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UK Bribery Act Enforcement Actions

The UK Bribery Act is an act of the Parliament of the United Kingdom enacted in 2010 to prevent, combat and penalize acts of bribery. The Bribery Act creates four offenses: 1) bribing another person 2) being... more +
The UK Bribery Act is an act of the Parliament of the United Kingdom enacted in 2010 to prevent, combat and penalize acts of bribery. The Bribery Act creates four offenses: 1) bribing another person 2) being bribed 3) bribing a foreign official 4) failure of a corporation to prevent bribery on its behalf. The Act provides for very stringent penalties and is considered one of the toughest pieces of anti-bribery legislation in the world.  less -
Latham & Watkins LLP

DOJ Issues New FCPA Guidelines Amid Growing Ambitions of UK and European Prosecutors

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The guidelines confirm that FCPA enforcement will continue but provide opportunities for foreign authorities to lead where US interests are not significantly impacted....more

Ropes & Gray LLP

New Case May Test the UK Bribery Act's 'Adequate Procedures' Defence

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On 17 April, the UK’s Serious Fraud Office (SFO) charged a UK-based insurance company, United Insurance Brokers Limited (UIB) with ‘failure to prevent bribery’ in connection with its international reinsurance activity in...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments: 2024 Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this special edition of our award-winning monthly Top 10 International Anti-Corruption Developments newsletter summarizes the most...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

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Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

A&O Shearman

New UK 'failure to prevent' fraud corporate criminal offence published - Update

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The Economic Crime and Corporate Transparency Act 2023 was granted Royal Assent on 26 October 2023. It contains a new ‘failure to prevent fraud’ corporate criminal offence which will render large companies liable for fraud...more

A&O Shearman

New UK 'failure to prevent' fraud corporate criminal offence

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A draft ‘failure to prevent fraud’ corporate criminal offence will render large companies liable for fraud committed by their associates. We consider the draft offence and implications for businesses....more

A&O Shearman

New UK 'failure to prevent' fraud corporate criminal offence published - Update 9/6/2023

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A draft ‘failure to prevent fraud’ corporate criminal offence will render large companies liable for fraud committed by their associates. We consider the draft offence and implications for businesses....more

BCLP

Fallout from the Glencore resolutions & lessons learned

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On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more

WilmerHale

Failure to prevent bribery

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On 14 April three individuals and three companies were sentenced for their role in a bribery scheme spanning nine years. The prosecution merits consideration because, as well as securing convictions for corruption and...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

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Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

A&O Shearman

Testing ABAC compliance programmes: lessons from recent enforcement actions

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Recent Deferred Prosecution Agreements (DPAs) show the UK Serious Fraud Office (SFO) scrutinising companies’ compliance programmes. All of the companies which entered into DPAs relating to bribery had anti-bribery and...more

A&O Shearman

A decade of the UK Bribery Act - lessons for companies from enforcement actions so far

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The UK Bribery Act 2010 (UKBA) turns ten years old on Thursday. What can companies learn from concluded UKBA enforcement actions in the past decade?...more

A&O Shearman

Woefully inadequate anti-bribery measures lead to deferred prosecution agreement for aircraft refurbishment company

A&O Shearman on

The SFO has concluded a deferred prosecution agreement with Airline Services Limited (ASL), a UK supplier of aircraft cabin parts and services, for failure to prevent bribery under s7 Bribery Act 2010.  Despite the company...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of COVID-19 on White Collar Enforcement

While enforcement agencies have yet to indicate that they intend to put their pens down in response to COVID-19, there is anecdotal evidence that some agencies have slowed their investigations as remote working impacts matter...more

Mitratech Holdings, Inc

Global Voices: Beating Bribery – Best Practice in Ethics and Conduct on the Global Stage

One of the biggest headaches for companies conducting business overseas still remains bribery and corruption. The grey area of what is deemed a fair gift, meal or payment against what might be constituted a bribe is a...more

BCLP

Bribery Act review: economic crime and failure to prevent offences

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The government published in May 2019 its responses to two Committee reports on financial crime. First,  the House of Commons Treasury Committee on 8 March 2019, published its report on “Economic Crime – Anti-money laundering...more

White & Case LLP

Deferred Prosecution Agreements 5 Years On – the Americanisation of UK Corporate Crime Enforcement

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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

BCLP

Anti-Corruption Enforcement: Analyzing the Enforcement Approaches of the US, the UK and France

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Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more

BCLP

What enforcement tools are in the armoury of prosecutors in the US, UK and France?

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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

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - March 2018

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

Latham & Watkins LLP

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

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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

Bracewell LLP

Modern Enforcement: Rolls-Royce’s $800 Million Global Settlement

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Rolls-Royce plc, a UK-based company that manufactures engines and generators for the aerospace, defense, marine, and energy sectors, has agreed to pay over $800 million to resolve parallel investigations by U.S., UK, and...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part IV – What Does it all Mean?

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

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