Investigations

The focus of this blog is to provide insights into the latest trends, risks and developments in financial services investigations, including those conducted by the FCA, the PRA and other overseas regulators. Set out below are Allen & Overy’s thoughts on the latest developments in this area.

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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The FCA confirms the number of open enforcement investigations into ‘non-financial misconduct’

It is now just over a year since Megan Butler wrote her letter to the UK Women and Equalities Committee which coined the (now common) phrase ‘non-financial misconduct’. Even before Megan Butler’s letter was published, many regulated firms were already looking at personal misconduct (especially sexual misconduct) committed by their employees through both employment and Read More

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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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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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