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Anti-Bribery and Anti-Corruption Enforcement in the U.S., UK, and Europe post-FCPA Pause

We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more

The ‘Failure to Prevent Fraud’ Offence: A Phased Approach to Implementing Effective Fraud Prevention Procedures

The Economic Crime and Corporate Transparency Act 2023 (the “ECCTA”) introduced a corporate ‘failure to prevent fraud’ offence providing that ‘large’ organisations may be held criminally liable if an ‘associate’ (such as an...more

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