ABSTRACT
Building on the government’s 2016 Action Plan for Anti-Money Laundering and Counter-Terrorist Finance which earmarked the creation of ‘aggressive new legal powers’ and ‘new capabilities’ for law enforcement to enable the ‘relentless disruption of criminals and terrorists’ as a major priority, the Act was passed on 27 April 2017 with overwhelming bipartisan support. The information-sharing framework introduced by the Criminal Finances Act 2017 is a continuation of the trend towards public/private partnerships in the fight against money laundering and terrorist financing. Two new corporate offences largely modelled on the corporate criminal liability provisions in the Bribery Act 2010 are also in force by virtue of Part 3 of the Act. Prior to the Criminal Finances Act 2017, the period in which no further action on a transaction could be taken after a suspicious activity report was submitted was 31 days after the National Crime Agency’s consent was withheld.
