In Second DPA, SFO and U.K. Court Focus on Cooperation, Self-Reporting and Compliance

Recently a U.K. court approved the second Serious Fraud Office application for a DPA. The identity of the counterparty remains confidential but is understood to be a small to medium-sized U.K. entity wholly owned by a U.S. corporation. The first DPA which was approved by the same judge in November 2015, was with Standard Bank, a regulated institution that settled for what could be perceived as a more stringent penalty. More recently, financially troubled Sweett Group was prosecuted after failing to cooperate in the SFO’s investigation. In a guest article, Elizabeth Robertson, a partner at Skadden located in London, discusses the key features of the most recent DPA and examines the differences between it, the Standard Bank case and the Sweett Group case offering insights on anti-corruption enforcement in the U.K. See “Lessons From the U.K. Sweett Group Prosecution” (Mar. 23, 2016).

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