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SFO Announces Ambitious Five-Year Plan

The Serious Fraud Office’s strategy for 2024 to 2029 indicates aspiration to be a more effective agency and to incentivise personnel. On 18 April 2024, the UK’s Serious Fraud Office (SFO) published an ambitious, albeit...more

Delaware Court Confirms Corporate Officers’ Duty of Oversight - Lessons for UK Companies

The US decision reminds UK companies and their officers to identify and report red flags about misconduct in the workplace. Certain shareholders of McDonald’s Corporation (the Company) sued David Fairhurst, the Company’s...more

Can Forced-Labour Goods Trigger UK Money Laundering Violations?

A court recently found that UK authorities did not fetter their discretion by not investigating general cotton imports potentially produced by the forced labour of Uyghur people in China. On 20 January 2023, the High...more

Whistleblow Insights: Recurrent Themes and Common Drivers - January 2023

Many sectors, including financial services, have encountered a discernible increase in whistleblows in recent times — a trend that shows no signs of abating. Indeed, some whistleblowers have seen fit to publicise their...more

UK Introduces Sanctions Regime Targeting Global Human Rights Offenders

The regulations will enable the UK government to sanction persons “involved” in human rights abuses — potentially anywhere in the world. On 6 July 2020, the UK Foreign Secretary announced the introduction of the Global...more

UK Sanctions Authority Issues Record Penalty for Russia-Related Sanctions Violations

The penalty reflects the increasingly active approach in the UK to the enforcement of sanctions breaches. The UK’s financial sanctions regulator, HM Treasury’s Office of Financial Sanctions Implementation (OFSI), has...more

UK SFO Releases Guidance on Corporate Cooperation Credit

Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations. On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more

Lessons for UK Companies From US DOJ Guidance on Corporate Compliance Programs

The DOJ’s recently updated guidance poses helpful questions for UK corporates evaluating the effectiveness of their internal compliance programmes. It is well known that a corporate’s failure to prevent offences can be...more

UK Serious Fraud Office Director Outlines Priorities in Keynote Speech

New director Lisa Osofsky confirms her focus on cross-border and corporate cooperation. On 3 September 2018, in her first speech, after only one week as head of the UK’s Serious Fraud Office (SFO), Lisa Osofsky laid out her...more

Internal Investigations Protected By Privilege Once More?

English Court of Appeal Reaffirms Privilege Over Internal Investigation Documents Prepared in Contemplation of Litigation - In a much anticipated decision, the Court of Appeal has reaffirmed legal privilege protection for...more

UK To Provide Compensation for Overseas Victims of Economic Crimes

A new UK policy establishes a commitment to providing victims of overseas bribery with compensation; however, important questions remain that will impact implementation. The UK’s Serious Fraud Office (SFO), the Crown...more

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