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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.
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 ...
July 10, 2020, Covington Alert
On 6 July 2020, the UK Government announced the creation of a new UK human rights sanctions regime, which is the first independent UK sanctions regime to be established under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA 2018”).
July 6, 2020, Covington Alert
On July 3, 2020, the U.S. Department of Justice’s (“DOJ” or the “Department”) Criminal Division and the U.S. Securities and Exchange Commission’s (“SEC”) Enforcement Division quietly released A Resource Guide to the U.S. Foreign Corrupt Practices Act, Second Edition (the “Second Edition”). The first edition of the Resource Guide (the “First Edition”) was ...