Enforcement action

Set out below are thoughts from Allen & Overy’s market leading investigations team on issues relating to enforcement action taken by the FCA, as well as other regulators in the UK and overseas.

New guidance about what to expect if self-reporting to the SFO

The Director of the SFO, Lisa Osofsky, confirmed back in April of this year that she would “soon be issuing guidance for corporates and their legal advisers to provide them with added transparency about what they might expect if they decide to self-report fraud or corruption to my office.” This Guidance was published as an Read More

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U.S. continues aggressive sanctions and anti-money laundering enforcement against non-U.S. banks

When assessing anti-money laundering risk and exposure, global financial institutions should be mindful of the complex landscape and assertions of broad authority by U.S. authorities and banking regulators. U.S. banking regulators, in conjunction with U.S. criminal and civil authorities, have traditionally pursued anti-money laundering and sanctions enforcement cases against multinational banks in relation to conduct Read More

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Parent company atones for the crimes of a subsidiary

The fifth DPA, between the SFO and Serco Geografix Ltd, is the first in which a parent company has undertaken to pay a penalty and oversee a group wide reinforcement of its compliance programme even though it was not liable for the underlying fraud and false accounting by its subsidiary.  Also worthy of note are Read More

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SFO rhetoric about cooperating witnesses continues to pile on the pressure

Lisa Osofsky, Director of the UK’s Serious Fraud Office (SFO), has talked about wanting to bring cases to life for juries by relying on cooperating offenders to give evidence against senior individuals. She reinforced this message last week at the GIR Live, Women in Investigations conference. The SFO’s aim here is to bring more senior Read More

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My turn to ask the SFO a few questions

Normally it is my clients who are on the receiving end of questions from the SFO, so I was delighted to be given the opportunity by GIR on Wednesday to be able to put some questions to the Director of the SFO, Lisa Osofsky,  about a number of issues that individuals and companies have been Read More

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