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

FCA: ‘We have not gone soft’

Sarah Hitchins

Bumper fines have become a mainstay of UK Financial Conduct Authority (FCA) enforcement action. However, last year we saw a significant drop in the financial penalties imposed by the FCA. It got people talking. Has the FCA gone soft? In a speech delivered earlier this month, Mark Steward gave a clear ‘no’ in response to Read More

SEC announces another large whistleblower award – with a twist

Kurt Wolfe

In 2016, the SEC announced 7 of its ‘Top 10’ whistleblower awards. And the Office of the Whistleblower has continued apace in 2017, recently announcing its sixth-largest whistleblower award – more than $5.5 million to a whistleblower ‘who provided critical information that helped the SEC uncover an ongoing scheme’. According to the Order Determining Whistleblower Read More

The Hong Kong “Manager In Charge” regime – a new approach?

Matt Bower

This blog post was co-authored by Charlotte Robins, a financial services and regulatory partner based in Hong Kong.  On 16 December 2016, the Securities and Futures Commission (SFC) published a ‘Circular to Licensed Corporations Regarding Measures for Augmenting the Accountability of Senior Management’ (Circular) together with associated Frequently Asked Questions. The SFC did so to Read More

Holding out? Don’t even think about it…

Will Yip

Recent decisions of the Hong Kong Court of Final Appeal (CFA) and lower courts in Securities and Futures Commission and C.L. Management Services Limited and Another concerning convictions under the Securities and Futures Ordinance (SFO) are notable as making it easier for the Securities and Futures Commission (SFC) to pursue unlicensed activity. The decisions also Read More

Whistleblower Annual Report: SEC’s Whistleblower Program Continues to have a ‘Transformative Effect’

Kurt Wolfe

The SEC’s Office of the Whistleblower recently released its 2016 Annual Report to Congress. In it, the Chief of the Whistleblower Office touted the ‘transformative effect the SEC’s whistleblower program has had on the agency’s enforcement program’. And, by all accounts, it was indeed a banner year for the Whistleblower Office. According to the Annual Read More