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Serious Fraud Office Issues Cooperation Guidance
August 23, 2019, Covington Alert
The Serious Fraud Office (SFO) released its much-anticipated cooperation guidance on August 6, 2019. The five-page document sets out the steps an organization can take to assist the SFO in an investigation and thereby maximise the organization’s chances of avoiding prosecution. The publication represents a welcome change in direction on the part of the SFO, which has previously refused requests to provide guidance on how a company should respond to an SFO investigation. However, there are elements of the new guidance which might cause companies unease.
February 15, 2021, Covington Alert
On 5 February 2021, the UK Supreme Court handed down its judgment in an appeal by KBR, Inc. (KBR) against the High Court’s refusal to quash a document production notice served on it by the Serious Fraud Office (SFO). Among other grounds, KBR—a U.S.-incorporated company that has UK subsidiaries but does not itself have a place of business or carry on business in ...
Winter 2021, Covington Alert
As we noted in a recent client advisory, we have observed an upward trend in recent years in anti-corruption enforcement activity in Africa, including cross-border cooperation between African law enforcement authorities and their counterparts in the U.S. and UK. Looking ahead to 2021 and beyond, we see no reason to expect this trend to reverse. While 2020 did ...
September 4, 2020, Covington Alert
It has been over twenty years since the OECD Anti-Bribery Convention came into force, over a decade since the enactment of the UK Bribery Act, and over three years since the passage of France’s Sapin II law. Alongside those ground-breaking developments have come a host of other measures across the Europe, Middle East, and Africa (“EMEA”) region to strengthen ...