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Attorney-Client Privilege Self-Reporting

WilmerHale

CFTC Releases Enforcement Manual in Hopes of Increasing Transparency

WilmerHale on

Intending to bring greater transparency to the operation of its enforcement program, the Commodity Futures Trading Commission’s (CFTC or Commission) Division of Enforcement (the Division) recently, for the first time, made...more

WilmerHale

SFO Director Attacks Privilege Ahead of Corporate Guidance on Cooperation

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The Director of the UK Serious Fraud Office (SFO), Lisa Osofsky, has promised to provide companies with concrete guidance on cooperation with the SFO. Based on her recent comments, this guidance is likely to encourage...more

Kramer Levin Naftalis & Frankel LLP

UK Court of Appeal Extends Privilege in Internal Investigations

Brief Comments on The Director of the Serious Fraud Office v. Eurasian Natural Resources Corporation Limited [2018] EWCA Civ 2006 - On Sept. 5, 2018, the Court of Appeal of England and Wales handed down a unanimous...more

WilmerHale

The UK’s second DPA: a hopeful judgment

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The approval of the Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and XYZ Limited (XYZ) by Leveson LJ on 8 July 2016 has generated much breathless commentary, not least because it is only the...more

Thomas Fox - Compliance Evangelist

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

WilmerHale

A transatlantic consideration of recent developments in corporate self-reporting

WilmerHale on

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

Locke Lord LLP

Internal Investigations: The Three C’s – Confidence. Credibility. Cost.

Locke Lord LLP on

In this issue: - THE THREE C’S — CONFIDENCE, CREDIBILITY AND COST - WHO CONDUCTS THE INVESTIGATION? - SCOPE OF THE INVESTIGATION - MINDSET AT THE OUTSET OF AN INVESTIGATION - THE NEED FOR SPEED ...more

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