The guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted....more
6/23/2025
/ Anti-Corruption ,
Bribery ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Authority ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Serious Fraud Office (SFO) ,
UK ,
UK Bribery Act
The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains.
On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more
2/14/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
EU ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
UK
Companies in the US and around the world should consider their potential for UK exposure and assess their compliance programmes in light of that risk.
On 1 September 2025, the UK will implement a new corporate criminal...more
2/13/2025
/ Corporate Governance ,
Corporate Liability ,
Corporate Misconduct ,
Criminal Prosecution ,
Enforcement Actions ,
Failure to Prevent ,
Fraud ,
Fraud Prevention ,
Multinationals ,
Risk Management ,
UK ,
White Collar Crimes
Welcome to our Litigation 2024 Year in Review and 2025 Outlook. In this report, we examine the legal trends that have shaped the commercial landscape in Europe and the UK and explore how these developments are likely to...more
2/11/2025
/ Arbitration ,
Class Action ,
Competition ,
Contract Disputes ,
Corporate Governance ,
Cryptocurrency ,
Data Privacy ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
EU ,
European Commission ,
Financial Institutions ,
Insolvency ,
Litigation Strategies ,
Mergers ,
Regulatory Reform ,
UK ,
Whistleblower Protection Policies ,
Whistleblowers
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
4/23/2024
/ Bribery ,
Cooperation ,
Corruption ,
Declination ,
Deferred Prosecution Agreements ,
Financial Action Task Force ,
Fraud ,
Non-Prosecution Agreements ,
OECD ,
Pilot Programs ,
Serious Fraud Office (SFO) ,
Strategic Enforcement Plan ,
UK ,
Whistleblower Awards ,
Whistleblowers
The US decision reminds UK companies and their officers to identify and report red flags about misconduct in the workplace.
Certain shareholders of McDonald’s Corporation (the Company) sued David Fairhurst, the Company’s...more
3/7/2023
/ Corporate Culture ,
Corporate Officers ,
Delaware General Corporation Law ,
Fiduciary Duty ,
McDonalds ,
Oversight Duties ,
Responsible Person Liability ,
Shareholder Litigation ,
Shareholders ,
UK ,
Willful Misconduct
A court recently found that UK authorities did not fetter their discretion by not investigating general cotton imports potentially produced by the forced labour of Uyghur people in China.
On 20 January 2023, the High...more
Many sectors, including financial services, have encountered a discernible increase in whistleblows in recent times — a trend that shows no signs of abating. Indeed, some whistleblowers have seen fit to publicise their...more
The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime.
In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more
11/5/2021
/ Biden Administration ,
Compliance ,
Compliance Monitoring ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Cross Border Privacy Rules (CBPR) ,
Cross-Border ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Personal Liability ,
UK ,
White Collar Crimes
The regulations will enable the UK government to sanction persons “involved” in human rights abuses — potentially anywhere in the world.
On 6 July 2020, the UK Foreign Secretary announced the introduction of the Global...more
The penalty reflects the increasingly active approach in the UK to the enforcement of sanctions breaches.
The UK’s financial sanctions regulator, HM Treasury’s Office of Financial Sanctions Implementation (OFSI), has...more
Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations.
On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more
8/10/2019
/ Cooperation ,
Corporate Cooperation Credits ,
Corporate Investigations ,
Criminal Investigations ,
Cross-Border ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Privilege Waivers ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
The DOJ’s recently updated guidance poses helpful questions for UK corporates evaluating the effectiveness of their internal compliance programmes.
It is well known that a corporate’s failure to prevent offences can be...more
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
English Court of Appeal Reaffirms Privilege Over Internal Investigation Documents Prepared in Contemplation of Litigation -
In a much anticipated decision, the Court of Appeal has reaffirmed legal privilege protection for...more
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
6/18/2018
/ Bribery ,
Costa Rica ,
Criminal Proceeds ,
Cross-Border ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
Just Compensation ,
Proceeds of Crime Act 2002 (POCA) ,
Restitution ,
Serious Fraud Office (SFO) ,
UK