economic sanctions and financial crime_598x17_s
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Economic Sanctions & Financial Crime
5th Advanced Forum on
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctions
Lead Sponsor Associate Sponsor Executive Sponsor Session Sponsors
The premier legal, enforcement and regulatory compliance event
500+ market leaders and policy makers have taken part since inception
90+ leading financial institutions expected to attend this year
20+ outstanding industry speakers
3 senior Government speakers confirmed
15-16 November, 2016 | Le Méridien Piccadilly Hotel, London, UK
David McLean, Deputy Head OFSI, HM Treasury
Jamie Rose, Deputy Chief, Regulated Industries Oversight & Evaluation
Sanctions, Compliance & EvaluationOffice of Foreign Assets Control (OFAC)
U.S. Treasury Department
Maud Bökkerink, Financial Supervisor AML/CFT, Integrity
De Nederlandsche Bank
Up to18.3 CPD
This year marks 30 years since the inception of C5 Group. It is time to match our brand with the dynamic strides we have made.
See inside for details…C5Business Information in a Global Context
a C5 Group CompanyBusiness Information in a Global Context
7+ hours of networking opportunities
2 highly practical workshops
ONE unmissable event
Dear Colleague,
Truly seismic changes are hitting compliance and legal professionals right now, including:
Brexit
Diverging US and EU sanctions against Iran
The Role, Powers and Priorities of the Newly Created OFSI
Tough US-style enforcement in UK
BUT ARE YOUR SANCTIONS RISKS PROPERLY UNDERSTOOD, ASSESSED AND MINIMISED?
Join C5’s 5th Annual “Economic Sanctions and Financial Crime” forum and get an Immediate Compliance and Enforcement Action Plan covering:
Critical changes in enforcement and asset freezing measures:New UK sanctions regimeNew global enforcement prioritiesDPAs vs civil sanctions
Managing Iran sanction relief: Restrictions still in place: Who do these apply to? What are the penalties?Impact on insurance & reinsurance industry
Thought leaders’ views on capturing new compliance risks: Ultimate beneficial ownership: Reinforcing screening and due diligenceSanctions-related liability in M&A dealsBeneficial ownership disclosure
Benchmarking internal processes: Robust, cost-effective monitoring People – processes – software: Coherent deploymentMinimising false positivesInternal investigations
AML & financial crime:Trade finance Cyber sanctions Offshore finance
Make the most of your attendance and take part in practical Workshops on 17th of November:
A Complete Guide on Mitigating Compliance Risks Related to Iran Sanctions Post-Implementation Day
Your Step-by-Step Guidance on Listing and De-listing on Targeted Sanctions in the UN, EU and US
Make sure you gain advantage by getting the latest thinking and strategic direction from the best in the business, and join sanctions and financial crime prevention experts who make this event a priority in their annual calendar.
We look forward to welcoming you at the forum.
Anita ArthurIndustry ManagerC5 Communications
+44 20 7878 6925 | [email protected]
EXCEPTIONAL LINE UP OF SPEAKERS INCLUDING:
David McLean Deputy Head OFSI, HM Treasury
Jamie Rose Deputy Chief, Regulated Industries Oversight & Evaluation Sanctions, Compliance & Evaluation Office of Foreign Assets Control (OFAC) U.S. Treasury Department
Aga Polcyn Financial Crime Counsel Morgan Stanley
Sophie van Til Leedham Head of Financial Crimes Group AIG EMEA
Maud Bökkerink Financial Supervisor AML/CFT, Integrity De Nederlandsche Bank
Haydn Main Head of Legal Renaissance Capital
Nathalie von Taaffe EMEA Head of Anti-Corruption & Sanctions Credit Suisse
Susan Leddy Head of Financial Crime Risk Group Operations, Director Legal & Compliance Swiss Re
Dirk Wegener Vice President FERMA
Marie Bolton-Jones Group Director of Financial Crime Willis Towers Watson
Karen Walter Director, Head of Economic Sanctions Unit, Group Legal & Compliance Allianz Group
David Marshall Head of Compliance NIBC N.V. London Branch
Simon Wilkin Head of Financial Crime Group SMBC Europe Limited
Fintan Byrne Head of Risk & Chief Compliance Officer CurrencyFair
