Compliance Perspectives: Compliance Challenges in India
FCPA Compliance Report-Episode 350, Linda Justice and Her Nancy Drew Approach
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol
A draft ‘failure to prevent fraud’ corporate criminal offence will render large companies liable for fraud committed by their associates. We consider the draft offence and implications for businesses....more
The investigation is being carried out under the CMA’s competition law powers rather than under its consumer protection functions. On 18 June, the CMA released an update noting that it had launched an investigation under...more
The Court of Appeal has recently handed down a number of important judgments addressing the scope of Legal Professional Privilege (LPP). In Sports Direct International plc v Financial Reporting Council, a unanimous Court of...more
On January 17, 2020, the United Kingdom’s Serious Fraud Office (“SFO”) published new guidance regarding how the office assesses the compliance programs of organizations that are under investigation. “Evaluating a Compliance...more
The UK and the US signed a new data-sharing agreement on 3 October designed to facilitate the exchange of evidence and enhance co-operation between the two countries and their respective investigatory authorities. The first...more
Director of the Serious Fraud Office Lisa Osofsky used her annual Cambridge Symposium speech to emphasise the importance of international and corporate co-operation, to issue a call to arms for greater legislative assistance...more
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
On July 9, 2019, the United Kingdom’s Financial Conduct Authority (FCA) published its latest Enforcement annual performance report for the year 2018/19. This follows the publication of its final FCA Mission: Approach to...more
One of the most insipid hit records of the 1960s was Roger Miller’s “England Swings (Like a Pendulum Do).” In an earlier edition of this august Journal, I detailed how differently our English “cousins” swing on the issue of...more