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
New guidance about what to expect if self-reporting to the SFO
16 August 2019 - Post by:
The Director of the SFO, Lisa Osofsky, confirmed back in April of this year that she would “soon be issuing guidance for corporates and their legal advisers to provide them with added transparency about what they might expect if they decide to self-report fraud or corruption to my office.” This Guidance was published as an › Read More
U.S. continues aggressive sanctions and anti-money laundering enforcement against non-U.S. banks
24 July 2019 - Post by:
When assessing anti-money laundering risk and exposure, global financial institutions should be mindful of the complex landscape and assertions of broad authority by U.S. authorities and banking regulators. U.S. banking regulators, in conjunction with U.S. criminal and civil authorities, have traditionally pursued anti-money laundering and sanctions enforcement cases against multinational banks in relation to conduct › Read More
Parent company atones for the crimes of a subsidiary
18 July 2019 - Post by:
The fifth DPA, between the SFO and Serco Geografix Ltd, is the first in which a parent company has undertaken to pay a penalty and oversee a group wide reinforcement of its compliance programme even though it was not liable for the underlying fraud and false accounting by its subsidiary. Also worthy of note are › Read More
Should I breach confidentiality to report suspected criminality?
03 July 2019 - Post by:
A recent case throws up some interesting issues concerning when it is OK (and when it is not OK) to breach confidence in order to report suspected criminality. The case concerned some private investigators who decided to report their clients for suspected criminal conduct, rather than keep confidential the results of their investigation: Saab & › Read More
SFO rhetoric about cooperating witnesses continues to pile on the pressure
20 June 2019 - Post by:
Lisa Osofsky, Director of the UK’s Serious Fraud Office (SFO), has talked about wanting to bring cases to life for juries by relying on cooperating offenders to give evidence against senior individuals. She reinforced this message last week at the GIR Live, Women in Investigations conference. The SFO’s aim here is to bring more senior › Read More