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AFB Practice Roundtable: How to Manage De-Banking Processes

This in-person practice roundtable is an opportunity for members to discuss and share their approach on the management of de-banking processes. In the wake of the Farage/Coutts review, there is renewed interest and discussion regarding de-banking decisions and practices.

The discussion will explore how to navigate issues such as: the filing of Suspicious Activity Reports; tipping off risk under the Proceeds of Crime Act (POCA) and the handling of associated Data Subject Access Requests as well as contractual considerations, including the liquidation of illiquid or non-transferable assets in custody.  

Members will also be invited to discuss how their approach aligns with their organisation’s financial crime compliance framework, including their risk assessments.

The session will be hosted and facilitated by members of the Contentious Financial Services team at Ashurst LLP.

AFB will circulate an agenda and a series of questions to attendees in advance which will be used to aid discussions. The Chatham House Rule will apply to this event to encourage open dialogue and discussion.

This roundtable is limited to 35 places and one person per member bank. We recommend booking early to secure your place.

Who should attend?

This in-person roundtable is aimed at representatives from the Legal, Compliance, Risk and Business functions.

What will members gain for use?

  • An understanding of the legal and reputational challenges of de-banking
  • Practical steps that can be taken by financial services firms

Facilitators

Philip Linton, Partner

Philip joined Ashurst after 12 years at Goldman Sachs, where he was a Managing Director and led the firm’s EMEA Litigation and Contentious Regulatory team. 

Philip has vast experience, across industry sectors, asset classes and geographies, in managing and advising on disputes, internal and regulatory investigations and related enforcement proceedings.

Neil Donovan, Senior Associate

Neil specialises in global criminal and regulatory investigations. Neil acts for financial institutions and corporates across a range of sectors. He has acted for clients on internal and external, multi-jurisdictional investigations related to allegations of bribery and corruption, money laundering, tax evasion, and accounting fraud. A key part of Neil’s practice is advising clients on the application of the UK sanctions and anti-money laundering regimes.

Matthew Russell, Partner

Matt is a recognised financial crime risk and compliance leader who has extensive advisory and industry experience in the assessment, design and implementation of systems and controls for managing the full spectrum of clients’ financial crime risks: money laundering, fraud, bribery and corruption, sanctions compliance, market abuse and tax evasion.

Adam Jamieson, Partner

Adam specialises in advising financial services firms, listed companies and senior individuals involved in internal and regulatory investigations. He has significant experience of representing clients in regulatory enforcement investigations conducted by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA).

Adam previously spent a year on secondment to the FCA’s Enforcement & Market Oversight Division. During his time at the FCA, Adam worked as an investigator on FCA and PRA investigations into both firms and individuals.

Logistics

Cost:        Included in AFB membership (no fee)

Location:  Ashurst LLP, London Fruit & Wool Exchange, 1 Duval Square, London, E1 6PW

Date:        Wednesday 6 March 2024

Time:        15:30 – 17:30 (Arrivals and networking 15:30 – 16:00)

There will be ample opportunity for questions throughout the session, however, if you would like to submit a question before or have any specific questions or areas that you would like the session to address, please send them to the AFB at secretariat@foreignbanks.org.uk as soon as practicable. You will receive details on attending the session a week before the event.