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Anita Clifford

Latest news & updates from Bright Line Law.

Failure to Prevent: Corporate Liability at the Cost of Individual Due Process?

Speed Read: This piece explores whether the failure to prevent model at the heart of the new offence of corporate failure to prevent facilitation of tax evasion contains a due process deficit. Introduction The new corporate offence of failure to prevent the facilitation of tax evasion reflects a wider...
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Reach, Risk and Record Sharing: Money Laundering Regulations 2017

Speed Read: Public consultation on the proposed new draft Money Laundering Regulations 2017 (“MLR 2017”) closed on 12 April 2017.  The government must now move swiftly with any amendments if it is to achieve compliance with the deadline of 26 June 2017 for the transposition of the EU Fourth...
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The Investigative Reach of Unexplained Wealth Orders: Exploring Derivative Use

Speed read: Unexplained Wealth Orders (“UWOs”) have the potential to play a large role in an investigation, without any qualifications on the use of the explanation beyond the self-incrimination privilege. Anita Clifford explores the potential for derivative use of the explanation provided in compliance with a UWO and prompts...
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Gross Human Rights Abuse and Property Forfeiture in the UK

Speed read: The Criminal Finances Bill 2016 is set to be passed in Spring 2017.  Clause 12 proposes to expand the definition of “unlawful conduct” appearing in Part 5 of the Proceeds of Crime Act 2002 to include gross abuse of human rights.  Bright Line Law was instructed by...
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Food crime on the enforcement menu

Speed read: Anita Clifford discusses the emerging focus on ‘food crime’ by law enforcement agencies in the UK and elsewhere, and scope for developing the criminal law response to wrongdoing in the food and drink industry. On 1 December 2016, the first Food Crime Reporting Hotline was launched in...
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The White Collar Centre