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.

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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Instant Messaging Apps and Corporate Record Retention Policies: revised DOJ guidance for companies

The U.S. Department of Justice (DOJ) has issued revised guidance regarding what records companies must retain to be eligible for full remediation credit under the FCPA Corporate Enforcement Policy. Previously, the Policy effectively required companies to ban the use of any ephemeral messaging applications which automatically delete data, such as WhatsApp and Wickr. The amended Read More

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FCA annual report 2017/18: Enforcement highlights

Yesterday afternoon the UK Financial Conduct Authority (the FCA) published its Annual Report. Alongside the Annual Report, the FCA also published its usual Enforcement Annual Performance Report (the Report), which sets out an overview of the FCA’s enforcement activities during 2017/18. Set out below are some of the key points highlighted by the Report.   Read More

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Know Your GDPR: self-reporting and enforcement considerations for contentious regulatory lawyers

With the recent implementation of the General Data Protection Regulation, many financial services institutions are asking themselves what it may mean from a more traditional financial services regulatory perspective, particularly in terms of firms’ ever-present reporting obligations. A&O has recently published a detailed guide to the GDPR for Litigators which deals with questions relating to Read More

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ASIC’s new Chairman promotes ASIC’s enforcement record and outlines his proposed approach to steadying the ship in choppy waters

The new Chairman of the Australian Securities and Investments Commission (ASIC), James Shipton, has welcomed the work of the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry (Financial Services Royal Commission) and noted that many of the matters that have been raised have already been, or continue to be, the subject Read More

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