Cross-border information-sharing – insubstantial guidance for UK corporates

Josef Rybacki (+44 (0)20 7872 1517, josef.rybacki@wilmerhale.com) is an associate in WilmerHale’s UK White Collar Defence and Investigations team.

On 12 May 2020, the UK belatedly published its statement on cross-border information-sharing within corporate groups. The one-page document primarily consists of general acknowledgements of the importance of this subject and restatements of the existing law. As a practical tool, says Josef Rybacki of WilmerHale, it is something of a damp squib; however, it does contain some limited guidance that may be of assistance to corporates when considering information-transfers between UK and non-UK subsidiaries, particularly relating to Suspicious Activity Reports (SARs).