Richard Wall Senior Manager, AML Governance Officer BMO Global Asset Management EMEA
Richard Ferris Chief Counsel Aon Risk EMEA
Chiawen Kiew Principal Investigations Manager, Office of the Chief Compliance Officer EBRD
Ali Rathod-Papier Legal Counsel, Group Financial Crime Legal Barclays Bank PLC
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctionsa C5 Group Company
Business Information in a Global Context
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctionsa C5 Group Company
Business Information in a Global Context
Economic Sanctions & Financial Crime 15-16 November, 2016 | Le Méridien Piccadilly Hotel
08.00 Registration, Refreshments and Networking
09.00 Opening Remarks from the Chair
Aga Polcyn Financial Crime Counsel Morgan Stanley (UK)
09.15 OPENING KEYNOTE and Q&A Toughening the UK’s Sanctions Enforcement Regime and What it Means for Financial Institutions
David McLean Deputy Head and Head of Compliance and Operations OFSI, Office of Financial Sanctions Implementation, HM Treasury (UK)
Key changes to the UK’s sanctions regime under proposed Policing & Crime Bill
Increasing and harmonising criminal penalties for non-compliance: OFSI’s enforcement tools
Alternative enforcement tools:
- Deferred Prosecution Agreements (DPAs)
- Serious Crime Prevention Orders (SCPOs)
- New monetary penalties regime
Q&A
10.00 “A Year in Review”: In Conversation with the Regulators on Global Priorities
Speakers include: Maud Bökkerink Financial Supervisor AML/CFT, Integrity De Nederlandsche Bank/Dutch Central Bank (Netherlands)
Key investigations, major enforcement actions and settlements related to Iran, Russia, Sudan, Cuba, Myanmar and North Korea
How do governments monitor compliance with sanctions? What types of offences and violations can trigger an investigation?
- What US banks are and aren’t able to do with these jurisdictions in general?
- What foreign subsidiaries of US banks can and can’t do in these jurisdictions
- When can banks be held liable in connection with their clients’ transactions?
How to mitigate the risk of further penalties
Where is the sanctions regulatory agenda heading next: top priorities for 2017 and beyond
Q&A
10.45 Refreshments and Networking
11.15 The Latest Legal Developments in Sanctions Law, Including the Impact of Brexit
Maya Lester QC Barrister Brick Court Chambers (UK)
Recent updates on case law of the European courts on sanctions
Legal issues arising out of Brexit
11.45 Strengthening Sanctions Compliance Programme to Capture New Risks and Prepare for What may Lie Ahead
Discussion Leader Aga Polcyn
Financial Crime Counsel Morgan Stanley (UK)
Speakers include: Eric R. McClafferty Partner Kelley Drye & Warren LLP (USA)
Haydn Main Head of Legal Renaissance Capital (UK)
Nathalie von Taaffe EMEA Head of Anti-Corruption & Sanctions Credit Suisse (UK)
What do financial institutions see as the next set of sanctions compliance challenges
What internal compliance procedures must be put in place to respond to an increased focus on enforcement and limit exposure:
- Ensuring senior management engagement
- Monitoring key local and international law obligations
- Setting up training
What forms of protection should be included into contracts and transaction documents to cover current and/or future sanctions?
Developing a robust and well-run sanctions violation-incident response plan and handling reputational damage once you’ve been subject to a high profile fine
Steps to monitor and anticipate possible future sanctions
FORUM DAY ONE: TUESDAY, 15 NOVEMBER 2016
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctionsa C5 Group Company
Business Information in a Global Context
Economic Sanctions & Financial Crime 15-16 November, 2016 | Le Méridien Piccadilly Hotel
13.00 Networking Luncheon
14.00 Iran: Dismantling Punitive Measures; Mitigating New Risks; Challenging Sanctions
Speakers include: Sarosh Zaiwalla Senior Partner Zaiwalla and Co. (UK)
Sophie van Til Leedham Head of Financial Crimes Group AIG EMEA (UK)
Unsynching US and EU sanctions against Iran: What residual restrictions are still in place? Who do these apply to?
