Subject to Inquiry

Subject to Inquiry


Government Investigations and White Collar Litigation Group

Tag Archives: “Richard Alderman”

Enforcement and Prosecution Policy and Trends


The Serious Fraud Office has taken action in the High Court under Part 5 of the Proceeds of Crime Act which has resulted in an Order for a parent company, Mabey Engineering (Holdings) Ltd, to pay £131,201 in recognition of sums it received through share dividends derived from contracts won through unlawful conduct by one of its subsidiaries, Mabey and Johnson Limited, in which it was a principal shareholder.… Continue Reading
Enforcement and Prosecution Policy and Trends

Self reporting under the Bribery Act: Why only ten companies so far?

Incentives to self report are a major part of effective anti-corruption enforcement in the US and the Guidance issued by the Ministry of Justice attempts to lay the groundwork for a similar culture of self reporting in the UK. But, absent the same freedom to engage in plea bargaining that its US counterpart, the Department of Justice, enjoys, does the Serious Fraud Office have the tools to incentivise self reporting sufficiently?… 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
Anti-Bribery and Corruption, Compliance, Enforcement and Prosecution Policy and Trends

Is compliance with the Guidance also compliance with the Bribery Act?

Compliance with the Guidance will take companies a long way towards compliance with the Act, it will not be a complete defence in circumstances where the SFO has taken the decision to prosecute. Consequently, whenever it is eventually published, the Guidance will need to be treated with caution by companies seeking to comply with the Bribery Act.… Continue Reading

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