Individuals

Taking enforcement action against individuals has long been a priority for the FCA in the UK, as well as regulators across the globe. Read Allen & Overy’s thoughts on this topic below.

Employee interviews in internal investigations

Recent developments in the U.S., UK and Germany have cast a spotlight on the interplay between corporate internal investigation interviews and investigations by, and cooperation with, the authorities. Interviewing company employees is often a key part of an internal investigation. Despite most employees having little choice but to agree to give internal interviews, they are 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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DPA penalty discount for self reporting: change recommended by House of Lords committee

The operation of the Bribery Act 2010 has been subjected to post-legislative scrutiny for the first time since it came into force. A House of Lords Committee heard evidence from businesses, NGOs, lawyers, judges, enforcement authorities and the government. The report, published on 14 March, is largely very positive about the impact of the Act. Read More

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