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The Corporate Offences of Failure to Prevent the Facilitation of Tax Evasion – What It Means for You

The United Kingdom’s Criminal Finances Act 2017 (the “Act”) creates two new corporate offences of failure to prevent facilitation of tax evasion (the “Corporate Offences”). These new Corporate Offences will be committed where...more

Bribery and the beautiful game: A typology

It will have saddened many people to read further allegations of wrongdoing in English football. The story, based on classic secret recording methods, was broken by The Daily Telegraph and has been picked up by the entire...more

New SFO Bribery Case: Can’t Pay? That Might Be Okay…

The UK Serious Fraud Office has entered its second deferred prosecution agreement (DPA) with a company accused of bribery. Links to the SFO press release, and the detailed preliminary and final judgments of the court are...more

LIBOR acquittals: Keep calm and carry on

Here’s some information that may shock certain sections of the media: Not everyone charged with a crime will be, or should be, found guilty. Even people with a case to answer on paper can still, quite properly, be acquitted....more

UK Bribery: For Cooperating Companies, Virtue Has At Least Some Rewards

On Monday 30 November, an English court approved a Deferred Prosecution Agreement (DPA) between the Serious Fraud Office and Standard Bank, in connection with payments made in Tanzania. This was the first DPA approved by the...more

Big win for SFO in LIBOR trial – Tom Hayes sentenced to 14 years. More SFO prosecutions to come in financial sector?

The conviction of Tom Hayes in the first UK LIBOR trial is a watershed moment. It’s a big win for the SFO, although it must be said that a more damning book of evidence could not be imagined. The judge’s sentencing remarks...more

Civil Liability Protection For Those Making Suspicious Activity Reports (SARs)

From 1 June 2015, UK-based businesses will have greater freedom to report suspicions of money-laundering without risking liability to customers, due to an amendment being introduced to UK money-laundering law....more

Forex trading probes: what is the legal position of the individual?

Forex trading cases are back in the headlines after record settlements by a group of banks with UK and U.S. authorities. The best coverage is in the FT....more

'Commercial' Bribery: No Hiding Places

Graham Marchment was a British engineer in the oil and gas industry, with responsibilities for procurement. He accepted money, described as ‘commission’, from various bidders, in exchange for confidential information about...more

5/26/2015  /  Bribery , Oil & Gas , UK , UK Bribery Act

Football Bribery: Jail for Ex-players and middlemen

A former professional football player, Delroy Facey, has been convicted and imprisoned for offences under the UK Bribery Act. If you love sport it’s a sad story. Facey was a decent striker who, at one time, was...more

Saul better make his own call: new liability for enablers of organised crime

The law in England and Wales will shortly be reformed so that those enabling the criminal activities of an organised crime group, including professionals, can be prosecuted more easily. All businesses need to be alive to the...more

FCA issues guidance on how firms should use social media for financial promotions

The UK’s Financial Conduct Authority (FCA) has published its guidance on using social media for financial promotions. In the guidance, the FCA made it clear that they understand the power of social media as a...more

“FCA enforcement up 20%”: But what does this tell us?

During 2014, the UK’s Financial Conduct Authority (FCA) opened around 20% more investigations than in 2013, according to today’s Financial Times (subscription required). This is in line with the stricter new regime supposedly...more

Jail for UK directors and corporate sentencing to come

The prosecution of Smith and Ouzman Ltd. for bribery is winding to a close, with the sentencing of two directors of the company for corruption....more

FCA Enforcement: The Landscape After FX

This briefing discusses the new approach of the UK’s regulator, the FCA, to regulatory enforcement of wholesale markets, as revealed by the recent settlements between the agency and five banks relating to FX manipulation....more

Shale Gas in the UK: a year in review (a regulatory and policy update)

Introduction - Shale gas exploration is now featuring in the news headlines in the UK on an almost daily basis. The positions of those for and against extraction of unconventional gas through hydraulic fracturing...more

2/18/2014  /  Fracking , Shale Gas , UK

UK Bribery: Construction in the Cross-Hairs

The UK’s Serious Fraud Office has made clear that its anti-bribery investigations are focussed on two industries in particular: construction and energy. Construction firms especially are under-prepared for the risks which...more

11/18/2013  /  Bribery , SFO , UK , UK Bribery Act

Private Equity Sound Bite: Anti-Bribery Procedures – What is ‘Adequate’?

The UK Bribery Act 2010 (the “Act”) has been described as “the most draconian anti-bribery law in the world” and “the Foreign Corrupt Practices Act on steroids”. It has far-reaching implications for any international business...more

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