer information between firms in the UK financial sector for the purposes of preventing, detecting and investigating economic crime concerns (see our blog post here for further details).
Customer information sharing in the Economic Crime and Corporate Transparency Act key points for firms | JD Supra
Quicker and easier sharing of customer information relating to economic crime concerns between firms in the UK financial sector has been encouraged by provisions in the Economic Crime and Corporate Transparency Act 2023 (Act), which came into force on 15 January 2024. The UK Government published accompanying in October 2024. We explore the key features of the new information sharing gateways.
New UK Government guidance on customer information sharing in the Economic Crime and Corporate Transparency Act 2023 | JD Supra
Quicker and easier sharing of customer information relating to economic crime concerns between firms in the UK financial sector has been encouraged by provisions in the Economic Crime and Corporate Transparency Act 2023 (Act), which came into force on 15 January 2024. The UK Government published accompanying in October 2024. We explore the key features of the new information sharing gateways.
New UK Government guidance on customer information sharing in the Economic Crime and Corporate Transparency Act 2023
Quicker and easier sharing of customer information relating to economic crime concerns between firms in the UK financial sector has been encouraged by provisions in the Economic Crime and Corporate Transparency Act 2023 (Act), which came into force on 15 January 2024. The UK Government published accompanying in October 2024. We explore the key features of the new information sharing gateways.
Risks in sustainability-related disclosures – reflections on landmark climate litigation actions in the English courts | JD Supra
Last year, we wrote about ClientEarth’s application to the High Court of England and Wales for permission to bring a judicial review claim, alleging that the UK Financial Conduct Authority (FCA) unlawfully approved the IPO prospectus of an energy company. Following the High Court’s dismissal of the application, a renewal hearing was held on 13 December 2023, where the judge again refused permission to bring the judicial review claim. Please see full publication below for more information.
Economic Crime and Corporate Transparency Act 2023 - anti-money laundering considerations for the regulated sector | JD Supra
As part of the Economic Crime and Corporate Transparency Act 2023, there are two new 'pay-away' exceptions to the need for a firm in the regulated sector to file a Defence against Money Laundering Previously a firm in the regulated sector1 faced an onerous burden when exiting a customer relationship where the account was suspected to contain criminal property. The firm had to seek a ‘defence against money laundering’ (DAML) from the UK National Crime Agency (NCA) before paying the property away.
UK sanctions systems and controls: lessons learnt | JD Supra
The UK Financial Conduct Authority (FCA) has assessed the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors and summarised its findings of good and poor practice. Acknowledging the size, scale and complexity of sanctions imposed since Russia’s invasion of Ukraine, the FCA continues to increase its focus on firms’ sanctions systems and controls and hopes that its findings will help firms to deliver greater compliance with sanctions.
Customer information sharing in the Economic Crime Bill key points for firms | JD Supra
Quicker and easier sharing of customer information relating to economic crime concerns between firms in the UK financial sector is being encouraged by provisions in the Economic Crime and Corporate Transparency Bill which is the final stages of its Parliamentary progress. We explore the key features of these new information sharing gateways. Current hurdles for firms wanting to share information Firms are currently unable to quickly share information with each other about economic crime concerns.
Judicial review challenge of the UK FCA by environmental charity - spotlight on disclosure risks | JD Supra
ClientEarth (an environmental charity) is challenging a decision by the UK Financial Conduct Authority (the FCA) to approve a prospectus of an energy company on the basis that it contains inadequate climate-related disclosures.
Supply chains and UK money laundering considerations | JD Supra
*Republished after last week's technical glitch*: A recent English court ruling has shed light on the approach of UK enforcement authorities to the question of money laundering risks where there is potential forced labour / modern slavery in a supply chain. The ruling will be of interest to companies that have identified these risks in their supply chains, when determining the potential regulatory consequences that flow from them.
FCA takes enforcement action against broker for market abuse identification and reporting failures – behind the headlines | JD Supra
January 9, 2023 To embed, copy and paste the code into your website or blog: Although, the FCA’s press release announcing its enforcement action against Sigma Broking Limited (Sigma) refers to “market abuse reporting failures”, some of the most interesting points in this case do not relate to the transaction reporting failures.
Cyber resilience: considerations for Boards | JD Supra
UK enforcement focus on operational resilience The FCA’s and PRA’s focus on operational resilience has been intensified by the current market and geo-political climate. Of particular concern is the increasing threat and impact of cyber attacks, as highlighted by the FCA’s Strategy for 2022-2025. Save for a GBP16.4 million fine imposed on a bank in 2018, the FCA has not brought enforcement action relating to cyber resilience issues.
Enforcement risks for firms unauthorised communication applications | JD Supra
With remote and hybrid working arrangements now the norm for many firms in the wake of the pandemic, risks of misconduct have become heightened by the increased use of unmonitored and/or encrypted communication applications to exchange business-related information. This area is the subject of ever-growing regulatory scrutiny, including by the UK Financial Conduct Authority (FCA).
Another Economic Crime Bill 2022 - anti-money laundering considerations for the regulated sector | JD Supra
As part of its crackdown on dirty money, the UK Government has published a second Economic Crime and Corporate Transparency Bill. The 250 page Bill covers a wide range of proposed reforms. This post focusses on the proposed changes to anti-money laundering (AML) practices, regulators’ powers and industry information-sharing that will directly impact firms in the financial sector.
UK Financial Conduct Authority enforcement insights | JD Supra
"Profound forces are reshaping financial services", according to the UK's Financial Conduct Authority (the FCA). In a recent speech, Nikhil Rathi, CEO of the FCA, echoes many of the future challenges and priorities set out in the FCA's Business Plan, this time sprinkled with some references to Kim Kardashian and Nicki Minaj. We consider here what the Business Plan and Rathi's speech might mean to firms from an enforcement perspective.
Disclosure of Suspicious Activity Reports (SARs) in civil litigation | JD Supra
The UK Government issued new guidance in July 2021 on how it considers companies and individuals should approach the question of disclosure of suspicious activity reports (SARs) in English civil litigation.
UK FCA extends annual financial crime reporting obligation (REP-CRIM) to more firms | JD Supra
The FCA is extending its existing annual financial crime reporting obligation (termed the “REP-CRIM” by the FCA) to a broader range of firm types. The change is expected to impact approximately 4500 firms who were previously not in scope. We take a look at what this means for the new firms in scope, and how they can draw some benefit from this new obligation.
Practical completion: Court of Appeal provides general guidance | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Failure to use reasonable endeavours: skating on thin ice | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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