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

Global cartel enforcement: Where is it heading in 2017?

John Terzaken

Depending on how you choose to read the mid-year statistics, 2017 is either trending towards record high or record low fine totals for global cartel enforcers. Fine totals in the first half of 2017 are at USD1.64bn. But this figure is heavily influenced by nearly USD1bn in fines the European Commission re-imposed on air cargo Read More

A&O SMCR reflections: Don’t overlook these things when considering employee conduct and performance issues

Sarah Hitchins

A lot of time has been spent by some firms managing conduct and performance issues under the UK Senior Managers and Certification Regime (the SMCR) over the past 15 months. In our second blog post looking at these issues (the last one is available here), we highlight key areas that firms should not lose sight Read More

Last Call for Securities Class Actions

Justin Ormand

The Supreme Court made clear this past Monday that there’s no room for hesitation in pursuing claims for securities law violations. In a 5-4 decision, the Court held in California Public Retirement System v. ANZ Securities (CalPERs) that the three year deadline for filing claims under Section 11 of the Securities Act of 1933 is Read More

A&O SMCR reflections: Managing conduct and performance issues

Sarah Hitchins

The UK Senior Managers and Certification Regime (the SMCR) has been in force now for well over a year. What challenges have firms have been facing? What are the issues that have caused firms most concern? In the first of a series of blog posts, we will be looking at issues that firms have been Read More

Kokesh is a game changer for the SEC’s FCPA Enforcement Program

Kurt Wolfe

The U.S. Supreme Court recently ruled, in Kokesh v. SEC, that a five-year statute of limitations applies to claims for disgorgement in SEC enforcement proceedings. It is an important decision that is likely to impact the SEC’s enforcement program, particularly in Foreign Corrupt Practices Act (FCPA) cases. Below, we suggest five changes that are likely to Read More