The Bribery Act: To Disclose or Not To Disclose?
FCPA Compliance and Ethics Report-Episode 19 with Barry Vitou on Bribery Act Updates
On 6th December 2018, the trial of two Tesco executives accused of false accounting collapsed. The judge concluded that the SFO's evidence, taken at its highest, was such that a jury could not properly convict. The SFO...more
The law and practice relating to financial crime and investigations is evolving fast. In the past 18 months we have seen two new Acts aimed at combatting financial crime (including the creation of two new corporate criminal...more
Rolls-Royce plc, a UK-based company that manufactures engines and generators for the aerospace, defense, marine, and energy sectors, has agreed to pay over $800 million to resolve parallel investigations by U.S., UK, and...more
Today I conclude my series on the Rolls-Royce global anti-corruption enforcement action by taking a look what it all means going forward. The resolution is more than simply the stunning fines and penalties of £671 million...more
On 17 January 2017, the UK Serious Fraud Office (“SFO”),[1] the US Department of Justice (“DOJ”),[2] and the Brazilian Ministério Público Federal (“MPF”) announced an $800 million global settlement with Rolls-Royce plc and...more
Today I continue my exploration of the Rolls-Royce global corruption enforcement action by considering the company’s resolution in the US under the Foreign Corrupt Practices Act (FCPA). Before we dive into that, I first...more
When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more
We originally wrote in 2014 about charges that had been brought in September of that year by the UK’s Serious Fraud Office against the French Multinational’s UK subsidiary, Alstom Network UK Ltd, and two former employees and...more
Given London’s role in international business and finance, the UK Bribery Act 2010 promised to form a potential strong counterpart to the U.S. Foreign Corrupt Practices Act (FCPA). Now, the UK government is taking steps which...more
The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more
The Bribery Act 2010 has now been in force for three years. Despite the announcements and commentary that it heralded a new and aggressive face toward corporate corruption, there have as yet been no corporate prosecutions...more
A proposed amendment to the UK Bribery Act would give the SFO greater power to prosecute corporates for financial crimes committed by their employees. The head of the UK’s Serious Fraud Office (SFO), David Green,...more
The trial of Victor Dahdaleh in London has collapsed due to the absence of key prosecution witnesses. The UK’s Serious Fraud Office (SFO) recently dropped its case against Victor Dahdaleh, the British-Canadian...more
As noted in our previous Alert in September 2013, the UK Crime and Courts Act 2013 has now come into effect this month making deferred prosecution agreements (DPAs) available to the Director of the Serious Fraud Office (SFO)...more
Beginning in February 2014, the agreements may be used as a sentencing tool for corporate bribery, fraud, and other economic crimes. Under the UK Crime and Courts Act 2013, which received royal assent in April,...more
The UK Serious Fraud Office (SFO) has updated a webpage on its case relating to Sustainable Agroenergy plc and Sustainable Wealth Investments UK Ltd. These are the first charges to be brought by the SFO under the Bribery Act....more
FDIC Guidance on Deposit Advance Products - On November 21, the FDIC issued final supervisory guidance to FDIC-supervised financial institutions with respect to the risks imposed by certain deposit advance products. ...more
Recent strategy paper sets out a new institutional structure for investigating bribery and proposes a reporting mechanism carrying financial incentives for whistleblowers. On 7 October, as part of its strategy document...more
Introduction - Welcome to the July/August 2013 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. In this month’s edition, the UK’s Serious Fraud Office files its first Bribery Act charges; a...more
From our deck chairs we thought we’d share this with you. An open letter from David Green, Director of the SFO, in connection with facilitation payments. Originally Published on thebriberyact.com - August 22, 2013....more
On August 14, the Serious Fraud Office (SFO) published a press release announcing that it has charged four men with offenses of conspiracy to commit fraud by false representation and conspiracy to furnish false information,...more
The Serious Fraud Office (“SFO”) brought fraud related charges against three directors and one employee of Sustainable AgroEnergy plc (“SAE”), a subsidiary of Sustainable Growth Group (“SSG”) on 14 August 2013, as part of a...more
On August 14, 2013, the Serious Fraud Office (SFO) charged three British nationals with offenses under the UK Bribery Act 2010. This is the first Bribery Act prosecution brought by the SFO. While it is impossible to discern a...more