Welcome to Allen & Overy’s Investigations Insight blog, sharing with you our views and insights into the latest trends, risks and developments in financial services investigations

Hong Kong SFC Investigation Priorities

Ryan Middlemas

A recent speech by Thomas Atkinson, the new Director of Enforcement for the Securities and Futures Commission (SFC), may herald changes to the SFC’s enforcement priorities. The SFC has also announced that it would be conducting a comprehensive review of its investigation processes in response to independent criticism. What does that mean for the enforcement Read More

SEC Whistleblower Update

Kurt Wolfe

There have been several noteworthy developments at the U.S. Securities and Exchange Commission’s Office of the Whistleblower over the last several weeks.[i] To summarize, recent developments underscore the whistleblower program’s success at attracting tips; highlight its continuing appeal to whistleblowers who live outside the United States; and demonstrate the SEC’s commitment to curb retaliation against Read More

Cease and desist – or not? Challenging the SFO’s discretion to investigate

Stacey McEvoy

In a case the first of its kind, Soma Oil And Gas Ltd (Soma) sought, by way of judicial review, to require the Serious Fraud Office (SFO) to cease its long-running investigation into potential bribery and corruption offences committed in Somalia by Soma. While expressing its ‘sympathy’ with Soma’s position, and exhorting the SFO to Read More

The Criminal Finances Bill: Part Two

Calum Macdonald

In our second piece on the recently published Criminal Finances Bill 2016-17, we turn to the proposed Unexplained Wealth Orders regime and new disclosure powers for use in money laundering investigations that regulators will receive.   Unexplained Wealth Orders: Explain An Unexplained Wealth Order (UWO) is an order granted by the High Court at the application of Read More

Diving into the depths of dark pool pricing

Stacey McEvoy

Following on from the FCA’s Thematic Review on Dark Pools, the FCA published in September an Occasional Paper on “Asymmetries in Dark Pool Reference Prices”, concluding that the net amount of arbitrage from reference price latency (ie where the pricing offered in a dark pool is stale) is relatively small (economically speaking), but when it Read More