In June 2019, the Law Commission published a report which examined the effectiveness of the SARs regime in a number of areas.
One area of focus was the extra-territorial effect of the UK’s money laundering law, in particular in relation to lawful conduct overseas. The Report noted that “There has always been complexity under money laundering law where dealings involve conduct illegal in the UK, but not unlawful under the criminal law of a foreign jurisdiction. These “Spanish bullfighter” issues (a shorthand for these type of concerns referring to the case of a Spanish matador spending his or her income in the UK), have become more pressing with the growth of the legal cannabis industry”.
The Report referenced Thomas Daniel’s article on the 2 Bedford Row website from November 2018 which predicted the issues which may be caused to UK investors wishing to invest in the growing cannabis industry in Canada.
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