Andrew Thornton-Dibb

Photo of Andrew Thornton-Dibb Andrew advises clients on contentious multi-jurisdictional regulatory issues, including regulatory investigations and prosecutions, the U.K. Bribery Act and other white collar crime matters involving global fraud and corruption.

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Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

By Benjamin A. O'Neil, Alex J. Brackett, Andrew Thornton-Dibb and Jah Akande on September 21, 2022 Anti-Bribery and Corruption

On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). The São Paulo-based company, whose shares are traded on the New York Stock Exchange, consented to a cease-and-desist order with the SEC… Continue Reading

DOJ Publishes FCPA Declination on Cross-Border Bribery Investigation

By Benjamin A. O'Neil, Francesca Titus, Andrew Thornton-Dibb and Elissa Baur on March 31, 2022 Anti-Bribery and Corruption

Without fanfare, DOJ recently published a “declination and disgorgement letter,” the first FCPA declination published by the Department since August 2020.… Continue Reading

UK set to shake up Corruption and Money Laundering Enforcement

By Andrew Thornton-Dibb on October 13, 2016 Anti-Bribery and Corruption, Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends

The UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law. The Government hopes that the Bill “will significantly improve the government’s ability to tackle money laundering and corruption, recover the proceeds of crime, and counter terrorist financing”, and… Continue Reading

The Anti-Corruption Summit – UK plans for further corporate criminal offences, and a host of other proposals

By Andrew Thornton-Dibb on May 12, 2016 Anti-Bribery and Corruption, Anti-Money Laundering, Compliance

The UK’s Prime Minster David Cameron has just hosted the “Anti-Corruption Summit”, a first of its kind, bringing together world leaders, business, and civil society with the goal of seeking to agree on a package of steps to: Expose corruption so there is nowhere to hide Punish the perpetrator and support those affected by corruption Drive… Continue Reading

The SFO’s “ongoing” investigation into Alstom – Further Charges

By Andrew Thornton-Dibb on March 29, 2016 Anti-Bribery and Corruption

We originally wrote in 2014 about charges that had been brought in September of that year by the UK’s Serious Fraud Office against the French Multinational’s UK subsidiary, Alstom Network UK Ltd, and two former employees and British nationals for corruption offences (under pre-Bribery Act era legislation) relating to transport projects in India, Poland, and Tunisia.… Continue Reading

SHARPER TEETH FOR SANCTIONS ENFORCEMENT?

By Andrew Thornton-Dibb on March 7, 2016 Anti-Bribery and Corruption, Compliance

The current UK sanctions enforcement regime is a complicated web reflecting the requirements of UN Security Council Regulations, EU Regulations, and UK Primary and Secondary Legislation. Penalties for breaches of sanctions are generally set out in the various statutory instruments that implement particular sanctions. The UK Government, through the Policing and Crime Bill that is… Continue Reading

The SFO’s ‘Seize and Sift’ Procedure

By Andrew Thornton-Dibb on February 8, 2016 Anti-Bribery and Corruption, Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims

R (on the application of Colin McKenzie) v Director of the Serious Fraud Office saw an unsuccessful attempt to judicially review the SFO’s currently in-use procedure for dealing with material that it has seized, and which may contain content subject to legal professional privilege (“LPP”). This ‘procedure’, set out in the SFO’s Operational Handbook, provides… Continue Reading

The Serious Fraud Office bribery charges against Alstom

By Andrew Thornton-Dibb on September 30, 2014 Anti-Bribery and Corruption, Enforcement and Prosecution Policy and Trends

“From this autumn, we will start to see cases adopted by us, under our recalibrated focus on top tier work, coming to trial…we have much in the pipeline.” David Green CB QC, Director of the SFO, addressing the Cambridge Symposium on Economic Crime on 2 September 2014 One such case is the SFO’s bribery case,… Continue Reading

UK Government’s Response to the Department for Business, Innovation and Skills “Whistleblowing Framework: Call For Evidence”

By Andrew Thornton-Dibb on July 22, 2014 Anti-Bribery and Corruption, Compliance, Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims

Crucially businesses should be confident that reprisals against whistle-blowers are not an issue for them, and that their organisation understands and trusts any whistleblowing policy and procedure they have in place. Deficiencies in these areas may very well lead to a Regulator challenging the overall effectiveness and adequacy of an organisations compliance programme.… Continue Reading

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