The UK's Criminal Finances Bill: A Comparison to the US Approach

Financial institutions should have a strong compliance program to address new provisions

By: Ellen Zimiles, Alex Shea, Rachel Sazanowicz

The UK is moving to increase its power to investigate and prosecute money laundering, terrorist financing, and tax evasion. In this effort, the UK Criminal Finances Bill (the “UK Bill”) is a draft bill currently before the UK Parliament that will amend the Proceeds of Crime Act of 2002 and the Terrorism Act 2000. Specifically, the UK Bill contains provisions that fall under four broad objectives identified by the UK:

  1. Improve the capability to recover the proceeds of crime
  2. Transform the relationship between the public and private sector
  3. Enhance the UK law enforcement response
  4. Combat the financing of terrorism

The UK approach to these issues is in many ways very different from the U.S. approach. It is therefore paramount that financial institutions take the necessary steps to prepare for the UK Bill’s new provisions. The following paper describes the provisions that meet the four objectives noted above and compares them to similar initiatives in the U.S.

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