On 23 May 2024, the UK Parliament passed the Digital Markets, Competition and Consumer (DMCC) Act, a landmark development in competition and consumer protection legislation. This comprehensive bill, over a year in the making, is anticipated to take effect in Autumn 2024. It introduces the most significant reforms in over two decades, affecting digital markets, merger control, and consumer law.
Themis is pleased to see the Government addressing much needed reform in protecting consumers from the potential harms of fake reviews as part of this Bill. Fake reviews mislead consumers, harm legitimate businesses and are becoming more accessible to fraudsters due to the existence of freely available AI tools to create them at scale.
Last year, the Department for Business & Trade launched its consultation on "Smarter Regulation: Improving consumer price transparency and product information for consumers". Focusing on 5 key areas, businesses and consumers were invited to comment on:
Here follows the UK regulator, Competition & Market Authority's (CMA), responses on fake and misleading reviews.
What reasonable and proportionate steps do you consider traders should take to remove fake reviews and prevent consumers from encountering them?
The CMA’s enforcement experience has focussed primarily on dedicated user review websites and larger platforms publishing or providing access to reviews. Our experience has shown that the scale, frequency and rapid dissemination of fake reviews means that it is impossible to address this issue effectively on a reactive case-by-case basis.
Based on our enforcement experience, the CMA agrees that traders which publish or provide access to reviews should take or use appropriate proactive measures to tackle fake reviews and their impacts on aggregated information, rather than relying on, for example, third parties to report problems before acting and addressing content on a piecemeal basis. We would, therefore, expect traders in scope to be able to take or use the measures described below.
Based on the CMA’s enforcement experience, they have identified measures that they would expect a trader who publishes or provides access to reviews to take or use to prevent reviews from misleading consumers.
These include:
As described above, traders which publish or provide access to reviews must take or use measures to prevent consumers from being misled. Critically, this means not only identifying and tackling fake reviews, but also preventing those reviews from impacting aggregated information such as overall ratings, review counts and rankings. Therefore, traders must ensure that they are taking or using measures to prevent published information that is influenced or determined by reviews – particularly aggregated information - from misleading consumers.
Themis believes in the power of authentic reviews to help consumers make informed decisions and help foster a community of trust between platforms and their customers. This is why we have developed our Platform Audit to support platforms striving to be proactive in tackling the fake reviews challenge.
An audit involves analysing your data to identify:
Following the audit, we will provide you with a comprehensive report outlining our findings, including a detailed breakdown of detected review threats, key takeaways and current trends.
Find out how we can help protect your business against fraud. We’d love to hear from you.
Stay on top of the ever-changing financial crime landscape by accessing the latest information on emerging criminal techniques and the risks associated with carrying out business with particular industries or in particular jurisdictions.
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The UAE’s 2025 AML/CFT law marks a major regulatory shift, replacing the 2018 framework with stricter compliance, stronger enforcement and greater accountability. With expanded scope, dual oversight and higher penalties, businesses must strengthen AML controls ahead of the 2026 FATF evaluation.
AI is transforming financial crime as much as compliance. The same tools used to detect risk are now automating fraud, laundering and cybercrime at scale. From AI-driven phishing to synthetic identities, our latest report explores how threats are evolving and how organisations can respond.
Scam call centres now operate like tech startups, using outsourced labour, data-driven tactics and AI to scale fraud globally. Their professional structure makes them hard to shut down, driving huge financial losses and severe emotional harm to victims worldwide.
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The holiday season drives generosity and year-end giving, but also a surge in charity fraud. In 2024, UK consumers lost over £1.2m to fake charity scams, while charities lose £1.65bn annually. This article explores how these scams work, warning signs, and how to protect yourself.
The illegal wildlife trade generates over US$48 billion annually, driving species extinction, biodiversity loss and ecosystem collapse. As global enforcement intensifies, tackling IWT remains a critical challenge for environmental and financial crime prevention.
As UK spending surges for Black Friday and Christmas, online scams spike. Fraudsters use fake websites, counterfeit products and AI-enhanced tactics to steal money and personal data. Shoppers must stay vigilant.
Identity fraud now extends far beyond data breaches and cloned credit cards. It includes scams that harvest personal information through fake job ads, fabricated profiles that meet onboarding checks, and AI-generated impersonation capable of fooling biometric security.
US Department of the Treasury lifted OFAC sanctions on Belavia on 4 Nov, easing curbs on Belarus’s state airline. Amid EU bans and Boeing route restrictions, analysts warn of higher sanctions evasion and parallel imports risks via Russia. Explore impacts on compliance, due diligence and trade.
“Pig butchering” is a fast-growing cryptocurrency scam where fraudsters build trusted and sometimes romantic relationships to lure victims into fake investment schemes, ultimately stealing large sums of money.
This blog examines the evolving threat of the global illicit drug trade in the Persian Gulf, highlighting four key trends we’re closely monitoring.
