On 25 November at a sentencing hearing at Southwark Crown Court, Alstom Network UK Limited (ANUK) – a subsidiary of French rail conglomerate Alstom – was fined £15m, plus £1.4m in costs, for conspiring to make corrupt...more
12/20/2019
/ Alstom ,
Bribery ,
Corporate Fines ,
Corporate Misconduct ,
Criminal Conspiracy ,
Criminal Convictions ,
Deferred Prosecution Agreements ,
Internal Investigations ,
Jury Trial ,
Remediation ,
Risk Assessment ,
Serious Fraud Office (SFO) ,
Subsidiaries ,
Suspensions & Debarments ,
UK
Anti-corruption watchdog Transparency International has published its 2018 Corruption Perceptions Index (“CPI”). The CPI analyses perceptions of public sector corruption in 180 countries and territories, and ranks each...more
On 28 November 2018, Lisa Osofsky, Head of the UK Serious Fraud Office (“SFO”), delivered the keynote address at the 35th International Conference on the Foreign Corrupt Practices Act (“FCPA”) in Washington DC. After a...more
On 3 September, Lisa Osofsky gave her inaugural speech as the new Director of the UK Serious Fraud Office (“SFO”) to the annual Cambridge International Symposium on Economic Crime.
After a long period of transition...more
The UK Financial Conduct Authority (“FCA”) recently released its 2018/19 Business Plan. The Plan sets out the FCA’s priorities for the year ahead across multiple areas, including financial crime....more
In Bilta (UK) Limited v Royal Bank of Scotland [2017] EWHC 3535 (Ch), the High Court once again addressed the application of legal privilege to documents prepared in the course of an internal investigation.
The internal...more
Last month, the European Union Agency for Network and Information Security (ENISA) published its 2017 ‘Threat Landscape Report’. The Report comments on general trends in the area of cybercrime, and identifies and gathers data...more
Last week the UK government announced plans to launch a new national economic crime centre (NECC), which promises to tackle ‘the most serious cases of economic crime’. This is a grand promise.
Originally published in The...more
In a speech delivered earlier this year to the AFME European Compliance and Legal Conference1, Mark Steward, Director of Enforcement and Market Oversight for the UK Financial Conduct Authority (“FCA”), addressed the agency’s...more
Speaking at the 35th annual Cambridge International Symposium on Economic Crime, Robert Buckland QC MP, the Solicitor General for England and Wales, and David Green QC, Director of the SFO, addressed the question, “Preventing...more
9/20/2017
/ Anti-Money Laundering ,
Chief Compliance Officers ,
Compliance ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corporate Liability ,
Deferred Prosecution Agreements ,
Financial Action Task Force ,
Financial Crimes ,
HM Treasury ,
Law Enforcement ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK
Following the investigations into alleged manipulation of the London Interbank Offered Rate (Libor), in July the head of the Financial Conduct Authority (FCA), Andrew Bailey, announced plans to abandon this “unsustainable”...more
In the wake of multiple criminal and regulatory investigations into alleged manipulation of the London Interbank Offered Rate (“LIBOR”), Andrew Bailey, Chief Executive of the UK Financial Conduct Authority (“FCA”) has...more
This article follows on from “Part I: Detecting bribery", which also contains a summary of the background to the OECD’s Phase 4 Report. For completeness, a short background section is repeated here....more
“The UK has made significant improvements to its ability to detect foreign bribery, but could still do more by reforming out-of-date legislation and better utilizing existing resources.”
On 23 March 2017, the...more
4/26/2017
/ Anti-Bribery ,
Anti-Money Laundering ,
Compliance ,
Deferred Prosecution Agreements ,
Information Reports ,
NGOs ,
OECD ,
Serious Fraud Office (SFO) ,
Suspicious Activity Reports (SARs) ,
UK ,
UK Bribery Act ,
Whistleblower Protection Policies
On Feb. 13, 2017, John Griffith-Jones, chairman of the U.K. Financial Conduct Authority, delivered a speech to the Cambridge Judge Business School at the University of Cambridge entitled "What makes good conduct...more
On 16 January 2017, the UK Government published its response to the International Development Committee’s (“IDC”) report “ Tackling Corruption Overseas”. The original IDC report appraised the UK Government’s efforts in...more
In the years since the financial crisis, the topic of whistleblowing has been high on the public agenda. At the 2016 Anti-Corruption Summit earlier this year, the UK government committed to “providing effective protections...more
The high-profile insider trading prosecution dubbed “Operation Tabernula”, brought by the Financial Conduct Authority (“FCA”), has this month secured two further convictions. After a 12-week trial, Martyn Dodgson and Andrew...more
In B, N, O, Q, R, U, V (Former Soldiers) v The Chief Constable of the Police Service of Northern Ireland [2015] EWHC 3691 (Admin), Lord Thomas provided helpful clarification on the court’s interpretation of legislation...more
On 27 January, the Divisional Court in R (McKenzie) v Director of the Serious Fraud Office [2016] EWHC 102 (Admin) confirmed the lawfulness of the SFO’s procedures for dealing with material potentially subject to legal...more