Enforcement risks of proposed Iran-related activity: Penalties and recent OFAC enforcement actions
Highlighting the difficulties in the continued application of US primary sanctions and
- General License H (and the challenges this poses)
- Continued use of sanctions clauses
- Continued SEC Section 219 reporting
- Transparency to clients, dealing with banks, recusal policies for US Persons, Iran crude shipments going around the world
Pursuing damages against current Government listings
Update on sanctions cases in the European court
What types of transactions can put you at risk of further fines and/or loss of dollar clearing licence?
15.00 Hot Topic: The Impact of Iran Sanctions Relief on the Insurance and Reinsurance Industry
Discussion Leader Susan Leddy
Head of Financial Crime Risk, Director Legal & Compliance Swiss Re (Switzerland)
Speakers include: Michael E. Zolandz
Partner Public Policy and Regulation and Government Dentons (USA)
Dirk Wegener Vice President FERMA - Federation of European Risk Management Associations (Belgium)
Marie Bolton-Jones Group Director of Financial Crime Willis Towers Watson (UK)
Can’t take time out of the office? View the forum from the convenience of your home or office. Save money on travel and view the forum according to your own schedule. This Forum recording allows you to view all the authorised sessions and handouts.
The recorded archives of the presentations will be available for you to view after the forum, so you can re-watch sessions, or view any sessions you may have missed.
FORUM ON DEMAND From £95
C5 works closely with sponsors to create the perfect business development solution catered exclusively to the needs of any practice group, business line or corporation. With over 500 forums held in Europe, Russia and the CIS, China, India, the US and Canada, C5 provides a diverse portfolio of first-class events tailored to the senior level executive.
To find out how to position your firm as an industry leader by sponsoring this event, please contact Sofiane Guerni on +44 (0)20 7878 6870 or email [email protected]
GLOBAL SPONSORSHIP OPPORTUNITIES
Payment obligations with Iranian or Iran-related entities in connection with claims and covers: How to find a bank willing to process payments related to Iran
USD-denominated contracts and premium splits: views and clashes within the industry
Due diligence: Some golden rules – do’s and don’ts to satisfy the regulators and protect yourself
Contractual questions: Are sanctions clauses enough? Consequences on standard capital markets sanctions reps and warranties ?
What does the future hold - crystal ball or a clear road ?
15.45 Refreshments and Networking
16.00 What to Watch out for from a Sanctions Perspective in M&A Deals
Tahlia Townsend Partner Wiggin and Dana (USA)
Sanctions-related liability in M&A transactions
16.30 Champagne Roundtables
Be part of informal thought leadership discussions with your peers as you end the day sharing your views, concerns and visions regarding the future of the industry
Brexit: What’s next for Sanctions?
Iran
Russia
AML and CFT
Trade Finance
Asset Freezing and DPAs
17.30 Forum Adjourns
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctionsa C5 Group Company
Business Information in a Global Context
Economic Sanctions & Financial Crime 15-16 November, 2016 | Le Méridien Piccadilly Hotel
08.15 Morning Refreshments and Networking
09.00 Opening Remarks from the Chair
09.15 Enforcing Sanctions Screening Protocols Amid Fast Evolving Regulation
Speakers include: Karen Walter Director, Head of Economic Sanctions Unit, Group Legal & Compliance Allianz Group (Germany)
David Marshall Head of Compliance NIBC N.V. London Branch (UK)
A risk based approach to sanctions and PEP screening
Keeping the multitude of lists up-to-date and ensuring prospective clients and account holders are properly screened against these lists
What to do once a hit is discovered. When to contact the authorities?
