
Extending Moratorium Periods
We have a proven track record of challenging applications for moratorium periods and advising on the legal and practical ramifications of doing so
The Suspicious Activity Report (SAR) regime obliges both those working inside and outside the regulated financial sector – so all financial institutions, as well as solicitors, accountants and estate agents, for example – to report any suspicion of money laundering activity to the National Crime Agency (NCA).
If the NCA refuses consent for a transaction to proceed, a moratorium period of 31 days is triggered during which the transaction is prohibited and any property involved, including bank accounts, is frozen. The initial 31-day period may be extended on application by up to six months while the issues disclosed in the SAR are investigated.
We advise individuals and businesses subject to moratorium periods, which often cause significant financial difficulties and reputational risk and which, if left unchallenged, may potentially pave the way for further investigations, restraint or asset freezing orders.
Where we can help
Our Criminal Litigation Team
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