Financial crime and fraud have long been at the top of regulators' agendas and are a particular focus in Europe in the context of COVID-19. Both have also been the subject of increasing numbers of civil and criminal court cases over recent years.
Whilst certain obligations on firms have been relaxed to take into account the pressures on firms dealing with the pandemic, regulators have repeatedly reinforced that firms' obligations in relation to the prevention and detection of financial crime remain. There is an understanding that the 'new normal' may have afforded criminals new opportunities to perpetrate scams and launder money; it was reported in August that the Financial Conduct Authority (FCA) in the UK was already investigating 165 suspected COVID-19 related scams.
This article contains updates on recent court judgments and activity by financial services regulators, and prosecutors, to tackle financial crime and fraud in three jurisdictions; the UK, Germany and Spain.
We will continue to publish updates quarterly. In the meantime, if you have any questions, please get in touch with the relevant contact below.