Tailoring global sanctions screening protocols to your operations
Measuring the functionality and effectiveness of your screening protocol. Customising screening criteria to the risks posed by particular transactions and financial products
Screening cross-border transactions
Record of screening policy: timescales, frequency, resolution of matches and reporting
10:00 Effective Implementation of Financial Sanctions and Asset Freezing Measures
Simon Wilkin Head of Financial Crime Group, PD – Legal and Compliance Department Sumitomo Mitsui Banking Corporation Europe Limited (UK)
What means of control should be put in place to prevent breaches of sanctions prohibitions
Existing frameworks and legal remedies related to confiscation, asset freezing and frozen asset management: International standards and best practices
Outlining effective prevention and detection procedures: focus on customer relationships/transactions
Detecting the areas where dealings with a sanctions target is possible
How Valuable are DPAs as a Tool for Resolving Sanctions in the UK
Many of our high-profile speakers confirm their participation after the brochure is published. If you would like to be considered as a speaker for this programme please contact Anita Arthur at [email protected]
What conditions must be met to qualify for suspension of proceedings, and avoiding possible criminal liability
Key concerns about DPAs vs civil sanctions
11.00 Refreshments and Networking
11.15 New Customer Due Diligence (CDD) and Beneficial Ownership Disclosure post Panama Papers
Speakers include:
Nancy A. Fischer Partner Pillsbury Winthrop Shaw Pittman LLP (USA)
Fintan Byrne Head of Risk & Chief Compliance Officer CurrencyFair (Ireland)
New company ownership information sharing requirements
Checks and assessments to verify the accuracy of information on beneficial owners
Tips and recommendations to develop a risk profile for each customer
What to look for when analysing customer relationships
When and how to facilitate proper reporting of suspicious activities
Assessment of risk and red flags
AML compliance screening
11.45 Preventing and Mitigating Rapidly Growing Risks of Terrorist Finance
Richard Wall Senior Manager, AML Governance Officer BMO Global Asset Management EMEA (UK)
Counter Terrorist Financing (CTF) is a complex area for financial crime prevention and yet so often overlooked in the industry as merely controls of the Al-Qaeda sanctions. This session will discuss why it is important to adopt a holistic approach to possible red flags throughout all aspects of FCP: on-boarding, ongoing monitoring, redemptions and closures
Overview of major terrorist groups, and “lone wolfs”: How do they operate? How are they are financed?
Insights of the geopolitical landscape
FORUM DAY TWO: WEDNESDAY, 16 NOVEMBER 2016
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctionsa C5 Group Company
Business Information in a Global Context
Economic Sanctions & Financial Crime 15-16 November, 2016 | Le Méridien Piccadilly Hotel
Best practice for detecting and managing the risks of terrorist finance:
- Risk assessment
- Third party relationships, including your correspondent networks
- Social media monitoring
Leveraging existing AML controls to strengthen CTF
12.30 Networking Luncheon
13.30 Deploying Best Practices and Supporting Processes to Drive Better Investigation Outcomes
Speakers include: Richard Ferris Chief Counsel Aon Risk EMEA (UK)
Chiawen Kiew Principal Investigations Manager, Office of the Chief Compliance Officer EBRD (UK)
Key behaviours and processes for successful investigations:
- Establishing governance
- Assessing risk
- Managing internal and external resources and stakeholders
How to manage investigations imposed by Multilateral Development Banks and International Financial Institutions (IFIs)
- Investigative protocols on sanctions
- How investigations are conducted - managed outcomes, conclusions, closure and governance
- Enforcement of debarment decisions
Best practices for robust, cost-effective and group-wide processes to monitor client activity for possible connections to money laundering and high-risk terrorist financing entities
Integrating people, processes and software protocol solutions into a coherent deployment
Practical solutions for deploying automated and manual screening systems across the sanctions and financial crime domains
Managed outcomes: conclusion, closure, and governance
14.30 Addressing Sanctions Risks in Trade Finance and Export Controls
Speakers include: Ali Rathod-Papier Legal Counsel, Group Financial Crime Legal Barclays Bank PLC (UK)
What are the main challenges in trade finance and why should you be paying attention to these risks?
What does the future of export controls in the trade finance context look like?
- Enforcement - The relationship with regulators
15.15 Refreshments and Networking
15.30 Re-evaluating Cybersecurity Controls and Minimising Imminent Cyber Sanctions Risks
Many of our high-profile speakers confirm their participation after the brochure is published. If you would like to be considered as a speaker for this programme please contact Anita Arthur at [email protected]
Governance and cyber risks assessment: Responding to cyber security inspections from the regulators
Checking for “indicators of compromise” on computers connected to the Swift messaging service
New sanctions programme targeting individuals and groups outside the US
Best practice on cyber security control measures; and reducing exposure to possible cyber sanctions from cyber-security breaches and clients data loss
16.00 Tailoring Internal Procedures amidst Intensified Investigations and Enforcement Actions into Offshore Tax
Many of our high-profile speakers confirm their participation after the brochure is published. If you would like to be considered as a speaker for this programme please contact Anita Arthur at [email protected]
Introducing a new criminal offence for failing to stop employees from facilitating tax evasion and dealing with the proceeds of evasion
What types of offences and violations can trigger an investigation?
