FCPA Compliance and Ethics Report-Episode 19 with Barry Vitou on Bribery Act Updates
According to the New York Times, the Securities and Exchange Commission (“SEC”) is investigating potential bribery issues stemming from alleged abuses in JPMorgan’s “Sons and Daughters” hiring program in China. As reported in...more
The UK Serious Fraud Office (SFO) has updated a webpage on its case relating to Sustainable Agroenergy plc and Sustainable Wealth Investments UK Ltd. These are the first charges to be brought by the SFO under the Bribery Act....more
FDIC Guidance on Deposit Advance Products -
On November 21, the FDIC issued final supervisory guidance to FDIC-supervised financial institutions with respect to the risks imposed by certain deposit advance products. ...more
On November 20, 2013, during a panel presentation at the 30th International Conference on the Foreign Corrupt Practices Act (“FCPA”), current and former prosecutors from the United States and the United Kingdom discussed the...more
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
On October 7, the Secretary of State for the Home Department in the UK released a policy paper entitled, Serious and Organized Crime Strategy, in which the Secretary discussed the government’s strategy towards combating...more
SFO’s director’s recent speech outlines enforcement of the Bribery Act and developments related to self-reporting, the possible extension of the corporate offence, and prosecutions.
On 24 October, David Green, director...more
One of the most dreaded questions in any Foreign Corrupt Practices Act (FCPA) investigation is: Where Else? By this I mean that if you have a systemic failure of internal controls in one geographic area it may well be that...more
In this Episode 19, I visit with Barry Vitou, one-half of thebriberyact.com duo. Barry advises on recent remarks at the PinsentMasons Regulatory Conference by SFO Director David Green on enforcement of the UK Bribery Act and...more
On this day 75 years ago Orson Welles caused a nationwide panic with his broadcast of “War of the Worlds” – a realistic radio dramatization of a Martian invasion of Earth. The show began on Sunday, October 30, at 8 pm....more
In times of austerity in Europe and America, emerging markets such as Africa, China, India, Latin America, the Middle East and CIS are increasingly offering the key opportunities for growth and investment returns for private...more
Recent strategy paper sets out a new institutional structure for investigating bribery and proposes a reporting mechanism carrying financial incentives for whistleblowers.
On 7 October, as part of its strategy document...more
Although the perceived slow pace of investigations and prosecutions by the Serious Fraud Office ("SFO") has come in for a great deal of commentary and criticism, it does appear that the SFO is slowly but surely ramping up its...more
Welcome to the July/August 2013 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. In this month’s edition, the UK’s Serious Fraud Office files its first Bribery Act charges; a...more
High Court holds that reports used by the Serious Fraud Office to obtain search and arrest warrants are not subject to litigation privilege in subsequent civil proceedings.
Donna Boehme and Jim McGrath continually rail against the notion that a ‘rogue employee’ causes the majority of bribery and corruption charges under such laws as the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act. ...more
From our deck chairs we thought we’d share this with you. An open letter from David Green, Director of the SFO, in connection with facilitation payments.
Originally Published on thebriberyact.com - August 22, 2013....more
On August 14, the Serious Fraud Office (SFO) published a press release announcing that it has charged four men with offenses of conspiracy to commit fraud by false representation and conspiracy to furnish false information,...more
The Serious Fraud Office (“SFO”) brought fraud related charges against three directors and one employee of Sustainable AgroEnergy plc (“SAE”), a subsidiary of Sustainable Growth Group (“SSG”) on 14 August 2013, as part of a...more
On August 14, 2013, the Serious Fraud Office (SFO) charged three British nationals with offenses under the UK Bribery Act 2010. This is the first Bribery Act prosecution brought by the SFO. While it is impossible to discern a...more
On 14 August, the Serious Fraud Office (SFO) announced that four men connected to Sustainable AgroEnergy plc have been charged with offences of conspiracy to commit fraud by false representation and conspiracy to furnish...more
An unknown number of employees of GlaxoSmithKline (China) Investment Co. Ltd., the local subsidiary of the British multinational corporation GlaxoSmithKline plc. (GSK), were detained on allegations of data fraud and bribery...more
When it comes to allegations of foreign bribery, what a difference a week can make. Just over ten days ago, a new player in the world of international bribery – the Chinese Ministry of Public Security – announced that it was...more
On June 27, the Serious Fraud Office and Director of Public Prosecutions launched a consultation on DPAs, which are being introduced under the Crime and Courts Act 2013 in February 2014....more
Last Thursday, the U.K. Serious Fraud Office released a draft Deferred Prosecution Agreement Code of Practices (Code) for comment. The draft Code represents a significant milestone for ethics and compliance in general, and...more