Last week, the U.S. Department of Justice (DOJ) announced that Sweden-based multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson) will plead guilty to breaching the Foreign Corrupt Practices Act...more
On January 17, 2023, Assistant Attorney General (AAG) Kenneth A. Polite, Jr. delivered remarks to an audience at the Georgetown University Law Center, announcing changes to the Criminal Division’s Corporate Enforcement Policy...more
On December 14, 2022, the U.S. Securities and Exchange Commission (SEC) unanimously adopted amendments to Rule 10b5-1 under the Securities Exchange Act of 1934, which adds new conditions to the use of the affirmative defense...more
On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange...more
Without fanfare, DOJ recently published a “declination and disgorgement letter,” the first FCPA declination published by the Department since August 2020.
As disclosed in the letter, DOJ has declined to prosecute Jardine...more
Threats to cybersecurity and data privacy are constantly increasing both in volume and complexity. This trend is expected to continue in 2022. In a bid to protect cybersecurity and ensure data is properly safeguarded,...more
This month, the UK’s Financial Conduct Authority (FCA) released its Business Plan for 2020/2021, setting out its objectives for the next three years. Its highest priority is to deal with the financial implications of the...more
The UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law.
The Government hopes that...more
On May 12, 2016, the UK’s Prime Minster David Cameron hosted the “Anti-Corruption Summit”, a first of its kind, bringing together world leaders, business, and civil society with the goal of seeking to agree on a package of...more
We originally wrote in 2014 about charges that had been brought in September of that year by the UK’s Serious Fraud Office against the French Multinational’s UK subsidiary, Alstom Network UK Ltd, and two former employees and...more
The current UK sanctions enforcement regime is a complicated web reflecting the requirements of UN Security Council Regulations, EU Regulations, and UK Primary and Secondary Legislation. Penalties for breaches of sanctions...more
R (on the application of Colin McKenzie) v Director of the Serious Fraud Office saw a failed application for permission to apply for a judicial review of the SFO’s currently in-use procedure for dealing with material that it...more
I recently attended a Fraud Conference in Miami where I heard a French lawyer insisting that since he was a defence advocate, his job was to defend his clients against fraud allegations, not to prosecute them. Instead of...more
The Financial Conduct Authority and the Prudential Regulatory Authority have recently been showing signs of gearing up for the new regime which is intended to have the effect of making senior bankers and other financial...more
8/20/2015
/ Bankers ,
Banks ,
Barclays ,
Financial Conduct Authority (FCA) ,
Financial Services Act ,
Forex ,
Libor ,
Personal Liability ,
Prudential Regulation Authority (PRA) ,
Senior Managers ,
Suspicious Activity Reports (SARs) ,
UK
Tom Hayes emerges from his trial at Southwark Crown Court for Libor manipulation as a very considerable loser, who took some very bad decisions in the course of the SFO investigation and trial (and perhaps deserves his long...more
Only a couple of weeks ago I was commenting on a NERA report that had found that in the period between April 2012 and October 2014 the FCA had imposed fines of over £1bn, in sharp contrast to the preceding decade during which...more
New York’s Southern District Court Judge Jed Rakoff is always worth listening to. He expresses trenchant views about the rule of law elegantly and politely. He is fearlessly independent. Prosecutors in the US, who are...more