What reasonable procedures must be put in place to stop an “associated person” committing an offence in jurisdictions outside the UK
Setting up rigorous “Know Your Client” and new client adoption procedures
Non-compliance with implementing new reporting schemes
16.45 Chair’s Closing Remarks
17.00 Forum Ends
Great range of experience among the speakers and some great insightNicholas Kinnear Group Sanctions Policy Team Lead, RBS
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctionsa C5 Group Company
Business Information in a Global Context
Economic Sanctions & Financial Crime 15-16 November, 2016 | Le Méridien Piccadilly Hotel
PRACTICAL WORKSHOPS DAY THREE: THURSDAY, 17 NOVEMBER, 2016
WORKSHOP AA COMPLETE GUIDE ON MITIGATING COMPLIANCE RISKS RELATED TO IRAN SANCTIONS POST-IMPLEMENTATION DAY9.00 – 12:00 (REGISTRATION BEGINS AT 8:45)
Dismantling a complex web of restrictive measures against Iran creates new responsibilities and significant new areas of regulatory and compliance risks. Attend this advanced, highly focused workshop and receive thorough guidance on hugely topical areas of careful management of your compliance program; testing your due diligence processes and ensuring proper procedures are in place and on par with the latest expectations of enforcement agencies.
Workshop Leaders:
Simon Wilkin is responsible for all matters relating to antimoney laundering, financial crime, anti-bribery and corruption and sanctions. He has been with SMBCE since December 2012. Prior to SMBCE Simon was the MLRO for Crédit Agricole Corporate and Investment Bank London Branch for two years until December 2012 and Investec Bank plc for 8 years until December 2010. Previously Simon served as a Detective for 13 years with the Metropolitan Police Service; his last positing was with the Fraud Squad at New Scotland Yard.
Sophie van Til Leedham has over 20 years of experience in the insurance industry, most notably in the areas of financial sanctions, AML, insurance law, general commercial law and data privacy. She and her team assist all business functions with sanctions and export control queries, as well as advise on AML and Anti Bribery and Corruption matters, working closely with the local compliance officers in the various countries. She is also responsible for the sanctions screening processes in EMEA. Prior to joining AIG, Sophie was Corporate Counsel and Data Privacy Officer for Chubb Insurance in Europe. She is a qualified lawyer in the UK, The Netherlands and the U.S. (in Connecticut and New York).
About Your Workshop Leaders:
What type of transactions can put your organisation at risk of further fines and/or loss/suspension of the dollar clearing licence?
What procedures must be put in place to ensure robust due-diligence and screening to avoid indirect breach?
Where and how to obtain information on Iranian counterparties (and their corporate structures) within a non-transparent environment?
Who can and can’t enter into transactions with the Government of Iran?
What activities must be disclosed to regulators under the US SEC reporting requirements? How often?
Dealing with the risk of possible “snap backs”: What sanctions/exclusion clauses and right of terminations should be used at the documentation drafting stage?
Processing Iran-related transactions: What should your compliance efforts entail in order to reflect the new reality?
Assessing money laundering, terrorism financing and corruption risks
Simon Wilkin Head of Financial Crime Group, PD – Legal and Compliance Department Sumitomo Mitsui Banking Corporation Europe Limited (UK)
Sophie van Til Leedham Head of Financial Crimes Group AIG EMEA (UK)
WORKSHOP BYOUR STEP-BY-STEP GUIDANCE ON LISTING AND DE-LISTING ON TARGETED SANCTIONS IN THE UN, EU AND US13.00 – 15.30 (REGISTRATION BEGINS AT 12:45)
To be able to implement and document robust and comprehensive compliance policies and programmes, financial institutions must understand complex procedures and precise obligations applied in relation to the adoption of sanctions and restrictive measures. This advanced, highly focused workshop will provide you with crucial information on listing and delisting procedures helping you to ward off any potential legal challenges.
