Life with GDPR - The ABB Enforcement Action from a UK Perspective
Everything Compliance-Episode 57-the Airbus edition
This Week in FCPA-Episode 190, week ending January 31, 2020 – the What’s $4 Billion Between Friends edition
This Week in FCPA-Episode 58, the Declination Edition
Everything Compliance-Episode 12
FCPA Compliance Report-Episode 282-SCCE CEI Wrap-up, Part II
FCPA Compliance and Ethics Report-Episode 167-Mara Senn on the Top 10 Practices in a Cross-Border Investigation
Serious Fraud Office (SFO) Director Nick Ephgrave has consistently touted the benefits of offering financial rewards to whistleblowers. With the FCA also considering its position on financial incentivisation, and a supportive...more
The Serious Fraud Office (SFO) recently published its new five-year strategy for 2024-2029 (the Strategy), setting out its ambitious aspirations to become a “pre-eminent specialist, innovative and collaborative agency which...more
Construction is a $1.7 trillion industry worldwide, contributing between 5 and 7 percent of GDP in most countries. However, it is also an industry that is highly vulnerable to corruption due to its inherent characteristics....more
Summary - The UK Serious Fraud Office ("SFO") has had significant problems with disclosure in its complex criminal investigations. The question has to be asked: is the current disclosure regime in criminal cases fit for...more
New criminal laws in the UK will make companies more vulnerable to criminal prosecution for the acts of their employees and agents than ever before. The Economic Crime and Corporate Transparency Act 2023 (“ECCTA”) introduces...more
On 26 October 2023, the Economic Crime and Corporate Transparency Act 2023 (the "Act" or "EECTA") received royal assent and became law. The Act introduced a number of changes, some of which came into effect immediately and...more
On 13th February 2024, in a wide-ranging speech, the Director of the UK Serious Fraud Office (SFO), Nick Ephgrave, publicly stated his provisional support for financial incentives to whistleblowers in allegations of...more
Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more
Nick Ephgrave QPM was appointed as Director of the Serious Fraud Office (SFO) back in September 2023. In his first speech he said he wants to reward whistleblowers. We take a look at the pros and cons of incentivising...more
On 13 February 2024, Nick Ephgrave gave his inaugural public speech as the new Director of the UK’s Serious Fraud Office (SFO). With a background in law enforcement, including as assistant commissioner of the Metropolitan...more
Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
2023 has been a year of change at the SFO with a new Director, enhanced investigatory powers and new statutory regime that will make it easier to prosecute corporate criminal offenders. Dropped investigations and acquittals...more
The battle against corporate crime intensifies as the UK government seeks to weaponise its incoming legislation. The "failure to prevent fraud" offence will require every large business to have ‘reasonable procedures in place...more
The UK Government yesterday introduced a new corporate “failure to prevent fraud” offence into draft legislation, the Economic Crime and Corporate Transparency Bill (“the Bill”). This is a significant development in UK...more
The Law Commission, on 10 June 2022, published its long-awaited Options Paper on Corporate Criminal Liability, which detailed possible options for the reform of corporate criminal liability in England & Wales (the “Options...more
On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more
The Justice Department continues its enforcement “silence” with no major corporate prosecutions announced this year. It is an interesting question but it appears that the wheels have ground to a halt, with one major...more
On 24 January 2022, the anti-corruption campaign group Spotlight on Corruption published a report on the state of economic crime enforcement in the UK (the “Report”). The Report warns that “the UK is currently losing the...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more
After three years of uncertainty over the Serious Fraud Office’s (“SFO”) powers to obtain documents located overseas, the UK Supreme Court has clarified the extraterritorial effect of the legislation facilitating that power...more
On 24 December 2020, the UK and the EU reached a new Trade and Cooperation Agreement. The deal, which came into force on 1 January 2021, has important implications for white collar crime enforcement across Europe, and in...more
CEP Magazine (January 2021) - The United Kingdom’s Serious Fraud Office published new guidance related to deferred prosecution agreements (DPAs). The guidance, nested in the office’s internal SFO Operational Handbook,...more
On 23 October 2020, the UK Serious Fraud Office (SFO) updated its Operational Handbook, publishing a new chapter on deferred prosecution agreements (DPAs) (the Chapter). This note summarizes key points from the Chapter and...more