Criminal

The UK’s second Deferred Prosecution Agreement

Calum Macdonald

On 8 July 2016, the UK’s second-ever Deferred Prosecution Agreement (DPA) was concluded between the Serious Fraud Office (SFO) and an unnamed party for a number of bribery offences. Related criminal proceedings are still on-going. Accordingly, to preserve anonymity certain facts have not yet been released and the judgment authorising the DPA refers to the Read More

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A new approach to enforcement of UK sanctions?

Thomas Cusworth

On 31 March 2016 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury (HMT), opened. As noted in our publication on 17 May 2016, this may herald more aggressive enforcement against breaches of the financial sanctions regime in the UK. OFSI has been created to administer and enforce UK sanctions and has Read More

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Settlement opportunities in France: Change on the horizon?

Dan Benguigui

Legislation recently (or about to be) adopted in France will strengthen the French legal systems’ opportunities to settle white collar investigations.   The “Sapin II” Bill Named after France’s Minister of Finance, Michel Sapin, the bill adopted by France’s National Assembly on 14 June 2016 and currently examined by the Senate, will introduce a new Read More

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Excluding lawyers from section 2 interviews: Has the SFO gone too far?

Sarah Hitchins

It has usually been taken for granted that an individual who is required to attend an interview with a UK regulator or authority can be accompanied by a lawyer of their choice. That is until now. The other week, the UK Serious Fraud Office (SFO) published new guidance regarding when lawyers will be permitted to Read More

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Key insights for international firms from the latest SEC & DOJ FCPA investigations

Alex Corey

On June 7, 2016, the U.S. Securities and Exchange Commission (SEC) entered into non-prosecution agreements (NPAs) with two unrelated U.S. companies in relation to Foreign Corrupt Practices Act (FCPA) misconduct. This is only the second time that the SEC has used NPAs to deal with FCPA misconduct. In a rare move, the U.S. Department of Read More

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