Workshop Leader:
Maya Lester QC Barrister Brick Court Chambers (UK)
About Your Workshop Leader: Maya Lester QC has a particular expertise in the law relating to economic sanctions. As the most recent Chambers & Partners (2016) put it, she “owns the world of sanctions”. She founded and co-writes a blog on European sanctions law (www.europeansanctions.com) and spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She recently started a Brick Court Chambers blog on the legal issues arising out of Brexit (brexit.law)
WORKSHOP B
The status update of the current UK economic and financial sanctions and restrictive measures
Update on sanctions cases in the European court
Key instruments for imposing sanctions
Can sanctioned parties challenge the legality of sanctions?
Listing procedures and due process
Challenging sanctions designations
Who is entitled to submit listing and de-listing requests?
What information should be included in listing and de-listing requests?
Delisting procedures: Review process - contentious issues – judicial review and legal remedies
To register call +44 (0)20 7878 6888 or visit www.c5-online.com/economicsanctionsa C5 Group Company
Business Information in a Global Context
Economic Sanctions & Financial Crime 15-16 November, 2016 | Le Méridien Piccadilly Hotel
THANK YOU TO OUR SPONSORS
Lead Sponsor
Dealing with complex issues of fraud, regulatory compliance and business disputes can detract from efforts to succeed. Better management of fraud risk and compliance exposure is a critical business priority – no matter what the industry sector is. With over 3800 fraud investigation and dispute professionals around the world, we can assemble the right multidisciplinary and culturally aligned team to work with you and your legal advisors. We work to give you the benefit of our broad sector experience, our deep subject matter knowledge and the latest insights from our work worldwide www.ey.com
Associate Sponsor
Pillsbury, a dynamic full-service law firm, has offices located across the globe to service our clients. Pillsbury’s international trade practice advises clients on a wide range of topics including export controls, economic embargoes and sanctions, anti-money laundering compliance, foreign investment and industrial security regulations, and anticorruption laws. Pillsbury’s Global Trade & Sanctions blog can be found at http://www.globaltradeandsanctionslaw.com
Executive Sponsor
Dentons is the world’s first polycentric global law firm. A top 20 firm on the Acritas 2015 Global Elite Brand Index, the Firm is committed to challenging the status quo in delivering consistent and uncompromising quality and value in new and inventive ways. Driven to provide clients a competitive edge, and connected to the communities where its clients want to do business, Dentons knows that understanding local cultures is crucial to successfully completing a deal, resolving a dispute or solving a business challenge. Now the world’s largest law firm, Dentons’ global team builds agile, tailored solutions to meet the local, national and global needs of private and public clients of any size in more than 125 locations serving 50-plus countries. The Firm serves the local, regional and global needs of private and public clients of all size— individuals; entrepreneurs; small businesses and startups; local, regional and national governments, and government agencies; and mid-sized and larger private and public corporations, including international and global entities www.dentons.com
Session Sponsors
Kelley Drye’s Export Controls and Economic Sanctions practice offers full-service export control and economic sanctions counseling. We advise clients on the full range of laws governing the export and reexport of goods, technology, software, and services. We institute compliance systems; conduct internal investigations; prepare VSDs; and represent companies facing civil and criminal enforcement proceedings www.kelleydrye.com
Wiggin and Dana is a full-service law firm with 150 lawyers that represents clients throughout the United States and globally from our offices in Connecticut, New York and Philadelphia. Wiggin and Dana provides a broad range of legal services to meet the needs of our diverse client base. Our clients include publicly traded companies, hospitals and other health care organizations, universities, entrepreneurs and emerging growth companies, real estate developers, financial institutions, museums, charitable organizations and individuals. www.wiggin.com
Economic Sanctions & Financial Crime 15-16 November, 2016 | Le Méridien Piccadilly Hotel
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This year marks 30 years since the inception of C5 Group. It is time to match our brand with the dynamic strides we have made.
See inside for details…C5Business Information in a Global Context
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Address: 21 Piccadilly, London W1J 0BH
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