We consider the implications for corporations under UK and US law, and the future of global criminal and civil investigations.

On November 26, 2015, the UK Serious Fraud Office (SFO) secured its first Deferred Prosecution Agreement (DPA) against UK-based ICBC Standard Bank Plc (Standard Bank) for failure to prevent one of its sister companies from bribing Government of Tanzania (GoT) officials, an offence under Section 7 of the Bribery Act 2010 (the Failure Offence).