Investigations & Dawn Raids

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Recent Articles

    United Kingdom

    HM­RC re­verse po­s­i­tion on col­lect­ing cus­tom­er IP data from fin­an­cial in­sti­tu­tions

    On 26 January 2023, the first report on HMRC’s use of financial institution notices (“FINs”) was laid before Parliament. The report includes a number of important updates, including an unexpected retreat on HMRC’s proposal, previously undisclosed, to use FINs to collect data held by financial institutions on where customers have accessed their online or mobile accounts (i.e., their geographical location by reference to an IP address, “Location Data”). The CMS Tax Disputes & Investigations team has been advising representatives of the UK banking and financial...
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    Czech Republic

    Cor­por­ate crim­in­al li­ab­il­ity in the Czech Re­pub­lic

    The Czech Act on Criminal Liability of Legal Entities and Proceedings Against Them covers criminal liability of legal entities in their own specific way. Corporate criminal liability applies to nearly all legal entities and to those inpiduals who work for them. Directors, management board members and employees place themselves and the companies in a high-risk situation if they are unaware of how their companies might be affected by the Act and what can be done to relieve the legal entity of criminal liability. Even though the Act came into force eleven years ago, many businesses either still don’t...
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    Changes made to Pol­ish sanc­tions re­gime

    On 5 August 2022, Poland passed a law that amends the Act on Special Solutions to Counteract Support for Aggression against Ukraine and to Protect National Security and the Act on the National Fiscal Administration (“Amendment”)[1], which introduces changes to the Polish sanctions regime[2]. The subject matter of this Amendment consists primarily of the following two regulations that may be applicable to an entity on which restrictive measures (i.e. sanctions), in the form of freezing funds and economic resources and the prohibition on making them available, have been imposed: (i) the...
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    England and Wales

    Rus­sia sanc­tions up­date: UK bans new in­vest­ment in­to Rus­sia

    New UK sanctions regulations have come into force imposing the most rigorous restriction on doing business with Russia since the invasion of Ukraine on 24 February 2022. The twelfth amendment to the Russia (Sanctions) (EU Exit) Regulations 2019 aims to “close off revenue streams that the Russian government could leverage” in order to “deepen…sanctions measures” and encourage Russia to “respect international law and the territorial integrity of sovereign nations”. It is now a criminal offence, imprisonable by a maximum term of seven years, for a UK citizen...
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    Reg­u­la­tion on for­eign sub­sidies is head­ing for the fin­ish line - European com­pan­ies need to be pre­pared

    Since 5 May 2022, EU trilogue negotiations have been underway on the first Regulation to limit the effect of subsidies from third countries to companies active in the EU. That an agreement will be reached can be considered a certainty. The Regulation could be applicable as early as the first half of 2023. The three new tools envisaged by the Regulation also mean new compliance burdens for many European companies. This article presents the most important amendments to the Commission's draft proposed by the European Parliament and the Council in the trilogue. First Regulation of its kind Existing...
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    South Africa

    Cor­rup­tion Per­cep­tions In­dex: how SA’s po­s­i­tion could be im­proved

    Most South Africans have come to terms with the idea that corruption in the country is endemic. There are few days that go by when there isn’t a headline about some form of malfeasance in both the public and private sectors. And while the Zondo Commission laid bare how entrenched corruption really is, few South Africans were truly shocked by the revelations. As if to underline how used to corruption the country’s people have become, the general sentiment in the wake of the recent floods that devastated KwaZulu-Natal was resigned acceptance that government officials would plunder relief...
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