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CybersecurityFeaturesInternational LawWhite Collar CrimeTechnology Media and TelecomCybersecurity Law & Strategy

Update on UK Sanctions, Anti-Money Laundering and Brexit

By André Bywater and Jonathan Armstrong

While it is typically more likely that cybersecurity issues are handled as a separate compliance function within an organization to the anti-money laundering and sanctions function(s), the cybersecurity function should not act within a vacuum; all of these functions ultimately also have the similar goal of protecting system integrity.

For example, in a given set of circumstances in the event of a cybersecurity incident affecting a financial institution, a regulator will likely need to be satisfied that the sanctions and anti-money laundering teams have robust knowledge, capacity, experience and training in dealing with cybersecurity issues. The respective cybersecurity, sanctions and anti-money laundering teams therefore need to work together, including as regards the teams providing each other practical skills and knowledge.

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