The FCA has recently launched consultation CP15/18 which sets out their proposed regulatory structure for Claims Management Companies (CMCs). The announcement also confirmed that jurisdiction for complaints would move from the LeO to the Financial Ombudsman Service (FOS); although one wonders how they will cope with an increased number…
So what DO I have to provide when I receive a subject access request?
With conflicting advice still available on the ICO website there seems to be a lot of confusion around exactly what a data subject is entitled to when they exercise their right of access under GDPR. Many data subjects still seem to think that this right entitles them to…
The Human Cost of Money Laundering – Part One
It is very easy to silo oneself when immersed in the world of investigating money laundering and to forget that actually it isn’t just about currency, commodities and hidden profits, but it’s about people. I have investigated a plethora of cases during my career and the focus is…
So what happens on May 26th?
25th May…. It’s the date we have all been working towards, some of us for many months. But what happens on 26th May, and the day after that? Well, initially we all have a well-deserved rest over a bank holiday weekend, and then it’s business as usual from Tuesday…
Technology for compliance
At the recent Teal Annual Conference, I spoke to the delegates about Technology in Compliance. I’d like to pose some of the questions we talked about during the session. How would your firm answer? How do your current systems and processes work for you? As a firm, are…
14 day countdown to GDPR
With just 14 working days to go until GDPR implementation day, what should you be focusing on? At our conference on 26th April, 57% of those attending said they had nearly completed all of the changes they needed to make in advance of 25th May, 4% stated that…
GDPR: Some practical tips for barristers
I recently presented at a GDPR and Cybercrime training session for a wonderful group of Fee Earners, who are members of a Barristers Chambers. During training I was asked some very interesting questions and as a group these issues were openly discussed. I was so impressed with the healthy discussions, I thought I…
AML v KYC v CDD FYI
Call me pedantic, but I like precision when I’m talking about compliance. Don’t get me started on 5MLD (which does not currently exist!). Yesterday I was invited to speak at the Internet of Agreements conference on Identity. I was giving the legal perspective, specifically around AML/KYC. The…
Bribery Act: do you have ‘adequate procedures’?
Understanding and complying with ‘adequate procedures’ as detailed in the Bribery Act legislation, was highlighted in the recent conviction of London-based Skansen Interiors Limited in March 2018. It is the first time a UK Jury has had to consider what “adequate procedures” should be for the purpose of a defence…
Do I need consent for direct marketing?
With less than 50 working days until GDPR takes effect on 25th May 2018, many businesses are starting to consider the ‘hot topic’ of whether their marketing lists will still be valid. But it’s not just GDPR that needs to be considered…… Current Rules (up until 25th May 2018)…