Episode 345 -- Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations
Episode 333 -- The Boeing Proposed Plea Agreement
2 Gurus Talk Compliance: Episode 26 – The Compliance Week Wrap Up Edition
Episode 305 -- Deep Dive into SAP FCPA Settlement
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
What DAG Lisa Monaco's Speech Means for Compliance Programs
Federal Monitorships and Making Them Work
FCPA Compliance Report - James Koukios on the Monaco Speech
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
Episode 160 -- A Deep Dive into the Herbalife FCPA Settlement
Everything Compliance-Episode 57-the Airbus edition
Episode 119 -- The Ericsson FCPA Settlement
Episode 117 -- FCPA Update: Samsung FCPA Settlement; Braskem Former CEO Indicted; Transport CEO Convicted after Trial
This Week in FCPA-Episode 96, 2018 - the Opening Day edition
FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor
FCPA Compliance and Ethics Report Episode 129-Judge Rakoff, Judge Leon and Individual Prosecutions Under the FCPA
FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
The Serious Fraud Office (SFO) is raising the stakes. With the publication of new Co-operation and Enforcement Guidance on 24 April 2025, the agency is ramping up enforcement and clarifying expectations for corporate...more
On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more
Our White Collar, Government & Internal Investigations Team examine the Crown Prosecution Service’s first deferred prosecution agreement and what it means for future enforcement....more
On June 15, 2023, the UK Government announced that it would seek to introduce the biggest reform of corporate criminal liability in England and Wales for more than 50 years. ...more
In its second year, the Biden administration has made clear its prioritisation of white-collar prosecutions. This includes changes in policy and guidance, such as a renewed focus on individual accountability, an increased...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
CEP Magazine (January 2021) - The United Kingdom’s Serious Fraud Office published new guidance related to deferred prosecution agreements (DPAs). The guidance, nested in the office’s internal SFO Operational Handbook,...more
On 23 October 2020, the SFO published a chapter from its Operational Handbook, including an expanded section on corporate co-operation, so as to give “comprehensive guidance” on the organisation’s approach to the use of...more
The SFO faced a challenging 2019, with some high-profile acquittals, dropped investigations and new cases which were widely perceived as relatively underwhelming. We look back at the last 12 months, and set out what might be...more
As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more
The much heralded Corporate Co-operation Guidance published by the Serious Fraud Office recently offers little comfort to corporates struggling with the dilemma of whether to self-report wrongdoing. Instead it offers a...more
Is there a point at which co-operation becomes capitulation? Is there a danger inherent in co-operating without the guarantee of a favourable outcome for doing so?...more
On 6 August 2019, the UK’s Serious Fraud Office (SFO) released Guidance on what it expects from organisations seeking cooperation credit in the agency’s investigations. The long-awaited Guidance is a codified and clarified...more
Five years ago, in the spring of 2014, Deferred Prosecution Agreements ('DPAs') were first introduced in the UK through the Crime and Courts Act 2013 ('CCA').1 Since then, the Serious Fraud Office ('SFO') has concluded four...more
Corruption Watch UK has claimed that “a company committing economic crime in the US is far more likely to be hit with criminal, civil and regulatory penalties than one in the UK.” In a hard-hitting report published on 5 March...more
On 6th December 2018, the trial of two Tesco executives accused of false accounting collapsed. The judge concluded that the SFO's evidence, taken at its highest, was such that a jury could not properly convict. The SFO...more
Summary: Deferred prosecution agreements have been widely used by US prosecutors since the early 2000s. Prosecutors in the UK and France only obtained this power in 2014 and 2016 respectively – but they are making up for...more
Introduction - As part of a global crackdown on tax evasion, the Criminal Finances Act 2017 (the Act) introduced a new offence. From 30 September 2017, an organisation commits a criminal offence if an employee or...more
Speaking at the 35th annual Cambridge International Symposium on Economic Crime, Robert Buckland QC MP, the Solicitor General for England and Wales, and David Green QC, Director of the SFO, addressed the question, “Preventing...more
On July 12, 2017, the U.S. Court of Appeals for the Second Circuit ruled in United States v. HSBC Bank USA, N.A. that a federal district court does not have the authority to supervise the implementation of a deferred...more
A common feature of corporate criminal disposal in the US for several decades, the use of corporate monitors in the UK in the same period has been, at best, sporadic. This was expected to change with the introduction of...more
The UK’s growing focus on corporate criminal liability was seen in two recent pieces of news. Last Friday the government announced a consultation on extending the reach of corporate criminal liability to additional...more
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
The approval of the Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and XYZ Limited (XYZ) by Leveson LJ on 8 July 2016 has generated much breathless commentary, not least because it is only the...more
In a busy week for the Serious Fraud Office (SFO), the United Kingdom’s antibribery prosecutor, it has announced its first-ever deferred prosecution agreement (DPA) for bribery offences and the first guilty plea under the...more