The Bribery Act: To Disclose or Not To Disclose?
FCPA Compliance and Ethics Report-Episode 19 with Barry Vitou on Bribery Act Updates
On September 1, the new Failure to Prevent Fraud offense will come into force, which has extraterritorial effect and significantly expands corporate liability for nine types of fraud committed by associated persons. The UK...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 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
The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more