On 6 August 2019, the UK's Serious Fraud Office (SFO) released its Corporate Co-operation Guidance (SFO Guidance), joining the US Department of Justice and French Parquet National Financier and Agence Française Anticorruption in issuing new 2019 corporate enforcement guidance. All three regions provide welcome direction to assist companies towards the same destination—leniency for co-operation and avoidance of a criminal conviction via local deferred or negotiated prosecution agreements. Despite these parallels, they are not a perfect match: companies must navigate several differences in cross-border investigations on the route to a global resolution.
This Legal Update (i) examines the key aspects of the SFO Guidance; (ii) considers the differences between the UK, US and French approaches; and (iii) reflects on some of the challenges that remain for multinational companies, particularly in the context of cross-border investigations.
Downloads – Download Document
Originally published September 10 2019
Visit us at mayerbrown.com
Mayer Brown is a global legal services provider comprising legal practices that are separate entities (the "Mayer Brown Practices"). The Mayer Brown Practices are: Mayer Brown LLP and Mayer Brown Europe – Brussels LLP, both limited liability partnerships established in Illinois USA; Mayer Brown International LLP, a limited liability partnership incorporated in England and Wales (authorized and regulated by the Solicitors Regulation Authority and registered in England and Wales number OC 303359); Mayer Brown, a SELAS established in France; Mayer Brown JSM, a Hong Kong partnership and its associated entities in Asia; and Tauil & Chequer Advogados, a Brazilian law partnership with which Mayer Brown is associated. "Mayer Brown" and the Mayer Brown logo are the trademarks of the Mayer Brown Practices in their respective jurisdictions.
© Copyright 2019. The Mayer Brown Practices. All rights reserved.
This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.