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The first UWO shows that all firms must get their anti-financial crime arrangements in order

The BBC reported at the end of last week that more than £400,000 of jewellery has been seized from Christies auction house by the National Crime Agency (NCA). This was connected to the NCA pursuing its Unexplained Wealth Order (UWO) issued against Zamira Hajiyeva, about which I have been commenting recently.

The items that were seized from Christies were reportedly being valued for Mrs Hajiyeva's daughter. 

This is an interesting update on the progress of the first UWO in the UK. However it is also a salutary lesson that, in the UK's rapidly evolving anti-financial crime landscape, businesses may be affected in a myriad of different and unexpected ways. 

Potentially illicit wealth or assets might reach unsuspecting firms or the activities of the authorities may affect the conduct of your business. 

All firms (even those not in the regulated sector) should therefore be sure to have their anti-financial crime arrangements in order to help guard against these potential risks - from private schools and auction houses to international banks. 

This really goes to show quite what a range of businesses can be potentially be exposed to allegedly illicit assets... We often hear about estate agents and banks, but anyone involved in the sale of high value goods, luxury cars, even private education, face the same risks.


unexplained wealth order, money laundering, financial crime, financial regulation, corporate crime, litigation

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