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

Woefully inadequate anti-bribery measures lead to deferred prosecution agreement for aircraft refurbishment company

The SFO has concluded a deferred prosecution agreement with Airline Services Limited (ASL), a UK supplier of aircraft cabin parts and services, for failure to prevent bribery under s7 Bribery Act 2010.  Despite the company having received external legal advice on ABAC policies and procedures, it had failed to implement the recommendations adequately: Serious Fraud Read More

SFO releases guidance on deferred prosecution agreements

On 23 October 2020, the SFO published another chapter of its gradually evolving Operational Handbook (the Handbook), this time covering the invariably attention-grabbing topic of Deferred Prosecution Agreements (DPAs). This newest addition to the Handbook, which follows and complements last year’s chapter on corporate co-operation, may not present those who are familiar with the SFO’s Read More

Legal resilience: lessons learnt from recent crises

Back in March, many of my colleagues were fielding urgent and complex Covid-related legal queries.  Many of the questions were familiar to those who remembered other recent crises, and caused us to think about what organisations could learn about legal resilience, including around dealing with regulators and compliance issues. This has resulted in A&O’s very Read More

Listing applications by cannabis companies – FCA statement

The FCA has clarified its approach to applications to list in the UK made by cannabis-related companies.  The statement acknowledges the uncertainty surrounding cannabis-related ventures from a money laundering perspective, given the distinction between recreational cannabis companies and those operating in the medical space.  Those in the former category are prevented from listing in the Read More

Future challenges in economic crime: a view from the SFO

“Future challenges in economic crime: a view from the SFO” was the title of a speech that Lisa Osofsky, Director of the SFO, gave on 8 October 2020. The speech, which touches upon new challenges as well as old ones, also sets out Ms Osofsky’s wish list for the SFO going forwards. A month earlier, Read More