Anti-Corruption & Foreign Corrupt Practices Act
Anti-Corruption & Foreign Corrupt Practices Act
Our team has unsurpassed experience in counseling and defending U.S. and foreign companies and individuals in matters relating to the U.S. Foreign Corrupt Practices Act and similar anti-corruption laws. We are frequently contacted when a potential corruption issue arises, and are go-to counsel for investigations and enforcement proceedings before the U.S. Department of Justice (DOJ), the Securities & Exchange Commission (SEC) and the Multilateral Development Banks, including the World Bank. In addition, we advise clients considering transactions in high-risk markets or with business partners with high anti-corruption risks. We also counsel clients who are designing compliance programs and in conducting risk assessments.
The SFO Issues New Guidance: More Sticks than Carrots
October 12, 2012 Read the memo
On October 9, 2012, the U.K. Serious Fraud Office ("SFO") issued revised guidance related to its enforcement of the U.K. Bribery Act. The new guidance addresses three issues: self-reporting, facilitation payments, and business expenditures for hospitalities and gifts. Most notably, the new guidance supersedes the former preference for settling self-reported cases on civil grounds and, in a noteworthy shift in tone, generally signals that under its new Director David Green, the SFO intends to function primarily in its role as a prosecuting body and not as a confidant to corporations.