Subject to Inquiry

Subject to Inquiry


Government Investigations and White Collar Litigation Group

Tag Archives: “risk assessment”

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

The UK Bribery Act and Senior Officers: personal liability focuses the mind

How do you go about removing or reducing the "consent/connive" risk? There is extensive guidance on how to implement a corporate bribery compliance programme, but no guidance on measures which individual directors should take. Recent OFT competition law guidance (in the context of whether it will seek a "competition disqualification order" (CDO) against a director following a competition law breach by his company) does however provide a useful parallel… 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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