The Bribery Act: To Disclose or Not To Disclose?
FCPA Compliance and Ethics Report-Episode 19 with Barry Vitou on Bribery Act Updates
In a recent alert, we highlighted the United Kingdom (UK) benchmark manipulation cases of Tom Hayes and Carlo Palombo from 2015 and 2019, respectively. Hayes was the first banker to be jailed in the LIBOR scandal....more
Documents, including interview notes, generated by mining company ENRC during an internal corruption investigation were protected by privilege and therefore did not have to be disclosed to the Serious Fraud Office (SFO). ...more
Welcome to BakerHostetler’s 2017 Mid-Year Cross-Border Government Investigations and Regulatory Enforcement Review. This edition delivers news, analysis and insights into key developments in the cross-border investigations...more
Europe at a glance - Across Europe, law makers are steadily expanding the circumstances in which companies can be found liable (whether criminally or otherwise) for the criminal conduct of their employees and other...more
Tom Hayes emerges from his trial at Southwark Crown Court for Libor manipulation as a very considerable loser, who took some very bad decisions in the course of the SFO investigation and trial (and perhaps deserves his long...more
The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more
On August 14, 2013, the Serious Fraud Office (SFO) charged three British nationals with offenses under the UK Bribery Act 2010. This is the first Bribery Act prosecution brought by the SFO. While it is impossible to discern a...more