Issue link: https://digital.shearman.com/i/1389983
31 human rights violations. The U.K. Foreign Secretary, Dominic Rabb—a key supporter of such sanctions— believes that their introduction is "a demonstration of Global Britain's commitment to acting as a force for good in the world." These moves provide a clear indication of how the U.K. intends to use its autonomous sanctions regime following its withdrawal from the European Union. REVIEW OF CORPORATE CRIMINAL LIABILITY On 3 November 2020, the U.K. Government published its long-awaited response to its Call for Evidence on options for reforming corporate liability for economic crime. It noted there may be scope for legislative change, but the Call for Evidence did not provide "a sufficient evidence base…to make immediate legislative change to the criminal law in relation to economic crime." The U.K. Government has asked the Law Commission to prepare an Options Paper setting out how effective the law is and where it can be improved. It has been asked specifically to carry out a detailed review of the "identification doctrine"—the principle that a corporate body can only be held liable for the acts or omissions of individuals if they represent its "directing mind and will" (absent an express statutory provision to the contrary). It may also consider other options, such as a new form of vicarious liability similar to the U.S. model or further "failure to prevent" offences, similar to section 7 of the Bribery Act 2010. The Law Commission is currently seeking views as part of a consultation exercise that is due to end on August 31, 2021. When launching the consultation last month, Professor Penney Lewis – the Criminal Law Commissioner – stated: [T]here is concern that the law on corporate criminal liability does not always appropriately criminalise corporate misbehaviour, especially when applied to large corporations. At the same time, it is important to ensure that any reform does not impose an undue burden of compliance on companies. The Options Paper is not due to be published until towards the end of the year, so any legislative change is some way off, but these developments are significant and may lead to a redefining of corporate criminal liability in the U.K. IDENTITIES OF ALLEGED AZERBAIJANI MONEY LAUNDERERS REVEALED In June 2021, the High Court lifted an anonymity order that had prevented the naming of a couple accused of funneling £14 million through the U.K. The activities of Izzat Khanim Javadova, the cousin of Azerbaijan's president, and her husband Suleyman Javadov, the son of a former minister, were investigated by the National Crime Agency (NCA) and both became the subject of several account freezing orders in 2018. The NCA alleges that the pair received the proceeds of "corruption, theft or embezzlement" between 2007 and 2018, and now seeks the forfeiture of the frozen funds in proceedings before the City of Westminster Magistrates' Court. This case highlights the growing trend of U.K. authorities seeking to secure assets held in the U.K. that are believed to have been obtained, at least in part, through foreign criminality, particularly bribery and corruption. It also demonstrates a growing willingness to use alternative tools to prosecution to tackle serious wrongdoing.