The Bribery Act: To Disclose or Not To Disclose?
FCPA Compliance and Ethics Report-Episode 19 with Barry Vitou on Bribery Act Updates
The UK SFO’s new guidance on corporate cooperation makes clear that a company must show cooperation if it is to be invited to enter into a Deferred Prosecution Agreement (DPA). No change there. So what’s different in the new...more
Knowing what’s coming is important, even if what’s coming is cold comfort. Our White Collar, Government & Internal Investigations Team reads between the lines of recent statements from key Department of Justice officials...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
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
Just when we thought 2016 was over and we could all breathe a sigh of relief, DOJ and the SEC have continued to run with a string of new enforcement actions. To all of those prognosticators, paparazzi, commentators, chicken...more
Today I conclude my series on the Rolls-Royce global anti-corruption enforcement action by taking a look what it all means going forward. The resolution is more than simply the stunning fines and penalties of £671 million...more
On 17 January 2017, the UK Serious Fraud Office (“SFO”),[1] the US Department of Justice (“DOJ”),[2] and the Brazilian Ministério Público Federal (“MPF”) announced an $800 million global settlement with Rolls-Royce plc and...more
Today I continue my exploration of the Rolls-Royce global corruption enforcement action by considering the company’s resolution in the US under the Foreign Corrupt Practices Act (FCPA). Before we dive into that, I first...more
Today I continue my exploration of the Rolls-Royce global corruption enforcement action which included the largest fine to-date under the UK Bribery Act, with its total fines and penalties under three agreements being around...more
Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more
As noted in our previous Alert in September 2013, the UK Crime and Courts Act 2013 has now come into effect this month making deferred prosecution agreements (DPAs) available to the Director of the Serious Fraud Office (SFO)...more