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Food for Thought: Individuals Remain in SFO’s Sights as Four From Patisserie Valerie Charged With Fraud

Individuals continue to face risk from prosecutions for economic crime, despite media focus on corporate criminal liability reforms. Four individuals have today appeared at Westminster Magistrates’ Court charged with fraud...more

SFO’s International Investigatory Powers Curbed in Supreme Court Ruling

Landmark decision holds that the SFO does not have the power to procure documents from foreign companies outside the jurisdiction. On 5 February 2021, the UK Supreme Court handed down a highly significant judgment in R...more

UK SFO Releases Guidance on Corporate Cooperation Credit

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

SFO Update: Lisa Osofsky’s First 50 Days

New SFO Director reaffirms her intentions and priorities for the agency. Fifty days have passed since Lisa Osofsky took over at the UK’s Serious Fraud Office (SFO), pledging to be a “different kind” of director....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

Internal Investigations Protected By Privilege Once 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

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

English High Court Decision Further Curtails Application of Legal Privilege in Internal Investigations

Corporations should take steps to ensure their internal investigations are not used against them in English litigation. A recent decision in an English court could have important consequences for internal corporate...more

Changes to Corporate Criminality Offences in the UK Cause Corporate Dealmakers to Review Acquisitions

Proposed changes to corporate criminal offending should cause corporate dealmakers to review the scope of acquisition diligence, particularly in light of the UK Serious Fraud Office’s (SFO’s) increasing use of deferred...more

Check Your Privilege: English Court Rules Internal Investigation Materials Cannot be Withheld from Prosecutor

“Privilege is a fundamental human right guaranteed by the common law, and a principle which is central to the administration of justice. Once a document is subject to privilege, the privilege is absolute: it cannot be...more

Firsts for UK SFO with in principle false accounting DPA, and for FCA with market abuse compensation, against Tesco

Following a two-year investigation, Tesco PLC has announced that its subsidiary Tesco Stores Limited (Tesco Ltd) had agreed in principle the terms of a Deferred Prosecution Agreement (DPA) with the UK Serious Fraud Office...more

Prosecuting Corporate Offending - A New Approach from the Serious Fraud Office

Deferred prosecution agreements (DPAs) became part of the prosecutors’ toolbox in 2014, allowing for settlement instead of bringing a case to trial. Recent statements from the Serious Fraud Office (SFO) indicate an increasing...more

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