Cobalt powers modern technology and electric vehicles but is tied to exploitation, corruption, and environmental harm. This article unpacks global cobalt supply chains, from DRC mines to battery factories, and shows how Themis helps businesses identify and manage related ESG risks.
The U.S. has just tightened its grip on global trade: a new BIS “affiliates rule” now pulls thousands of companies worldwide under U.S. export controls. If ownership links are hidden, you could still be exposed—discover why this game-changing rule is reshaping compliance everywhere.
We’ve handpicked a selection of standout books our team discovered over the summer—perfect picks to kick off the “back-to-school" season. These compelling reads offer deep insight into financial crimes, the systemic vulnerabilities they exploit, and their far-reaching consequences.
AI is fast becoming a high-ROI tool in financial crime and compliance. From cutting costs and boosting efficiency to enhancing resilience, strategic AI investments are helping CFOs do more with less - transforming risk management and unlocking new value across the financial sector.
The UK’s latest National Risk Assessment (NRA) reveals how money laundering and terrorist financing are evolving—and how the UK is fighting back. A vital guide for AML policy, it arms businesses with intelligence to spot risks and stay protected.
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Many clients have heard of the OFAC 50 Percent Rule but aren’t sure how it affects them. It’s far-reaching, with hidden sanctions risks. This post explains the rule, why it demands deeper due diligence, and steps to identify and mitigate those risks.
In June, the EU removed the UAE from its list of high-risk jurisdictions from an AML perspective, signaling growing international confidence in the country’s financial crime oversight.
This article explains how data and analytics are used to detect insurance fraud more effectively.
New updates to the Land Conversion and Financial Crime Risk Assessment link environmental harm to financial crime. Cattle rustling in Nigeria and Cameroon is now red-rated, with added risks on carbon credit fraud, child labour, mining corruption, and gold smuggling.
An overview of modern slavery, distinguishing between human trafficking, smuggling, and forced labor. It highlights the global prevalence of exploitation and the importance of understanding these definitions to combat such crimes.
Dubai’s $160B foreign-owned real estate market faces money laundering risks. The UAE now requires reporting of property deals over AED 55K via REAR. Criminals like Daniel Kinahan have exploited property to hide illicit funds, underscoring the need for strict compliance.
Examines how digital platforms and cryptocurrencies facilitate human trafficking, allowing traffickers to operate anonymously and at scale, posing challenges for law enforcement.
Investigates how sanctions intersect with trade-based financial crimes in Hong Kong, highlighting the complexities businesses face in navigating regulatory compliance.
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Environmental crime worsens gender inequality, driving violence, trafficking, and hardship for women—especially in regions like the DRC and Peru. Women defenders face abuse, and climate change deepens risks like water scarcity, child marriage, and health threats. Tackling these crimes is key to protecting women’s rights and safety.
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Explores the application of fuzzy logic in Anti-Money Laundering (AML) systems, emphasising its role in improving name-matching accuracy and reducing false positives, thereby enhancing compliance efficiency.
This book focusses on the challenges faced by law enforcement in North West USA and in British Columbia to combat illegal logging, as well as those of the timber-industry communities established since the late 19th century to maintain meaningful and financially viable lives.
The FATF has highlighted the UAE’s progress in fighting financial crime. Its third enhanced follow-up report upgraded three recommendation ratings for the country, marking a step forward in meeting international standards.
Lebanon’s economic collapse, fuelled by debt, corruption, and instability, has led to hyperinflation and greater financial crime risk. In Oct 2024, the FATF grey-listed Lebanon. The country pledges a two-year reform plan to boost transparency and restore investor confidence.
The UK treats profits from legal overseas cannabis businesses as criminal property under the Proceeds of Crime Act. Few cases qualify for exceptions, creating a legal grey area—so anyone handling such funds should proceed cautiously and seek legal advice.
The UK’s 2023–2026 Economic Crime Plan commits £400M to tackle money laundering, kleptocracy, and fraud, with reforms to Companies House, crypto, and sanctions. Progress is clear, but critics urge more urgency and funding. Success depends on public-private collaboration.
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Romance scams rose 30% in 2022, with victims losing £8,234 on average—especially men and those aged 65–74. Scammers use fake profiles and emotional manipulation. Themis urges due diligence in dating; tools like Themis Search can flag risks and help platforms protect users.
Crypto plays roles in both social good and crime—over $50M has aided Ukraine, but bad actors use it to evade sanctions and launder funds, notably via the UAE and Central African Republic. Themis calls for stronger due diligence and compliance to curb misuse.
The Russian invasion of Ukraine has heightened trafficking risks for women and children. Over 2.5M flee, with traffickers exploiting chaos, especially in Moldova, Poland, and Italy. The OSCE urges swift action to warn refugees of false offers and protect them.
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