FCA makes foray into use of freezing orders

Suspicious activity by a fintech start-uphas prompted the Financial Conduct Authority to bring urgent court proceedingsagainst seven bank accounts held by QPay Europe, securing £2 million of allegedcriminal proceeds. Jonah Anderson and Lucy Rogers examine the useof account freezing orders and account forfeiture orders by the FCA and other UKauthorities.

Jonah Anderson is a partner at White andCase who advises on sensitive financial crime issues, while Lucy Rogersis an associate with experience advising large corporates, financial servicesfirms and individuals on regulatory and criminal enforcement matters. Contact themon jonah.anderson@whitecase.com and lucy.rogers@whitecase.com.

In January 2018, United Kingdom lawenforcement agencies were granted new powers to pursue the forfeiture ofassets. [1] Unexplained wealth orders (UWOs)initially grabbed the media’s attention, but the relative ease with which UKlaw enforcement can seek and obtain an account freezing order (AFrO) or an account forfeiture order (AFO) means that they are used moreoften than UWOs in practice.