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ARTICLE · 23 JULY 2024

Pulling At The Thread – New Judgment Confirms Supply Chain Risk For Companies

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The Court of Appeal's recent judgment in R (oao World Uyghur Congress) v NCA [2024] EWCA Civ 715 clarifies UK's Proceeds of Crime Act 2002 (POCA), highlighting risks for businesses. It mandates vigilance against inadvertent involvement in money laundering via supply chains, impacting sectors from textiles to finance, urging enhanced compliance and risk mitigation efforts.

United KingdomCriminal Law
Lorna Emson
Lorna Emson
Max Hobbs
Max Hobbs
Helen Harvey
Helen Harvey

At the end of June, the Court of Appeal handed down judgment in the case of R (oao World Uyghur Congress) v NCA [2024] EWCA Civ 715.

The Court of Appeal has clarified the operation of certain parts of the UK's Proceeds of Crime Act 2002 (POCA) and the approach the UK authorities should take to money laundering investigations. The judgment is important for a number of reasons.

  • Many businesses may face a new or heightened risk of prosecution for criminality in their supply chain and related money laundering offences. This could arise in unexpected ways. Companies such as clothing manufacturers, furniture makers or food suppliers may be impacted, as could investment firms, banks and commodity traders that are exposed, directly or indirectly, to the proceeds of crime.

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