Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Tag Archives: “due diligence”

Anti-Bribery and Corruption, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

Anticorruption compliance is more than adopting a policy

When the prosecutors come knocking on the door with a search warrant, one of the first things they will look for is evidence as to whether the company adhered to and fulfilled the six principles of adequate procedures. If one or more of those six steps is missing, the company may have no defence to a prosecution… Continue Reading
Anti-Bribery and Corruption, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

UK Financial Services Authority fines Willis Limited, insurance brokers, for failures in its anticorruption compliance programme – some sobering lessons for all companies

So, another large insurance broker has been publicly criticised and fined. According to the FSA, this was avoidable as Willis knew what they had to do in terms of compliance and they knew the risks to their business in relation to bribery and corruption, but it appears that their compliance was inadequate in several different respects… Continue Reading
Enforcement and Prosecution Policy and Trends

Serious Fraud Office targets private equity firms

One industry which faces potentially onerous obligations under the Bribery Act 2010 about which there has been little official comment is private equity. That position changed last week. In a speech to private equity clients of the law firm Debevoise & Plimpton LLP, Richard Alderman, the Director of the Serious Fraud Office, made it clear that the Act applied as much to private equity firms as any other.… Continue Reading

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