Welcome to Allen & Overy’s Investigations Insight blog, sharing with you our views and insights into the latest trends, risks and developments in business crime and financial services investigations

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

The End of SEC Disgorgement?

In Kokesh v. SEC, 137 S. Ct. 1635 (2017), the U.S. Supreme Court held that disgorgement in SEC enforcement actions constitutes a penalty rather than equitable relief. Disgorgement requires a defendant to return the ill-gotten gains obtained as a result of his wrongdoing. The Supreme Court’s decision meant that SEC disgorgement now is subject to Read More

U.S. DOJ Antitrust Division launches Procurement Collusion Strike Force

The U.S. Department of Justice’s Antitrust Division announced on 5 November 2019 that it has established the Procurement Collusion Strike Force (PCSF), a new task force designed to detect criminal anticompetitive behavior in government procurements. This comes off the back of recent statements from senior DOJ officials that the Division had plans to be more Read More

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

International tier one telecoms carrier fined for sanctions breach

The UK financial sanctions enforcer, the Office of Financial Sanctions Implementation (OFSI), announced on 28 October a fine of a UK subsidiary of an international tier 1 telecoms carrier (the Company) for indirectly facilitating international telephone calls to SyriaTel, a designated entity under EU financial sanctions on Syria, implemented by the Syria (European Union Financial Sanctions) Read More