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Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Francesca Titus

Photo of Francesca Titus Francesca represents companies and individuals in complex, high value, multi-jurisdictional white collar crime litigation. An experienced barrister, she has defended clients in over one hundred jury trials, and appeared as advocate in the Court of Appeal (Criminal Division). Francesca advises business leaders at times of crisis when they are caught up in high profile investigations or prosecutions conducted by the Serious Fraud Office, Her Majesty’s Revenue and Customs, the Financial Conduct Authority, the National Crime Agency or the Crown Prosecution Service.

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New Revelations in Ukraine Lead to Tightening Global Sanctions

By Alex J. Brackett, Edwin O. Childs, Patrick Rowan, Elissa Baur, Laura Colombell Marshall, Jason H. Cowley and Francesca Titus on Enforcement and Prosecution Policy and Trends, Sanctions, Trade Embargo, and Export Controls
RELATED UPDATE: FinCEN Alert Highlights Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites and Their Proxies (January 30, 2023) As the world watched in horror over the atrocities occurring in the war zones of Ukraine this week, global leaders re-doubled their efforts to bring increasing sanctions pressure to bear on Russian industry, the… Continue Reading

The Perils of Global Expansion: World’s Largest Ad Agency Sanctioned $19 Million for FCPA Violations, Insufficient Controls

By Alex J. Brackett, Francesca Titus, Patrick Rowan, E. Andrew Southerling and McGuireWoods LLP on Anti-Bribery and Corruption, Sanctions, Trade Embargo, and Export Controls, Securities and Commodities
Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange Commission (SEC) to resolve alleged violations of the Foreign Corrupt Practices Act (FCPA). According to an SEC order memorializing the settlement, WPP’s trouble began when… Continue Reading

Taxpayer Protection Taskforce Aims to Recover £1 billion from Business

By Francesca Titus and Katie Steven on Financial Institution Regulation
This alert is a continuation from a March 3, 2021 post. On 3rd March 2021, UK Chancellor Rishi Sunak announced a £100 million Taxpayer Protection Taskforce (Taskforce) to scrutinise claims made under Government financial business support schemes designed to help companies and individuals navigate their way through the economic impact of the COVID-19 pandemic.… Continue Reading

Budget Launches Taskforce to Uncover Exploitation of the UK Government’s COVID-19 Financial Rescue Schemes

By Francesca Titus, Chloe S. Steele, Alice O'Donovan and Rend Alani on Financial Institution Regulation
In today’s budget, UK Chancellor Rishi Sunak announced a £100 million Taskforce to scrutinise claims made under business support schemes designed to help companies and workers navigate their way through the economic impact of the COVID-19 pandemic. The Taxpayer Protection Taskforce will be examining claims made honestly but in error as well as those made… Continue Reading

With Fraud Against UK Businesses at Epidemic Levels, Businesses Need to Know How to Protect Themselves

By Francesca Titus, Chloe S. Steele and Alice O'Donovan on Fraud, Deception and False Claims
Fraud has reached epidemic levels in the UK and should be seen as a national security issue, says think tank the Royal United Services Institute (RUSI) in a paper published last week[1]. It is the crime to which UK citizens are most likely to fall victim[2]. Its impact on the private sector has consequences for… Continue Reading

The Brexit Deal; UK Crime Fighting with European Friends

By Francesca Titus on Anti-Money Laundering, Enforcement and Prosecution Policy and Trends
Since Brexit, the relationship between the European Union (EU) and the UK concerning law enforcement cooperation is now governed by the UK-EU Trade and Cooperation Agreement (the Agreement). The UK Government state that the safety and security of British citizens is a top priority.  It argues that the Agreement provides a comprehensive package of operational… Continue Reading

FCA Bans Three People From Working in Financial Services Industry, for Non-Financial Misconduct

By Francesca Titus and Alice O'Donovan on Enforcement and Prosecution Policy and Trends, Financial Institution Regulation
On 5 November, the Financial Conduct Authority, the UK’s financial services regulator, permanently banned three men convicted of non-financial criminal offences from ever working in the financial services industry, on the basis that they do not meet criteria defining a fit and proper person. For details about this latest development and implications for the industry,… Continue Reading

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