Introduction

In R (on the application of KBR, Inc) (Appellant) v Director of the Serious Fraud Office (Respondent) [2021] UKSC 2¹ the Supreme Court held that the Serious Fraud Office ("SFO") may not compel a foreign company to produce documents held overseas under section 2(3) of the Criminal Justice Act 1987 ("CJA 1987").

The Supreme Court’s decision in Sevilleja v Marex Financial Ltd [2020] UKSC 31 of 15 July 2020 provided much needed clarity on the scope of the rule against “reflective loss”.

Today, the Financial Services Authority (FSA) published Final Notices for Christchurch Investment Management Limited (Christchurch) and the firm's compliance officer, David Thornberry, for breaches of the FSA's client money rules (CASS rules).