Summary
Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration.
This taskforce was announced by the UK's Serious Fraud Office (SFO), France's Parquet National Financier (PNF) and the Office of the Attorney General of Switzerland (OAG) at a meeting in London. Its founding statement notes "the significant threat of bribery and corruption" and states that its members recognise that "success relies on us working closely and effectively together". It intends to deliver a working group for case cooperation and increased best practice sharing.
The SFO, PNF, and OAG have long been active anti-corruption enforcement agencies in Europe and have a track record of working closely and well together. High-profile bribery settlements with companies on which they have collaborated include Rolls Royce 2017 and Airbus in 2020. A joint investigation into the Thales Group by the SFO and PNF was announced in November 2024.
Nick Ephgrave, the Director of the SFO, said that this commitment "reaffirms our individual and collective commitment to tackling the pernicious threat of international bribery and corruption, wherever it occurs." His comments were echoed by Jean-François Bohnert, Head of the Parquet National Financier, who said that the taskforce will "strengthen our current cooperation in order to fight more efficiently against bribery and corruption in individual cases."
Comment
The significance of this new alliance lies more in its symbolism and its timing rather than its practical effect. The taskforce announcement is light on practical detail but loudest about what it does not say, namely that it aims to positively distinguish the UK, France, and Switzerland's anti-corruption enforcement posture from that of the United States's current position on the Foreign Corrupt Practices Act ("FCPA").
This announcement comes just a month and a half after President Trump issued an Executive Order directing Attorney General Bondi to conduct a six-month review of the guidelines and policies governing FCPA investigations and enforcement actions, effectively pausing FCPA enforcement. The order came a few days after a memo from Attorney General Pamela Bondi instructing the United States Department of Justice (DOJ) to redirect its enforcement efforts away from corporate crimes like FCPA violations and toward the Administration's priorities: combating illegal immigration, drug cartels, and allegedly unlawful DEI practices. While SFO director Nick Ephgrave has indicated that this new alliance and task force "is in no way a reaction to that,"1we can expect that it may help fill the enforcement void created by the FCPA pause in the United States.
The creation of the taskforce follows efforts in recent years by European agencies to develop more nimble enforcement tools such as deferred prosecution agreements, long available in the United States and the UK, more recently introduced in France, and builds upon increasing collaboration among these agencies over the last few years. The alliance further highlights the increasing role of European regulators in leading multi-jurisdictional bribery cases, potentially reducing the DOJ's historical dominance in such investigations. Indeed, it is possible that enforcement agencies in other countries will join the taskforce in the future.
Fundamentally, the announcement offers a timely reminder to all those companies who conduct business in Europe that the investigation and enforcement of global bribery and corruption concerns remains a law enforcement priority. Anti-bribery legislation in the UK, France, and Switzerland has wide-reaching jurisdiction and permits these agencies to prosecute criminal conduct that occurs overseas, if the conduct has a link to the prosecuting country, reinforcing the need for companies operating globally to have effective compliance programs and anti-bribery measures in place.
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