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Recent FCA financial crime enforcement actions
Posted: 09/05/2025
This article discusses the FCA's recent enforcement actions in respect of financial crime failings at Starling Bank and Metro Bank. These actions demonstrate the FCA's heightened scrutiny of firms' financial crime systems and controls, focusing on sanctions (in the case of Starling Bank) and the use of automated transaction monitoring system......>>
FCA updates its Financial Crime Guide
Posted: 09/05/2025
Financial crime remains a top priority for the Financial Conduct Authority (FCA), with a particular focus on sanctions in light of the ongoing geopolitical tensions with Russia. In order to strengthen firms' financial crime systems and controls, the FCA updated its Financial Crime Guide in November 2024, following a consultation. The sections of the......>>
High Court on appeal rejects novel 'retrieval duty' on a recipient bank
Posted: 03/04/2025
On 25 March 2025 the High Court handed down its judgment in the seminal case of Santander UK PLC v CCP Graduate School Ltd [2025] EWHC 667 (KB), which considered whether there is a tortious duty of retrieval on a recipient bank in relation to funds transferred as a result of fraud, when the victim of fraud is not a customer of that bank......>>
When Cupid’s arrow strikes – staying safe from the heartbreak of romance fraud
Posted: 13/02/2025
‘Beware the slings and arrows of outrageous fortune...’ Roman emperor Claudius II executed two men — both named Valentine — on 14 February in different years during the third century. In later years, Romans marked the feast of Lupercalia, between 13-15 February, with rituals that included animal sacrifices and (violent) ceremonies......>>
Top cybersecurity threats around Valentine’s Day (and how to manage the risk)
Posted: 12/02/2025
St Valentine is thought to have been a clergyman in the Roman Empire. According to legend, he signed a letter ‘from your Valentine’ to his jailer’s daughter, whom he had befriended and healed from blindness. Eventually, St Valentine would lose his head for his faith. Fast forward a thousand years, few would be aware of his brutal end......>>
The first digital gilt to use blockchain technology
Posted: 11/02/2025
On 14 November 2024, the Chancellor of the Exchequer announced in her Mansion House speech that the government will issue a digital gilt instrument, known as ‘DIGIT’. This pilot issuance will take place within the newly established Digital Securities Sandbox (DSS). These initiatives aim to allow the government to explore the benefits......>>
Love on(the)line: the darker side of AI
Posted: 11/02/2025
On 13 January 2025, Prime Minister Keir Starmer set out a blueprint to ‘turbocharge’ AI and unveiled details of the government’s AI Opportunities Action Plan. In a press release about the announcement, AI is heralded by the government as having the ability to ‘transform the lives of working people – it has the potential to speed......>>
Broken hearts - digital assets in insolvency: practical aspects for insolvency practitioners
Posted: 10/02/2025
Digital assets, including cryptocurrencies and non-fungible tokens (NFTs), have seen exponential growth. With the continued adoption and expanding personal ownership of digital assets, they will increasingly become a regular part of insolvency proceedings. This is true whether they are assets to be realised in the insolvency or if an insolvent......>>
Court breaks up representative action romance: Getty Images v Stability AI
Posted: 10/02/2025
The case of Getty Images (US) Inc and Ors v Stability AI Ltd [2025] EWHC 38 (Ch), which the team previously reported on (see here), continues to progress through the English High Court. Most recently, the claimants sought for Thomas M Barwick Inc, the sixth claimant, to act as a representative for a class of individuals in the claim. On 14 January......>>
The regulatory outlook – a period of transition
Posted: 17/01/2025
Over the coming year, the financial regulation team will be writing a series of articles on the future of financial regulation in the brave new world of Brexit, a Labour government, the Trump administration, and the imperative for growth. This first article will look at the various tensions within the HR aspect of financial regulation......>>

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