Bribery Act: do you have 'adequate procedures'?

Understanding and complying with ‘adequate procedures’ as detailed in the Bribery Act legislation, was highlighted in the recent conviction of London-based Skansen Interiors Limited in March 2018. It is the first time a UK Jury has had to consider what "adequate procedures" should be for the purpose of a defence to the corporate offence of ‘failing to prevent bribery’ under the UK Bribery Act 2010. The CPS brought proceedings against the Skansen (now dormant) and its senior executive Stephen Banks, Managing Director at the time. The prosecution claimed Mr Banks had bribed a project manager at a property company to secure a £6 million refurbishment contract. Mr Banks pleaded guilty to three

Do I need consent for direct marketing?

With less than 50 working days until GDPR takes effect on 25th May 2018, many businesses are starting to consider the ‘hot topic’ of whether their marketing lists will still be valid. But it’s not just GDPR that needs to be considered…… Current Rules (up until 25th May 2018) Data Protection Act 1998 (DPA98) Privacy and Electronic Communications Regulations 2003 (PECR) After 25th May 2018 General Data Protection Regulation (GDPR) Privacy and Electronic Communications Regulations 2003 (PECR) BUT only until the Regulation on E-Privacy and Electronic Communications (the E-Privacy Regulation) comes into force General Principles Under DPA98 “An individual is entitled at any time by notice in writ

Communication, communication, communication.

The legal industry can be a mixture of things, both good and not so good. People tend to focus on the things that drive them, whether it’s the bottom line of fee income, helping clients or having to make what some people may see as ruthless decisions for the success of the business. However, I also see leaders in firms who consider people as their biggest asset, whether that is their staff, suppliers or their clients, and who lead by example and deal with making decisions in an ethical way. There will always be occasions where decision makers in a firm and managers/supervisors must deliver difficult news. It is often the case that is not the news itself that can leave individuals disappo

Conference time - full agenda now released

The Teal Compliance and Lockton Conference 2018 takes place on the 26th April 2018 in London. With so much change afoot in the world of compliance, the theme for this year's conference is 'Navigating a year of change'. As a team we have all been working hard to pull together an agenda which covers all the key updates and provides perspectives from industry experts on practical application of the changes to regulations - from AML to GDRP to Code of Conduct. The full agenda has now been released and you can read about it here In addition the whole of the Teal Team will be available throughout the the day and many of our associates will be leading speaking session, alongside high profile exter

Do we need to "change up" AML Training?

I have been training in AML for 13 years. I love it, I love spreading the word, helping staff in law firms understand the risks they face, and what to look out for to try and identify someone trying to use them to launder money. Sopranos, The Wire, Breaking Bad and McMafia have all played a part in raising the awareness of how the baddies launder money, but we need to make sure that the training is relevant to lawyers, and their staff. I’ve trained countless numbers of MLROs in those 13 years. I’ve never met any who did not accept and appreciate the need to have their firm understand the anti money laundering legislation and how to apply it in their firm. That said, I have been talking about

The Data Protection Bill - What do I need to know?

The draft Data Protection Bill [HL] 2017-19 will get it’s second reading in the House of Commons today, Monday 5th March 2018, moving one step closer to receiving Royal Assent. In preparation for the second reading, the House of Commons issued a 60-page briefing paper which includes a summary of the Bill and the House of Lords debates[1]. In May 2018, as we all know, there will be some changes to the EU’s data protection framework – the General Data Protection Regulation (GDPR) will apply from 25th May and as it is a Regulation it does not need to be transposed into domestic law. But prior to that, the Police and Criminal Justice Directive, also known as the Law Enforcement Directive (LED)

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