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Compliance matters: meeting SFO expectations

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29 April 2020 / Annabel Kerley , Jonny Frank
Issue: 7884 / Categories: Features , Criminal
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Jonny Frank & Annabel Kerley offer practical guidance for companies under investigation

 

In brief

 

  • Covers the Serious Fraud Office guidance on compliance programmes.
  • Offers practical tips and steps to follow for companies whose compliance programmes are under investigation.

The UK Serious Fraud Office (SFO) published updated guidance within its Operational Handbook on the effectiveness of corporate compliance programmes in January. The guidance, ‘Evaluating a compliance Programme ’, speaks loudly to organisations, both on the importance of effective remediation and being prepared for the SFO to review the compliance programme itself, in addition to a criminal investigation into the underlying facts (see https://bit.ly/2SayBxl).

In these types of enquiries, time is of the essence, so global and UK-based companies must act immediately. To help get started, below are actionable takeaways for remediation tactics that should meet the SFO’s expectations as well as tips to help organisations prepare for an investigation into their compliance programme.

 

Steps for effective remediation

 

In deciding whether to prosecute, the guidance

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