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DOJ Issues New FCPA Guidelines Amid Growing Ambitions of UK and European Prosecutors

The guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted....more

Key Takeaways From the SFO’s New Corporate Guidance

The updated guidance puts a heavy emphasis on self-reporting and clarifies how corporates under investigation can earn cooperation credit from UK prosecutors....more

UK Government Publishes Guidance on “Failure to Prevent Fraud” Offence

Guidance clarifies the implementation date, scope, and application of landmark new corporate offence, and provides suggestions for fraud-prevention procedures. On 6 November 2024, the UK Home Office published...more

SFO Announces Ambitious Five-Year Plan

The Serious Fraud Office’s strategy for 2024 to 2029 indicates aspiration to be a more effective agency and to incentivise personnel. On 18 April 2024, the UK’s Serious Fraud Office (SFO) published an ambitious, albeit...more

UK Serious Fraud Office Director Outlines Priorities in Keynote Speech

New director Lisa Osofsky confirms her focus on cross-border and corporate cooperation. On 3 September 2018, in her first speech, after only one week as head of the UK’s Serious Fraud Office (SFO), Lisa Osofsky laid out her...more

UK To Provide Compensation for Overseas Victims of Economic Crimes

A new UK policy establishes a commitment to providing victims of overseas bribery with compensation; however, important questions remain that will impact implementation. The UK’s Serious Fraud Office (SFO), the Crown...more

5 Predictions for the UK’s Serious Fraud Office Under New Director

New director Lisa Osofsky’s cross-border and corporate experience may lead the SFO in a fresh direction. The announcement that Lisa Osofsky has been appointed as Director of the UK’s Serious Fraud Office (SFO) likely...more

English High Court Decision Reinforces Application of Litigation Privilege in Internal Investigations

The decision indicates that company counsel should consider early how best to anticipate challenges to privilege claims over investigation materials. Introduction - A recent English High Court decision has important...more

Bilta v. RBS: When Will Litigation Privilege Apply to Information Gathering in Internal Investigations

The English High Court has reconfirmed that litigation privilege can apply to information gathering in internal investigations. Specifically, lawyers must have engaged in the information gathering for the dominant purpose of...more

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